Part 91 COW vs. Part 107: Understanding the New Regulatory Standard for Police and Fire Drone Programs with the Shielded Operations Waivers
Updated February 2026
This post replaces our June 2025 article “COA vs. Part 107: Which Path Is Best for Police and Fire Drone Operations?” to reflect major FAA regulatory changes.
The Regulatory Landscape Has Changed
The regulatory landscape for public safety drone operations has changed dramatically.
If your department is still operating under the old Certificate of Authorization (COA) framework — or if you've been hesitant to pursue beyond visual line of sight (BVLOS) operations because of the lengthy approval process — there’s good news:
The FAA has streamlined everything.
The traditional COA process that once took 6–10+ months has been replaced by a new Certificate of Waiver (COW) framework.
What’s changed:
Processing times dropped from months to as little as 1–2 weeks
Some Drone as First Responder (DFR) waivers approved in under 2 hours
Waiver validity extended from 2 years to 4 years
Visual observers no longer required for many BVLOS operations
In this post, we’ll break down the two primary pathways now available to public safety agencies and help you determine which is right for your department.
The Big Picture — What Changed?
The Old Way (Pre-2025)
COA applications processed through FAA Air Traffic Organization
6–10+ month processing times
Required rooftop visual observers for BVLOS
2-year validity
Monthly reporting requirements
Complex NOTAM filing
The New Way (2025–Present)
Certificate of Waiver (COW) processed through FAA Flight Standards
1–2 week processing times (some same-day approvals)
Visual observers replaced by detection equipment (ADS-B In)
4-year validity
No monthly reporting
Simplified application via email or FAA DroneZone
This shift was driven by the FAA Reauthorization Act of 2024 (Public Law 118-63), which streamlined processes for public safety drone operations and formally defined “Public Safety Organizations” under Section 926(e).
Understanding Your Two Options
Public safety agencies now have two distinct pathways for BVLOS and DFR operations.
Option 1 — Part 107 PSO Shielded Operations Waiver
Best for:
Volunteer fire departments
501(c)(3) search and rescue organizations
Public safety organizations that may not qualify for Public Aircraft status
Key Features
Available to ANY Public Safety Organization (PSO)
Does NOT require Public Aircraft Operator (PAO) status
BVLOS up to 1 statute mile from the Remote Pilot in Command
Operations up to 200 feet AGL
No visual observers required
Requires Part 107 Remote Pilot Certificate for all pilots
What Gets Waived
107.31 (Visual line of sight)
107.39 (Operations over human beings)
107.145 (Operations over moving vehicles)
Important:
This waiver does NOT waive airspace authorization requirements (107.41).
If operating in controlled airspace:
You must apply separately for a Wide Area Authorization (WAA) through FAA DroneZone
LAANC cannot be used with BVLOS waivers
Option 2 — Part 91 PAO/PSO Shielded Operations Waiver
Best for:
Municipal police departments
County sheriff’s offices
Fire districts
Governmental entities qualifying as both PAO and PSO
Key Features
Requires BOTH PAO and PSO status
Two altitude tiers available:
200-foot waiver
Primary collision avoidance via obstruction shielding + ADS-B In
400-foot waiver
Requires FCC-approved DAA (Detect and Avoid) systems meeting ASTM/RTCA standards
No distance limitations (operational limits still apply)
No visual observers required
Broader operational flexibility
What Gets Waived
14 CFR 91.113 (Right-of-way / see-and-avoid rules)
14 CFR 91.119 (Minimum safe altitudes)
91.126–91.131 (Certain airspace communication requirements)
14 CFR 91.155 (Basic VFR weather minimums)
Critical Distinction — Part 91 Does NOT Require Part 107 Certificate
Part 91 operations do NOT require pilots to hold a Part 107 Remote Pilot Certificate.
Under Part 91, agencies may self-certify their aircraft and pilots. This means:
The department is responsible for establishing training standards
The department must verify pilot competency
The department must defend its internal training if an incident occurs
This flexibility can also increase liability exposure.
Why We Still Strongly Recommend Part 107 Training and Certification
Even under Part 91, we strongly recommend Part 107 certification for all pilots because it provides:
A recognized baseline of aeronautical knowledge
Portable credentials if officers transfer
Demonstrated compliance with FAA testing standards
Reduced liability exposure
A foundation for internal documentation
Professional certification that upskills employees that they can use outside of work
Part 107 certification adds professionalism, protects your officers, and reassures the public that your department is operating responsibly.
Which Path Is Right for Your Department?
You Likely Qualify for Part 107 PSO Waiver If:
You’re a volunteer fire department
You’re a 501(c)(3) search and rescue organization
You receive reimbursement (e.g., FEMA)
You’re a private ambulance service providing public safety support
You want the simplest and fastest path to BVLOS
You May Qualify for Part 91 PAO/PSO Waiver If:
You’re a political subdivision (city, county, state, tribal government)
Your agency owns the aircraft or leases exclusively for 90+ days
Operations are strictly governmental
You do NOT receive compensation
You do NOT fly commercially
Pro Tip:
If uncertain about PAO status, consult legal counsel. Operating under the wrong framework creates liability risks.
The Application Process
Part 107 PSO Shielded Operations Waiver
Step 1: Prepare Documentation
Agency letter certifying PSO status per PL 118-63 Section 926(e)
Signed FAA checklist
Concept of Operations
Step 2: Submit via FAA DroneZone
Log in
Select Part 107 Waiver Application
Attach documentation
Step 3: Apply Separately for Airspace Authorization (If Needed)
Submit Wide Area Authorization (WAA)
Allow 60+ days for controlled airspace
Processing Time: 1–2 weeks typical
Part 91 PAO/PSO Waiver
Step 1: Verify Eligibility
Confirm PAO status under 49 USC 40102(a)(41) and 40125
Confirm PSO status under PL 118-63 Section 926(e)
Step 2: Prepare Documentation
Letter certifying PAO + PSO status
FAA Form 7711-2
Appropriate checklist
Concept of Operations
Step 3: Submit via Email
Send to: 9-AVS-AFS-750-91.113Waivers@faa.gov
Processing Time: 1–2 weeks typical
Common Application Mistakes That Cause Delays
The FAA frequently sees:
Letters that fail to reference PSO qualification per PL 118-63
Missing Responsible Person signature
Submitting Public Declaration Letter instead of PSO certification
Unsigned or incomplete checklist
Illegible submissions
Missing equipment specs
While the process is faster, it’s not simpler. A single documentation error can reset your timeline.
DFR — The Numbers Tell the Story
Old COA Process vs. New COW Process
Processing time: 10+ months → 1–2 weeks (some under 2 hours)
DFR waivers (2018–2024): ~50 total
DFR submissions (as of June 2025): 300+
DFR approvals: 214+
Validity: 2 years → 4 years
Monthly reporting: Required → Not required
Visual observers: Required → Not required
DFR adoption has accelerated dramatically.
What About Existing COAs?
If you currently operate under a COA:
Continue operating under your current COA
Begin applying for a Shielded Operations COW ASAP
COAs will NOT be renewed under the old process
A new COW does NOT automatically cancel your COA
There is no operational gap during transition.
Looking Ahead — Part 108 BVLOS Rulemaking
The FAA is developing Part 108 for permanent BVLOS rules.
NPRM published: August 7, 2025
Comment period closed: October 6, 2025
Limited comments reopened: Through February 11, 2026
Final rule expected: Spring 2026
Agencies investing now in compliant equipment and documentation will be positioned well when Part 108 becomes law.
Our Recommendation — Start with Part 107, Then Expand
Get pilots Part 107 certified
Apply for Part 107 PSO Shielded Operations Waiver
If eligible, pursue Part 91 PAO/PSO waiver for additional flexibility
Invest in hands-on training
Regulatory compliance is only the beginning. Tactical proficiency matters.
Need Help Getting Started?
V1DroneMedia provides:
Shielded Operations Waiver Application Assistance
Advanced Public Safety Drone Training: Search & Rescue and Tactical Drone Operations
Our instructors combine aviation and real-world police operational expertise
👉 Request Drone Training Consultation
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Drone as a First Responder: How Drones Are Changing Emergency Response
At a Glance
Drone‑as‑a‑First‑Responder (DFR) programs are reshaping public safety. By pre‑positioning drones at launch sites and dispatching them automatically after a 911 call, agencies can arrive on scene in minutes with real‑time video. The technology promises faster response times, improved situational awareness, greater officer and public safety, and lower operating costs than helicopters. Ohio cities like Cincinnati and Dublin are proving DFR works. As the FAA prepares to normalize BVLOS operations through Part 108, now is the time for agencies, businesses and organizations to understand the investment, regulatory and community considerations associated with starting a DFR program. This post dives into the mechanics, benefits, costs and future outlook of DFR.
Introduction
A drone‑as‑a‑first‑responder (DFR) program takes the idea of using drones for public safety to the next level. Instead of dispatching a small uncrewed aircraft system (UAS) only when a human operator arrives on scene, DFR programs pre‑position drones at launch stations across a city and deploy them automatically or remotely as soon as a 911 call is received. These drones travel to the incident in minutes and livestream video back to dispatch, giving officers or firefighters en route crucial intelligence about what is happening. DFR programs remain new, but departments in Ohio and across the United States are proving that this model can improve response times, increase safety and reduce costs.
This post explains how a DFR system works, outlines the benefits driving adoption, highlights examples from Ohio, and considers what the trend means for first responders, small businesses and organizations with in‑house drone programs.
What Is a Drone‑as‑a‑First‑Responder Program?
A DFR system consists of pre‑positioned drones, launch stations and integrated software that connects to existing 911 or computer‑aided dispatch (CAD) systems. When a call comes in, a remote pilot (or an autonomous system) launches the nearest drone and sends it directly to the coordinates of the incident. The drone’s onboard cameras – typically high‑resolution optical and infrared sensors – stream video back to incident command, allowing personnel to assess conditions before ground units arrive. Many DFR systems use rooftop docks that protect the aircraft from weather and keep batteries charged so the drones are always ready to fly. Sense‑and‑avoid sensors such as ADS‑B receivers or radar help the drone detect other aircraft and navigate safely, while geofencing software keeps the drone within approved boundaries.
Because the drone is deployed immediately, it often arrives within minutes of the call – sometimes before any human responder. In the Chula Vista Police Department’s pioneering DFR program, drones reached the scene in under 2.5 minutes on over 4,000 calls, and more than 1,000 deployments showed that no officer needed to be dispatched because the drone footage indicated the situation did not warrant a physical response. This model is still relatively new because it requires operations beyond visual line of sight (BVLOS), over people and at night – activities prohibited under the FAA’s standard Part 107 rules. Agencies must obtain a Certificate of Authorization or BVLOS waivers, and they need to demonstrate rigorous safety procedures and pilot training.
Why Departments Are Adopting DFR
DFR programs appeal to public safety agencies because they deliver tangible benefits:
1. Rapid response times. Drones can be dispatched within seconds and often arrive before ground units, enabling responders to make critical decisions faster.
2. Enhanced situational awareness. High‑resolution cameras and sensors provide real‑time aerial views so dispatchers and officers can see the layout of the scene, track suspects or locate victims.
3. Increased safety for officers and the public. Because drones act as a first set of eyes, officers can assess threats from a safe distance and even decide not to engage when a response is unnecessary.
4. Cost‑effective operations. Drones can cover large areas quickly, reducing the manpower needed for search operations, and their operating costs are much lower than crewed aircraft like helicopters.
5. Versatile functionality. Modern drones can carry infrared cameras, thermal sensors, two‑way communications, and even spotlight or loudspeaker systems, making them useful for search‑and‑rescue, firefighting, surveillance and negotiation scenarios.
6. Improved data collection and documentation. Recorded video streams are valuable for investigation, training and refining response strategies.
Examples from Ohio
Ohio has emerged as a leader in DFR adoption, with two cities piloting large‑scale programs in 2024–2025. These examples demonstrate how DFR can be tailored to local needs.
Cincinnati Police Department
In July 2024 the Cincinnati Police Department (CPD) launched a Drone‑as‑a‑First‑Responder program in partnership with Axon and Skydio. Police Chief Teresa Theetge described the technology as “game‑changing” and said it would allow the department to identify risks, respond faster and deploy resources more efficiently. CPD initially stationed drones in neighborhoods such as Price Hill, Over‑the‑Rhine, Queensgate, the West End, Downtown and the University of Cincinnati area, covering about 40 % of the city. By the end of 2025, the department plans to expand coverage to 90 %. Skydio executive Noreen Charlton called it the largest DFR deployment in the Midwest. CPD emphasizes that drones respond only to dispatched calls and are not used for random surveillance, addressing potential privacy concerns.
Dublin Police Department
Dublin, Ohio, implemented its own DFR program in 2024 using four DJI M30 drones housed in autonomous rooftop docks. The drones can be launched remotely by certified officers and reach an incident within 90 seconds, traveling up to 45 mph. Each drone carries infrared cameras and can stay aloft for 30–35 minutes. The program costs about $492,000 over three years and builds on Dublin’s initial drone program launched in 2019. Twenty‑two of the city’s 75 officers are currently certified pilots, and more are being trained. Dublin expects to deploy drones multiple times per day and may share them with neighboring jurisdictions. The program’s planners note that as drone technology and regulatory approvals mature, municipal DFR programs are becoming more practical and are no longer seen as experimental. Watch video below for more details on their program.
Implications for Different Entities
First Responders
For police, fire and EMS agencies, DFR offers a way to boost effectiveness without adding more personnel. Rapid aerial intelligence can help incident commanders allocate resources wisely, reduce officer exposure to dangerous situations and potentially de‑escalate encounters by giving officers a clearer picture of what awaits them. DFR footage can also document scenes for investigations or training purposes, aiding transparency and accountability. Departments considering DFR must invest in training, safety protocols and community engagement, and they should plan for FAA approval of BVLOS operations.
NEW: Ohio Launches New Statewide Drone-as-a-First-Responder Pilot Program (2025–2027)
Ohio recently became the first state in the country to launch a state-supported Drone-as-a-First-Responder (DFR) Pilot Program, created under HB 96 and administered by ODOT’s DriveOhio UAS Center. The program will provide selected police, fire, EMS, and sheriff agencies with a fully reimbursed, turnkey DFR capability, including a Drone-in-a-Box system (an automated station for drone housing, launch, landing, and charging), NDAA-compliant aircraft, software, DFR training, FAA support, and standardized operational templates.
Selected agencies will participate in a two-year evaluation to measure how rapid aerial response improves situational awareness, response times, and safety outcomes across urban, suburban, and rural regions.
The application window for the first cohort closed on November 26, 2025.
Small Business Owners
DFR programs create opportunities and challenges for small businesses. On the supply side, drone service providers can partner with local governments to set up launch docks, maintain fleets, operate flights or process data. Companies that specialize in inspection, security or event management can adopt similar rapid‑response models for private clients, using drones to monitor property, infrastructure or large venues. On the demand side, small businesses may benefit indirectly when police and fire departments use DFR to improve public safety and reduce property damage. Entrepreneurs should keep abreast of local privacy policies and procurement rules, especially in states that restrict the purchase of drones from certain foreign manufacturers.
Organizations with In‑House Drone Departments
Corporations, utilities and large institutions often maintain their own drone programs for inspections, security and logistics. The DFR model illustrates how remote operations and autonomy can increase efficiency: by pre‑positioning drones at strategic points, organizations can respond to alarms or hazards without sending personnel, reducing downtime and exposure to risk. Integrating drones with existing incident management software and automating launch and return cycles can streamline operations. However, organizations must evaluate whether the increased investment in docking stations, sensing technology and regulatory compliance is justified by their operational needs.
Considerations and Challenges
While DFR programs offer many benefits, agencies must navigate regulatory and practical hurdles. BVLOS operations, flights over people and night operations require FAA waivers and rigorous safety cases. Public trust and privacy are essential; the Department of Homeland Security suggests publishing flight logs and encrypting data to address privacy concerns. Agencies must also budget for hardware, maintenance, training and compliance costs. Additionally, the National Defense Authorization Act of 2024 restricts federal funding for drones made with components from certain foreign entities, which may influence equipment choices.
Part 91, Part 108 and the Future of BVLOS
As of late 2025 and now effective in 2026 FAA has released new regulatory standard for public safety programs - Certificate of Waiver under Part 91, which replaces Certificate of Authorization, and comes with built-in Beyond Visual Line of Sight operational capability once approved and the law enforcement pilots are trained. Learn more about Part 91 COW operations and application process in our blog post Part 91 COW vs. Part 107: Understanding the New Regulatory Standard for Police and Fire Drone Programs
In spring 2025 the FAA released draft rules for a new Part 108 that will normalize routine BVLOS operations for highly automated drones beyond first responder programs. The Notice of Proposed Rulemaking states that Part 108 will cover operating rules for BVLOS flights of highly automated drone systems—including aircraft over 55 pounds—and set requirements for the design and manufacture of BVLOS‑capable drones. The proposed rules introduce several important changes:
Operator certification. Organizations wanting to fly BVLOS at scale will need to become Certified Operators and document their safety management systems, roles and procedures.
No new pilot certificate. Instead of requiring a new license, Part 108 creates operational roles such as Operations Supervisor and Flight Coordinator; qualified personnel must be trained by their organization[.
Drones must declare compliance. Unlike the waiver process under Part 107 and Part 91, Part 108 requires drones to have a “declaration of compliance” demonstrating they meet technical safety standards for automated BVLOS flight.
Right‑of‑way in shielded areas and multi‑drone operations. Under Part 108, drones operating in shielded areas near fixed infrastructure have right‑of‑way over manned aircraft, while operators must use Electronic Conspicuity (EC) to detect aircraft outside shielded areas. The rules also explicitly allow one operator to manage a fleet of highly automated drones, enabling larger area coverage and opening the door to continuous DFR patrols.
The proposed rules include a 60‑day public comment period, after which the FAA will finalize the rule, with an executive order targeting a March 2026 completion. During this transition, existing Part 107/Part 91 waivers remain valid. For public safety agencies, Part 108 could streamline DFR programs to scale up rapidly. However, the requirement for highly automated, compliant drones means agencies must evaluate whether their current equipment will qualify or whether upgrades are needed. DFR programs that invest now in automated platforms and robust safety documentation will be well positioned to transition to Part 108 when it becomes law.
Costs and Resources
Hardware, software and staffing
Implementing a DFR program requires significant up‑front investment in drones, docking stations and software. MITRE’s analysis of the Chula Vista program found that each drone—including high‑resolution cameras, sensors and software—costs about $35,000 and that staffing remote pilots at four launch locations costs about $400,000 per year. These expenses provide 98 % coverage of the city’s 52 square miles. Dublin, Ohio’s program illustrates a mid‑size investment: four drones, docks and support infrastructure cost roughly $492,000 over three years.
Commercial providers offer packaged solutions with leasing options. For example, a DFR bundle including a drone dock, sensor payload and service plan can cost $16,599, while annual software subscriptions like DroneSense may be $8,970. Agencies can also lease hardware; a DJI Dock 2 may cost $20,000 and a ground‑based detect‑and‑avoid (DAA) system another $25,000, with software and regulatory costs around $10,000. Remote drone pilots can be hired on contract at about $60 per hour. Costs vary widely depending on the number of drones, sensors, launch sites and staffing model.
First Responder agencies must consider organization of their DFR programs, such as who controls and directs the automated drone release, monitors its video feed and coordinates operations with the officers on the scene. All of the program participants also have to be trained to utilize the hardware, understand program limitations, and conduct field communications.
Ongoing maintenance and other expenses
Running a DFR program also entails recurring costs: battery replacements, dock maintenance, software licensing, data storage and cybersecurity. Agencies must invest into pilot training and recurrent certifications, and may need to hire technical staff to integrate drone feeds with dispatch systems. The Department of Homeland Security notes that agencies must plan for equipment, infrastructure, maintenance and training costs as well as the expense of complying with regulations such as remote ID and NDAA purchase restrictions. Typical cost categories include purchasing drones and hardware, software licensing, personnel training, obtaining regulatory approvals, ongoing maintenance and operations, and community engagement and data management solutions.
Despite these costs, DFR remains cheaper than traditional air support. A single police helicopter can cost millions of dollars to purchase, and fuel costs alone can run hundreds of dollars per hour. DFR systems provide similar overwatch capability at a fraction of the price, delivering multiple perspectives by deploying several drones simultaneously.
V1Dronemedia provides assistance with every type of drone program setup for first responder agencies, including Shielded Operations & Drone as a First Responder regulatory training and program setup: program consultations, application for Certificate of Waiver under Part 91, operational drone training (FAA regulatory & hands-on pilot training), and hardware purchase assistance. Request a free consultation today. We also provide Part 107 Regulatory Training
Community and Stakeholder Considerations
Public acceptance and privacy
DFR programs will succeed only if the community accepts them. MITRE’s report notes that organizations like the ACLU and Electronic Frontier Foundation worry that drones could gradually expand from emergency response into routine surveillance. Past missteps—such as the Seattle Police Department’s aborted drone program following public protests—highlight the risk of launching without community support. Transparency is critical: publishing policies, procedures and flight logs and engaging the public before deployment. The DHS TechNote echoes this, advising agencies to encrypt data, comply with privacy frameworks like HIPAA and CJIS, and plan data retention policies carefully.
Facilities and partnerships
Launching a DFR program requires physical space for launch stations, often on rooftops of police stations, firehouses or community facilities. Agencies should coordinate with local governments and property owners to site docks strategically and ensure safe flight paths. Collaboration with fire departments and emergency medical services can broaden the benefits; MITRE notes that many police departments share drone livestreams with fire departments to improve coordination during fires or vehicle accidents. Partnerships with universities or technology vendors can provide expertise in software integration, data analytics and maintenance.
Stakeholder engagement
Stakeholders include elected officials, community leaders, civil liberties organizations, and the broader public. Agencies should hold informational sessions, demonstrate the technology, and solicit feedback to address concerns. Clear policies limiting drone use to dispatched calls—as Cincinnati and Chula Vista do—can help assuage fears of unwarranted surveillance. Agencies should also develop communications plans to explain how DFR can improve response times, protect officers and save money compared to helicopters.
Conclusion
Drone‑as‑a‑first‑responder programs are reshaping public safety by delivering rapid aerial intelligence to emergency responders. By stationing drones across a jurisdiction and integrating them with dispatch systems, agencies like Cincinnati and Dublin are improving response times, enhancing situational awareness and reducing risk to officers and the public. The model is still maturing, but advances in autonomy, sense‑and‑avoid technology and regulatory frameworks are making widespread adoption more feasible. Whether you’re a public safety official, a small‑business owner looking to leverage drone services, or an organization running an internal drone program, understanding the DFR concept will help you plan for the future of uncrewed aviation.
Currently most police departments operate their drone programs under Part 107 or COA, both of which require special BVLOS waivers to set up DFR programs or to fly Beyond Visual Line of Sight. As of 2026, if an agency is considering setting up their Drone as a First Responder program, they will have to apply for Certificate of Waiver (COW) under Part 91, which includes BVLOS operations. If an agency wants to fly Beyond Visual Line of Sight with Part 107 pilots, then they will need to apply for Shielded Operations Waiver. V1Dronemedia can assist with COW & Shielded Ops Waiver applications, as well as DFR program training and setup. Request a consultation about which drone program is right for you, and we will provide a clear path for your agency. Stay informed about regulatory and other drone industry changes that effect law enforcement by signing up for our Drone Newsletter for First Responders. Check out our Basic and Advanced Training Programs for First Responders, and DFR & Shielded Ops programs.