Part 108 Flight Coordinator: Duties, the 5-Hour Rule, and Ratios

Under proposed Part 108, the person watching your BVLOS drone wouldn’t be called a pilot, wouldn’t need an FAA airman certificate, and might not touch a stick at all. They’d be a Flight Coordinator.

The FAA picked that term on purpose. It changes who can do the job, how they qualify, and what they answer for. This guide walks through the Flight Coordinator role as written in the FAA and TSA notice of proposed rulemaking published August 7, 2025, mainly proposed 14 CFR 108.310, with the sections that feed into it.

One caution up front. Part 108 is still a proposal. The final rule has been under White House review since July 10, 2026, and nothing has published in the Federal Register as a final rule. Today, BVLOS work still runs on Part 107 waivers and exemptions. For the full picture of where the rule stands, start with our Part 108 BVLOS guide.

What is a Part 108 Flight Coordinator?

The proposed definition in 108.3 is short: a Flight Coordinator is “an individual who monitors an unmanned aircraft system operating under this part and that can control, initiate emergency actions, or issue commands to the unmanned aircraft during flight.”

Three words in that definition do most of the work. Monitors, because the default job is watching a highly automated aircraft and its systems. Initiate emergency actions, because the coordinator is the human who steps in when something goes wrong. Issue commands, because Part 108 aircraft wouldn’t be flown with a joystick. Proposed 108.810(a) would bar direct manual control, so any input goes through the automation as simple commands like a new altitude, airspeed, or heading.

The FAA chose “flight coordinator” over “pilot” to avoid confusion with manned pilots and Part 107 remote pilots in command. Under Part 107, safety rests largely on one person. Under Part 108, it rests on the aircraft design, the operator’s procedures, and several roles, with the coordinator handling tactical oversight of individual aircraft.

Is a Flight Coordinator always required?

No, and this is the part people miss. Proposed 108.310(a) says the operator must designate a Flight Coordinator before each flight if the manufacturer’s operating instructions require one.

The FAA openly contemplates fully automated flight. If an aircraft can handle normal operations and emergencies on its own, and the manufacturer says no coordinator is needed, the rule wouldn’t force one. The proposal even adjusts Remote ID for that case: under proposed 108.200, the broadcast wouldn’t have to include control station location when the aircraft is flying without a Flight Coordinator.

For anything short of full autonomy, expect the manufacturer to require a coordinator. In that setup the coordinator provides direct oversight, even if they aren’t actively steering, and watches the systems that keep the flight safe.

What the Flight Coordinator would actually do

Proposed 108.310(d) gives the core duties. The person assigned as Flight Coordinator must:

• Take appropriate action to keep the aircraft from posing an undue hazard to people, aircraft, or property, within their control.
• Maintain situational awareness of the aircraft and direct it as needed to stay compliant with the rules.

Both duties carry the same limit: within the limitations of the UAS design. A coordinator can’t be blamed for failing to do something the system doesn’t let them do. They can be on the hook for not doing what it does let them do.

A few other sections hand the coordinator specific authority:

• Emergency deviation. Proposed 108.215(b) lets the Flight Coordinator deviate from any Part 108 rule to the extent needed to meet an in-flight emergency that requires immediate action. The operator then owes the FAA a report within 10 business days under 108.45(f).
• Lighting. Proposed 108.110(c) lets the coordinator dim or turn off the aircraft’s lighting when operating conditions make that safer. The FAA’s example is takeoff and landing, where bright lights can wreck night vision that takes about 30 minutes to recover.
• Handoffs. Proposed 108.310(c) allows control to pass from one coordinator to another mid-flight, but only if the company operations manual has handoff procedures. The FAA’s example is a coordinator having a medical emergency.

The 5-hour rule: how someone qualifies

This is the most concrete requirement in the section. Under proposed 108.310(e), nobody could serve as a Flight Coordinator until they have at least 5 hours of operating experience in the specific make and model they’ll be working with.

The FAA based the number on the 5 hours required of a flight engineer under 14 CFR 63.37. Its reasoning is that the core job, watching critical systems and coordinating emergency procedures, is similar, and that heavy automation and simple controls mean the experience doesn’t need to be long. The agency asked for comment on whether 5 hours is enough, so this number could change in the final rule.

Those 5 hours must be flown under direct supervision. The proposal lists who can supervise:

• A fully qualified Flight Coordinator
• An Operations Supervisor
• A person the operator has qualified and designated to make sure personnel are trained

The FAA says direct supervision has to let the supervisor step in or correct a mistake, which may mean a clear view of the trainee’s actions and active communication. Training scenarios count toward the hours.

Proposed 108.310(b) bars anyone from directing an aircraft unless they’re a qualified, authorized coordinator, with a carve-out for trainees logging those supervised hours.

The first-coordinator problem

A new operator has an obvious puzzle: you can’t be supervised by a qualified coordinator if you don’t have one yet. The FAA answers this in Table 1 of the preamble.

• Certificated operators, first cadre: the Operations Supervisor or a designated training person can supervise.
• Permitted operators, first cadre: only the Operations Supervisor. Permit holders wouldn’t need a training program, so there’s no separate training person to lean on.
• Once coordinators exist: a fully qualified coordinator can supervise new ones, along with the Operations Supervisor, and for certificated operators, the designated training person.

Because a qualified coordinator would be needed before real flights start, the first cadre has to get its hours during setup, before operations begin.

Staying current: 5 hours every 12 calendar months

Qualifying once isn’t enough. Under proposed 108.310(f), a coordinator must have served as Flight Coordinator for at least 5 hours on the same make and model within the preceding 12 calendar months. If that lapses, 108.310(g) says the operator must requalify them before they work that make and model again.

Note what’s tied to what. Currency is per make and model, not general. A coordinator who’s sharp on one aircraft isn’t automatically current on another.

Worked example: a new inspection company

Say a small utility inspection company applies for a Part 108 operating permit with one aircraft model and three people. The owner is the Operations Supervisor. Two technicians will be Flight Coordinators.

Before the first paid flight, both technicians need 5 hours each on that model. Since this is a permitted operator building its first cadre, the owner, as Operations Supervisor, has to directly supervise all 10 of those hours. They can come from training flights over the company’s own test site.

In March the company adds a second model. Each technician needs another 5 supervised hours on it. Once one qualifies, that technician can supervise the other.

Then one technician moves mostly to office work and logs only 3 hours on the original model over the next 12 calendar months. That person has lapsed on that model and must be requalified before serving as its coordinator again. Track it per person, per model.

One coordinator, how many aircraft?

Proposed 108.210 sets the default at 1:1, one aircraft per Flight Coordinator. Going higher, often called 1:many, would require a method acceptable to the FAA, likely through future industry consensus standards or case-by-case review, much like how package delivery and agricultural exemptions are reviewed today.

There are two ceilings on any ratio above 1:1:

• The manufacturer’s maximum in the operating instructions. You can’t exceed it.
• What the coordinator can actually handle during normal, abnormal, and emergency conditions. That can be lower than the manufacturer’s number.

The FAA says the manufacturer’s ratio reflects the technology under ideal conditions. The operator’s ratio also has to account for weather, human factors, population density, and detect-and-avoid tools.

Worked example: a delivery shift at 1:3

Say a delivery operator has FAA acceptance for up to three aircraft per coordinator, and the manufacturer allows five. On a clear morning, one coordinator runs three routes. Two hours into the shift, a storm cell starts moving toward one route and another aircraft reports a degraded link.

The accepted ratio is a maximum, not a permission slip for every condition. If that coordinator can’t safely handle three aircraft through the abnormal event, the operation needs a planned response: hand aircraft to another qualified coordinator under the manual’s handoff procedures, hold departures, or land early. The coordinator acts on the aircraft in front of them. Whether the operation keeps flying at that ratio is a question for the Operations Supervisor, which we cover in our Operations Supervisor guide.

Training, fitness, and security

Beyond the hour requirements, a Flight Coordinator would fall under the general personnel rules that apply to all operations personnel:

• Training (108.315). General topics like airspace, weather, crew resource management, transfer of control, and multi-aircraft operations, plus make-and-model training on emergency, lost link, and detect-and-avoid procedures. Current within 24 calendar months.
• Medical (108.320). No serving with a condition that would interfere with safe operation. No FAA medical certificate.
• Alcohol and drugs (108.325). Eight hours bottle to throttle, no serving while under the influence, and a 0.04 alcohol concentration limit.
• Duty and rest (108.330). A 14-hour duty day, a 50-hour duty week, 10 hours of continuous rest in the 24 hours before duty, and one full day off per week.
• Security (108.335). People performing Flight Coordinator functions would be covered persons who need a TSA security threat assessment.

Edge cases worth settling in your manual

Your Part 107 certificate doesn’t transfer. Part 108 wouldn’t require airman certificates at all. Your Part 107 experience is useful, but it wouldn’t count as the 5 hours on a Part 108 make and model unless you actually log those hours on that aircraft.

Recreational permits are different. Under proposed 108.475, recreational permit holders would be exempt from the 5-hour and recency requirements in 108.310(e) and (f), along with some other operator duties.

A handoff without procedures isn’t allowed. If your manual doesn’t have handoff procedures, 108.310(c) wouldn’t let you transfer control mid-flight. Write them before you need them.

What to do now

1. Log hours by make and model today, even under Part 107 waivers.
2. Draft handoff procedures and a 1:1 default before planning any 1:many work.
3. Pick who will supervise your first cadre and budget the hours.
4. Build a simple currency tracker: person, model, hours in the last 12 calendar months.
5. Watch for the final rule. The 5-hour number and ratio rules could change.

The takeaway

The proposed Flight Coordinator is a make-and-model specialist, not a licensed pilot. Five supervised hours to start, five every 12 calendar months to stay current, 1:1 unless the FAA accepts more, and the authority to break a rule when an emergency demands it. None of it is law yet.

Primary sources

FAA and TSA, Normalizing Unmanned Aircraft Systems Beyond Visual Line of Sight Operations, notice of proposed rulemaking, 90 FR 38212, August 7, 2025. Final rule review status: OIRA, RIN 2120-AL82.