Part 91 COW vs. Part 107 for Public Safety Drones
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.
How to Choose the Right Path for a DFR Program (2026 Guide)
If you're looking into launching a Drone as First Responder (DFR) program—or expanding one—you’re stepping into a regulatory landscape that has changed quickly.
Not long ago, public safety drone operations were built around two main paths:
Part 91 (Public Aircraft Operations), typically using the COA (Certificate of Authorization) framework
Part 107, where agencies could apply for waivers to expand beyond standard limitations
Both paths worked—but neither was simple when it came to scaling DFR.
If you wanted to fly beyond visual line of sight (BVLOS):
Under Part 91, you typically needed a COA with significant coordination and documentation
Under Part 107, you had to stack multiple waivers, often with long approval timelines
In most cases, approvals could take 6–10+ months, and operational flexibility was limited.
That system has now been replaced.
The FAA has shifted to a Certificate of Waiver (COW) framework, designed specifically to streamline public safety drone operations.
What that means in practice:
Approvals now often take weeks instead of months
Some DFR waivers are being approved in days—or even hours
Many operations no longer require visual observers
Agencies are scaling DFR programs much faster
👉 Bottom line:
DFR is no longer experimental—it’s operational.
Which brings us to the question most agencies are trying to answer now:
👉 Do we operate under Part 91 or Part 107—and which one is right for us?
The Two Paths (Without the Jargon)
At a high level, every public safety drone program falls into one of these two frameworks:
Part 107 (Where Most Agencies Start)
This is the most common entry point, especially for:
Volunteer fire departments
Nonprofits and search & rescue
EMS providers
Agencies working with contractors
You’re operating under FAA rules as a civil drone operator with a waiver.
In practice:
Pilots must hold a Part 107 certificate
You apply for a waiver (typically Shielded Operations for DFR)
It’s the fastest and most accessible way to launch
👉 If you’re just getting started, this is usually the path.
➡️ Learn more: How to get your Part 107 license
Do DFR pilots need a Part 107 certificate?
If you're operating under Part 107, yes—it’s required.
Under Part 91, technically no. But most agencies still require it anyway.
Why?
Because it:
Creates a standardized knowledge baseline
Reduces liability exposure
Makes your program more defensible
Part 91 (Public Aircraft Operations)
This is typically available to:
Police departments
Sheriff’s offices
Government agencies
Here, you’re operating as a public aircraft operator, which gives you more flexibility—but also shifts more responsibility to your agency.
Key difference:
The FAA does not require Part 107 certification
Your agency defines training, standards, and oversight
👉 More flexibility—but also more accountability.
Do volunteer fire departments qualify for Part 91?
In most cases, no.
Volunteer departments, nonprofits, and private EMS providers usually do not meet the federal definition of a public aircraft operator.
That means they operate under Part 107 instead.
Quick Reality Check
Not a government entity? → You’re almost certainly operating under Part 107
Government agency? → You may qualify for Part 91, depending on structure
Getting this classification right early is critical.
Where Advanced DFR Programs Fit: Shielded Operations
Most DFR programs today want to be structured around Shielded Operations.
That simply means:
Flying low (typically ≤200 ft)
Using buildings and terrain as natural separation from aircraft
The drone is being operated Beyond Visual Line of Sight (BVLOS)
This model is what makes DFR scalable:
Safer operations
Faster approvals
Lower equipment costs
👉 For most agencies, this is the practical starting point.
➡️ Read more:What are Shielded Operations?
Do we need a waiver to run a DFR program?
Yes.
DFR programs rely on BVLOS (Beyond Visual Line of Sight) operations—and those require a waiver under current FAA rules.
Does a waiver mean we can fly anywhere?
No.
A waiver allows how you operate—not where.
You may still need additional airspace authorization, especially near airports or controlled airspace.
Part 91 vs. Part 107 — What Actually Matters
Instead of getting buried in regulations, here’s what matters operationally:
Pilot Requirements
Part 107 → FAA-certified pilots required
Part 91 → Agency-defined training
Operational Flexibility
Part 107 → More structured
Part 91 → More flexible
Liability
Part 107 → FAA sets the standard
Part 91 → Your agency defines (and defends) the standard
👉 This is one of the biggest strategic differences between the two paths. However since there is no written standard, the agency needs to document and implement these standards. We now offer DFR Implementation Support for any first responder agency in the US to help you customize and define the operational standards.
Is DFR considered surveillance?
No—and it’s important to be clear about that.
DFR programs are designed for:
Emergency response
Real-time situational awareness
Officer and community safety
They are not intended for general surveillance.
That said, state laws still apply.
For example, in Ohio:
👉 House Bill 77 requires law enforcement to obtain a warrant for most drone-based surveillance activities.
➡️ Read more here: Ohio New Drone Law HB 77
What equipment is required for DFR and Shielded Operations?
At a high level:
Remote ID compliant aircraft
Anti-collision lighting
ADS-B detection capability
Reliable communications
Your exact setup depends on your waiver and program scale.
Where Most Agencies Should Start
For most departments, the best path is:
👉 Start with Part 107 → expand into Part 91 (if eligible)
How long does it take to launch a DFR program?
A realistic timeline:
Planning: 30–60 days
Waiver: a few weeks to a few months
Training + deployment: 30–90 days
👉 Most agencies can be operational in 2–4 months.
The Most Common Mistake
It’s not technical—it’s strategic.
👉 Agencies choose the wrong regulatory path at the beginning.
How do we know if DFR will work for our agency?
You need to evaluate:
Regulatory eligibility
Airspace complexity
Call volume
Staffing
Budget
👉 This is exactly what a DFR readiness assessment is designed to answer.
➡️ Start here: Request DFR Implementation Support
Final Takeaway
There isn’t one “best” path—only the right one for your agency.
Part 107 → fastest way to launch
Part 91 → expanded capability (if eligible)
The agencies that succeed with DFR:
Make the right decision early
Build training and policies correctly
Scale intentionally
🚀 Ready to Build Your DFR Program?
We help agencies:
Determine Part 91 vs Part 107 eligibility
Prepare waiver applications
Design scalable DFR programs
Train pilots for real-world operations
👉 Request a DFR Implementation Consultation
👉Explore Public Safety Drone Training Basic and Advanced Courses (Part 107, Hads-On Drone Operations, Search & Rescue, Tactical Operations)
Need Help Getting Trained?
Additional Public Safety Resources: :
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
👉 Subscribe to our First Responder Newsletter
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.