Part 108 Readiness Checklist: What a BVLOS Operator Can Prepare Now

Status: Proposed rule, not yet effective. Last checked: September 30, 2026. This checklist describes the FAA’s August 2025 proposal, not permission to fly BVLOS today. The final rule may change the details. If your operation needs a waiver under current rules, a draft Part 108 permit will not replace it.

Part 108 can feel like a paperwork problem until you try to map one real job. A company may know its aircraft, crew and route, yet still be unable to show which operating path fits, where it can fly, what happens on a lost link, or who owns the records. Use this worksheet to find those gaps before the rule is final. It is a planning tool, not an FAA application or a declaration that your operation complies.

Start with one mission, not your whole company

Write down a single proposed BVLOS job: the customer, launch and landing points, route, altitude, aircraft and payload, expected flight count, and the people and property below. Mark whether it is package delivery, agriculture, aerial surveying, civic interest, training, demonstration, recreational use, or flight testing. Those are the permit categories in proposed § 108.400; an operation outside them would need FAA authorization. A certificate has a narrower list of named categories in proposed § 108.500, with other types subject to FAA authorization. Do not assume a company’s marketing label maps cleanly to a category.

For a roof survey, “we inspect roofs” does not answer whether the proposed operation is aerial surveying, where it crosses public roads, or whether the roof is beside an airport. Sketch the actual route and label every segment. For a delivery run, include the pickup and handoff locations, not merely the straight line between them. Keep the first worksheet narrow so a failure is visible.

1. Choose the proposed operating path

• Record the mission category and why it fits the proposed permit or certificate language.
• List the aircraft’s weight, dimensions, speed and manufacturer-designated uses, and the number of aircraft you want to operate.
• Check the population categories along the route, the airspace, and any proposed over-people activity. A low-risk rural route and a route over a busy shopping area are not interchangeable.
• Write down which limits would force a certificate or a different route, rather than assuming a permit scales indefinitely.

The proposal gives smaller operations an operating permit route and more complex or higher-risk operations a certificate route. Both would require an FAA-issued authorization before operating under Part 108. A certificate application adds items such as a training program, communication and ground risk assessments, a safety management system, and a duty/rest plan. Read the detailed split in our permit versus certificate guide. Your answer here should be a documented working hypothesis, not a claim that the FAA has approved it.

2. Define the operating area and an alternate landing plan

Proposed § 108.165 puts responsibility on the operator to obtain FAA approval for each intended operating area before beginning there. On a map, mark the route, takeoff and intended landing sites, alternate landing areas, obstacles, roads, sensitive sites and likely people below. For each alternate, ask whether the aircraft can reach it with the proposed reserve power, whether overflight there is allowed, and whether it avoids undue risk to people or property.

Example: a construction-progress flight may stay over one job site on paper but need an off-site landing when wind or battery state changes. A parking lot is not automatically safe because it is close. Note parked cars, moving pedestrians, gates and the person who can secure the location. If you cannot name a safe reachable alternate, keep the row open.

3. Check airspace and ground exposure

Proposed § 108.180 treats operations in Class B, C, D and certain surface Class E airspace differently from an unconstrained rural route. The proposal calls for an approved method of strategic deconfliction and conformance monitoring in those areas, with additional detect-and-avoid conditions in Class B and C and FAA authorization for designated airspace. Proposed §§ 108.185 and 108.190 tie over-people categories and some denser-area operations to other safeguards. An open-air assembly is generally off-limits under the proposal unless specifically authorized.

For every route segment, note the airspace class, applicable restrictions, population category by time of day, whether strategic deconfliction is needed, and who supplies it. A Thursday afternoon roof job may differ from the same route beside a Saturday event. Do not substitute an old LAANC approval for a future Part 108 operating-area approval or assume a map screenshot settles the question.

4. Match the aircraft to the job

Proposed § 108.105 would require an aircraft and associated elements in safe condition, an FAA airworthiness acceptance for ordinary Part 108 operations, and the applicable equipment requirements. Ask the manufacturer which operations, conditions and limitations its documents support. Record the exact model and configuration, not just the brand. A payload, firmware update or battery change can alter what needs to be assessed.

Collect the manufacturer’s operating and maintenance instructions and its configuration document. Proposed §§ 108.130 and 108.135 would make these documents and a current company operations manual accessible to relevant crew. The manual should cover preflight, weight and balance, emergency and lost-aircraft recovery, maintenance, records, reporting and hazardous-material handling where applicable. “We have an SOP” is not enough if nobody can identify its revision or use it during a shift.

5. Name the people and prove their currency

The proposal would put operational responsibility on the company, not create a new FAA Part 108 pilot license for each person. Proposed § 108.305 calls for one or more qualified Operations Supervisors; § 108.315 calls for training suited to each operations person’s duties. A Flight Coordinator may need to monitor and intervene in a flight depending on the aircraft and operation. Build a roster with names, assigned roles, training evidence, aircraft and task qualifications, recent activity and who covers an absence. See our separate guides to the Operations Supervisor and Flight Coordinator roles.

If you expect a certificate, budget for the formal training program in proposed § 108.540 and the duty/rest plan in § 108.505. Proposed § 108.330 sets duty and rest limits for operations personnel. A five-person schedule that works for one demonstration may fail when two routes overlap or a coordinator is out sick. Draw an actual weekly roster before saying the operation is staffed.

6. Test command link, lost link and weather decisions

Walk through a loss of command-and-control link at the worst point on the route. What does the aircraft do? Who receives the alert, what do they see, how long do they wait, and where can it land? Certificate applicants would need a communication assessment covering command-and-control coverage, availability, monitoring and lost-link procedures under proposed § 108.550. Even if you expect a permit, this scenario is a useful engineering test, not an optional box to wave away.

Proposed § 108.170 requires preflight checks of weather, route restrictions, ground obstacles, aircraft condition, staffing, applicable deconfliction, reserve power, weight and balance, attached objects, and navigation and communication systems. Turn each into a go/no-go question with an owner and a source. “Weather looks fine” is not the same as comparing route-specific winds and visibility to manufacturer limits and a safe alternate.

7. Make records retrievable before flights multiply

Proposed § 108.40 is specific: aircraft service time and life-limited parts; flight time, date, route, altitude, registration, operation type and personnel; personnel qualifications and assignments; and maintenance and other records. Proposed § 108.45 adds reporting and aircraft usage/reliability data. Pick one sample flight and see whether you can export its path, crew, aircraft configuration, maintenance status and incident trail without searching five phones.

A spreadsheet can be a useful start if it has an owner, version control, backups and a repeatable way to retrieve a flight. A pretty dashboard is not proof. If a field is missing today, record who will gather it and how. Do not manufacture historical entries to make the workbook look complete.

8. Build the application evidence, then separate permit and certificate extras

For a proposed permit, § 108.405 lists applicant and base information, the Operations Supervisor, operation type and area, company manual, recordkeeping and reporting processes, aircraft types, and other information FAA may request. A proposed certificate application under § 108.505 asks for those basics and more: a training program, communication and ground risk assessments, a safety management system, hazardous-material procedures, inoperative-equipment procedures, and duty/rest compliance. Proposed § 108.560 ties a certificate holder’s SMS to Part 5. The FAA may still ask for demonstrations and further documentation.

Create one folder per mission with a dated evidence index. Use columns for item, source, owner, revision, gap, next action and proposal section. Do not build a “submit now” packet from the NPRM: there is no final Part 108 application to submit yet. When the rule is final, compare every row against the final text and FAA instructions before treating the packet as current.

Three quick readiness tests

1. One rural survey route: Can you identify the proposed operation category, permitted aircraft configuration, area approval, alternate landing point, Operations Supervisor, crew, record fields and lost-link response? If yes, you have a starting dossier, not approval.
2. Same route over a town event: Reassess population exposure, open-air assembly restrictions, deconfliction, personnel and landing choices. “Same aircraft” does not mean “same risk.” Move the route or time if the new case does not fit.
3. Two aircraft on overlapping shifts: Check the proposed Flight Coordinator coverage, crew training and duty/rest, link monitoring and how records tie each person to each flight. Scale reveals gaps that one-aircraft testing hides.

What can you do now?

Start a dated mission worksheet, collect manufacturer documents, draft a revision-controlled manual, map operating areas and alternates, build a crew training register, and test whether one flight’s records are retrievable. Label each item “current practice,” “proposed Part 108 planning,” or “requires final-rule confirmation.” Keep flying only under rules and authorizations in force today, including any necessary Part 107 waiver. For the broad rule and its status, read our Part 108 overview and status tracker. For the comparison to today’s rule, see Part 107 versus proposed Part 108.

Primary source: FAA and TSA, Normalizing Unmanned Aircraft Systems Beyond Visual Line of Sight Operations, 90 FR 38212 (August 7, 2025), especially proposed Part 108 §§ 108.40, 108.105, 108.130-108.135, 108.165-108.190, 108.300-108.330, 108.400-108.405, 108.500-108.560. This is an NPRM, not the final rule. Check the Federal Register rule page before relying on any proposed requirement.