The outbreak of COVID-19 has caused confusion about the testing process for Part 107. The largest testing organization, CATS/PSI, has closed all of their physical test centers across the United States from March 19 until at least April 13. Unfortunately, it is likely that this date will be extended given the closure of many non-essential businesses across the country and that it will not be possible to take a Part 107 test at an FAA-approved testing center for the foreseeable future.

This means that aspiring Part 107 Remote Pilots are currently unable to take their initial exam. It also puts those who need to take the recurrent examination in a difficult position. Some Remote Pilots who needed to take the recurrent exam before the end of March were unable to do so, and many more Remote Pilots will need to take the recurrent exam by the end of April.

What can I do if I was unable to take the recurrent exam in March?

At this moment in time, official FAA regulations regarding testing and currency have not changed. Once you pass the initial Part 107 exam, your certificate is valid for 24 months, until the end of the 24th month. If you do not renew your certificate prior to the end of the 24th month by taking the recurrent exam, you are not able to exercise the privileges of your Part 107 certificate.

Current FAA guidance is that unfortunately, if you needed to take the recurrent exam before the end of March and you were unable to do so, you are not allowed to utilize your Part 107 certificate.

According to current regulations, you will not have to take the initial exam again. Even if your certificate lapsed at the end of March, once the FAA devises a solution, you will just need to take the recurrent exam to continue utilizing your Part 107 certificate.

What do I do if I need to take the recurrent exam in April?

If you need to take the recurrent exam in April, remember that you do not need to take the recurrent exam until the end of the month, so there is no need to worry (yet).

What is the likely solution to this issue?

The FAA is aware that these issues exist, and they are working on a solution.

One potential solution could be for the FAA to grant a temporary exemption for Part 107 operators who need to take the recurrent exam, allowing them to continue operating until testing centers are reopened as long as they continue to follow Part 107 regulations.

Another potential solution could be to allow those needing to take the recurrent exam to take the abbreviated online exam on the FAA website that current Part 61 pilots are able to take to add a Part 107 certification.

Unfortunately, neither of these solutions seem like an adequate replacement for the initial exam, but we hope the FAA will provide a way for aspiring Remote Pilots to take the initial exam and earn their Part 107.

What action should I take if I’m running a drone program?

As of early April, the testing issue only affects those who want to take the initial exam or those who were not able to take the recurrent exam in March.

If you are strictly complying with Part 107, you should not allow these Remote Pilots to operate as a Remote Pilot in Command until they have taken the recurrent exam.

However, drone programs will have to evaluate the effect of grounding competent, non-current RPICs, and the level of risk to your operation if you have to ground multiple RPICs, especially if you’re operating an essential business with limited personnel.

For example, the FAA has provided guidance for other parts of the aviation community that enforcement actions will not be taken against required pilot crew members or flight engineers whose medical certificate expires from March 31 through June 30 of this year.

How can grounded RPICs be useful?

As long as a current RPIC supervising the operation can take the control of the sUAS if needed, you can still have a non-current RPIC flying sUAS operations.

Part 107.12(a)(2) states that a person may manipulate the flight controls of a small UAS as long as they are “under the direct supervision of a remote pilot in command and the remote pilot in command has the ability to immediately take direct control of the flight of the small unmanned aircraft.”

Another way that grounded RPICs can be useful is as a visual observer (VO) in any operation that requires a VO or could be made safer by the presence of an experienced VO.

How can I stay informed about this issue?

We will update our user community as more information from the FAA becomes available. Be sure to follow Kittyhawk on social media and LinkedIn for the latest information and updates.

If you would like to discuss this situation and the effect it has on your drone operations, get in touch with me at andrew@kittyhawk.io.

Additional information is available at https://www.faa.gov/coronavirus/, as well as the FAA’s social media accounts.

Fly safe!

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