This week the FAA announced, with great fanfare, its decision to raise the minimum altitude of the Blanket COA from 200′ to 400′. This action will greatly ease the administrative burden on both FAA and operators, and is estimated to eliminate between 30% and 40% of all of the COA requests that FAA has to process on a daily basis. The FAA’s announcement did not, however, highlight the other major change that came to the blanket COA, a greatly expanded FAA reporting requirement.

Under the old 200′ Blanket COA, there were 6 different types of malfunctions that were supposed to be reported to the FAA, along with any lost link events. The 400′ Blanket COA has a new section that has extensive additional incident, accident, and mishap reporting requirements. Within 24 hours, an operator is now required to report accidents where there is a:

  1. Fatal injury, where the operation of a UAS results in a death occurring within 30 days of the accident/mishap
  2. Serious injury, where the operation of a UAS results in: (1) hospitalization for more than 48 hours, commencing within 7 days from the date the injury was received; (2) results in a fracture of any bone (except simple fractures of fingers, toes, or nose); (3) causes severe hemorrhages, nerve, muscle, or tendon damage; (4) involves any internal organ; or (5) involves second- or third-degree burns, or any burns affecting more than 5 percent of the body surface.
  3. Total unmanned aircraft loss
  4. Substantial damage to the unmanned aircraft system where there is damage to the airframe, power plant, or onboard systems that must be repaired prior to further flight
  5. Damage to property, other than the unmanned aircraft.

Similarly, the operator is required to report any incident where there is:

  1. A malfunction or failure of the unmanned aircraft’s on-board flight control system (including navigation)
  2. A malfunction or failure of ground control station flight control hardware or software (other than loss of control link)
  3. A power plant failure or malfunction
  4. An in-flight fire
  5. An aircraft collision involving another aircraft.
  6. Any in-flight failure of the unmanned aircraft’s electrical system requiring use of alternate or emergency power to complete the flight
  7. A deviation from any provision contained in the COA
  8. A deviation from an ATC clearance and/or Letter(s) of Agreement/Procedures
  9. A lost control link event resulting in
    1. Fly-away, or
    2. Execution of a pre-planned/unplanned lost link procedure.

The COA requires both an initial report as well as follow-on reports that must be made after the completion of a safety investigation. The COA also reminds operators that many of these mishaps are also events that must be reported to the National Transportation Safety Board under 49 CFR Part 830.

So, as with all administrative burdens, the FAA giveth and the FAA taketh away. While operators are filling out this new paperwork, they should take solace in the fact that they are giving the FAA the type of real-life safety data that will form the basis of future FAA rulemaking that will further open the skies for beyond line of sight or congested area operations.

Originally posted March 31, 2016