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FAA Part 107 Rule Changes re: Showing RPIC to LEO etc. . .

BigAl07

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This is for Part 107 Operations ONLY right now . . . (Recreational your day is coming in just a couple of months)

Specifically in regards to WHO you must legally show your ID and Part 107 Credentials to:
Up until 4/21/21 a RPIC is only required to show their RPIC Certificate to FAA Officials requesting it. This changes with the New Rules for Part 107 that were created December 28th 2020, added to the Federal Register on March 16th 2021, and will go into Full Force/Effect on April 21st, 2021. As of 4/21/21 you will be required to provide a Hard Copy (electronic version is NOT accepted, PHYSICAL COPY REQUIRED) of ID, RPIC, Proof of Currency, Registration, and any other "required FAA Documents" upon any request from someone with the following agencies:

  • FAA
  • NTSB
  • TSA
  • and any Federal, state, or local Law Enforcement Officer

This includes your ID, RPIC, Proof of Recurrency, Aircraft Registration, and any other "Document, Record, or Report Required to be kept under FAA regulations"!! This means a physical copy (plastic/paper) and not merely an electronic version on your phone/tablet etc. A Physical Copy must be shown if requested by those agencies! If you do not comply you are not in compliance with Part 107.

Here is the actual wording from the Executive Summary about this topic (notice it's all of the items below not pick & choose):

Inspection, testing, and demonstration of compliance
A remote pilot in command, owner, or person manipulating the flight controls of a small unmanned aircraft system must:
  • • Have in that person’s physical possession and readily accessible the remote pilot certificate with a small UAS rating and identification when exercising the privileges of that remote pilot certificate.
  • • Present his or her remote pilot certificate and identification upon a request from the FAA, NTSB, TSA, or any Federal, state, or local law enforcement officer.
  • • Make available, upon request, to the FAA any document, record, or report required to be kept under FAA regulations.
  • • Upon request, must allow the FAA to test or inspect the small unmanned aircraft system, the remote pilot in command, the person manipulating the flight controls of a small unmanned aircraft system, and, if applicable, the visual observer to determine compliance with the rule.

If you are flying under a Recurrency (anyone who isn't in their first 24 months of UAS operation are the only ones who would be) you have to have a printed copy of your most recent Proof of Currency with you. That's a print out of your FAA Document showing satisfactory completion of the Recurrency Test/Training. You should also have your plastic RPIC on hand as well IMHO.

Here is a link to the Executive Summary which includes OOP, Night Flight w/o Waiver and the other new aspects of Part 107 going into effect later this month:
 
Good write-up. Thanks for posting. I did my 107 Rating via the Part 61 method as I'm an ATP rated pilot, but one of the requirements was to have a current BFR, and this applied to my recent Part 107 recurrent as well. Having not read the technical language related to the new Part 107 recurrent process (via the FAA's proposed online test), I wonder if the BFR will no longer be required. It does seem unnecessary IMO.
 
Good write-up. Thanks for posting. I did my 107 Rating via the Part 61 method as I'm an ATP rated pilot, but one of the requirements was to have a current BFR, and this applied to my recent Part 107 recurrent as well. Having not read the technical language related to the new Part 107 recurrent process (via the FAA's proposed online test), I wonder if the BFR will no longer be required. It does seem unnecessary IMO.


I'm in the same boat as you. I took my Part 61 Online Recurrency at the end of February.

I have it in writing from our FAA UAS Specialist that Part 61 Operators can now take the new Part 107 Online Training Module and become "Current" without the need for BFR. So if you want to utilize Operations Over People or Night flight w/o a waiver (after 4/21/21) you can take the new Training Module and exercise those privs as well.
ALC-677: Part 107 Small UAS Recurrent Non-Part 61 Pilots
 
I'm in the same boat as you. I took my Part 61 Online Recurrency at the end of February.

I have it in writing from our FAA UAS Specialist that Part 61 Operators can now take the new Part 107 Online Training Module and become "Current" without the need for BFR. So if you want to utilize Operations Over People or Night flight w/o a waiver (after 4/21/21) you can take the new Training Module and exercise those privs as well.
ALC-677: Part 107 Small UAS Recurrent Non-Part 61 Pilots
Thanks! I figured that would be the case. The BFR requirement seemed excessive, and I knew that would eventually go away. I'll be sitting for the new recurrent process ASAP.
 
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Thanks! I figured that would be the case. The BFR requirement seemed excessive, and I knew that would eventually go away. I'll be sitting for the new recurrent process ASAP.
Same here, but my flight review just expired and I haven’t had a chance to get a new one. There is a still a separate recurrent course for Part 61 pilots (ALC-515) from ALC-677, which specifies it is for non-Part 61 pilots and Part 61 pilots without a current flight review. I’m assuming ALC-515 is the same older recurrent course for pilots, but it shows it was updated in March, presumably to add items from the new reg. revisions. I’m guessing it may have fewer airspace items since a Part 61 pilot would presumably be up to speed on those already.
 
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I logged in to the FAA site this morning and took the training modules and test. I'm now recurrent per the current and upcoming rule changes for 24 months. There were many additions to the prior training modules for recurrency, so it's worth taking one's time and reading everything carefully.
 
Is there a way to get a copy of the paper saying you passed recurrent? My dog ate mine. I always keep my FAA license card with me though.
 
Is there a way to get a copy of the paper saying you passed recurrent? My dog ate mine. I always keep my FAA license card with me though.

Assuming that you mean the Airman Knowledge Test Report from the in-person recurrent, I've never asked but the "DO NOT LOSE THIS REPORT" warning on the document suggests that it may not be easy to replace.

You could just take the new online recurrent training and get a shiny new certificate that way, which will also qualify you for night flights etc.
 
If you are flying under a Recurrency (anyone who isn't in their first 24 months of UAS operation are the only ones who would be) you have to have a printed copy of your most recent Proof of Currency with you.

Where in the rule is this stated?
 
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Where in the rule is this stated?


If you're flying beyond your initial 24 months of the IKT, your plastic RPIC does not demonstrate "Currency" as a RPIC. If you are only carrying the plastic card, you're outside of the initial currency dates, you have no way to show you're current. Just like with MANNED aviation, our Pilots License is issued initially but after that our currency is documented in our Log Book. We are required to provide that when requested in order to prove currency.
 
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If you're flying beyond your initial 24 months of the IKT, your plastic RPIC does not demonstrate "Currency" as a RPIC. If you are only carrying the plastic card, you're outside of the initial currency dates, you have no way to show you're current. Just like with MANNED aviation, our Pilots License is issued initially but after that our currency is documented in our Log Book. We are required to provide that when requested in order to prove currency.

But you're not required to carry your logbooks with you as a manned pilot. You just need to make them available upon request by the FAA, and this doesn't mean immediately in the field, but just in a reasonable time after they are requested.
 
Where in the rule is this stated?

The amended 107.7 states:

§107.7 Inspection, testing, and demonstration of compliance.​

(a) A remote pilot in command, owner, or person manipulating the flight controls of a small unmanned aircraft system must—​
(1) Have in that person's physical possession and readily accessible the remote pilot certificate with a small UAS rating and identification when exercising the privileges of that remote pilot certificate.​
(2) Present his or her remote pilot certificate with a small UAS rating and identification that contains the information listed at §107.67(b)(1) through (3) for inspection upon a request from—​
(i) The Administrator;​
(ii) An authorized representative of the National Transportation Safety Board;​
(iii) Any Federal, State, or local law enforcement officer; or​
(iv) An authorized representative of the Transportation Security Administration.​
(3) Make available, upon request, to the Administrator any document, record, or report required to be kept under the regulations of this chapter.

It likely derives from 107.7(a)(3), and is mentioned in the new recurrent training under RPIC responsibilities:

grab149.png

1617801879155.png
The
 
The amended 107.7 states:

§107.7 Inspection, testing, and demonstration of compliance.​

(a) A remote pilot in command, owner, or person manipulating the flight controls of a small unmanned aircraft system must—​
(1) Have in that person's physical possession and readily accessible the remote pilot certificate with a small UAS rating and identification when exercising the privileges of that remote pilot certificate.​
(2) Present his or her remote pilot certificate with a small UAS rating and identification that contains the information listed at §107.67(b)(1) through (3) for inspection upon a request from—​
(i) The Administrator;​
(ii) An authorized representative of the National Transportation Safety Board;​
(iii) Any Federal, State, or local law enforcement officer; or​
(iv) An authorized representative of the Transportation Security Administration.​
(3) Make available, upon request, to the Administrator any document, record, or report required to be kept under the regulations of this chapter.

It likely derives from 107.7(a)(3), and is mentioned in the new recurrent training under RPIC responsibilities:

View attachment 126897

View attachment 126896
The

As I said above, none of that requires that you carry the currency document with you while flying. The regulation is quite clear about what needs to be with you physically, and what documents just need to be provided to the FAA later upon request.
 
As I said above, none of that requires that you carry the currency document with you while flying. The regulation is quite clear about what needs to be with you physically, and what documents just need to be provided to the FAA later upon request.

The recurrent training clearly states it as a requirement. Part 107 does not.
 
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The recurrent training clearly states it as a requirement. Part 107 does not.

Part 107 would be the controlling legal rule in that case then. "Training" can't create a legal obligation.
 
Part 107 would be the controlling legal rule in that case then. "Training" can't create a legal obligation.

Agreed, but they are likely to argue that your certificate alone doesn't demonstrate the currency required by Part 107 to fly legally (unless the date of issue is within the past 24 months) and therefore is insufficient.
 
Agreed, but they are likely to argue that your certificate alone doesn't demonstrate the currency required by Part 107 to fly legally (unless the date of issue is within the past 24 months) and therefore is insufficient.

Strictly speaking, the date of issue doesn't prove anything either. If you order a replacement certificate, the date of issue will be the current date, not the date you originally earned the certificate.
 
Strictly speaking, the date of issue doesn't prove anything either. If you order a replacement certificate, the date of issue will be the current date, not the date you originally earned the certificate.

Is this discussion going down a rabbit hole of pedantry?
 
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Is this discussion going down a rabbit hole of pedantry?

I thought we were discussing what was legally required to be carried while operating a UAS?
 
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