Part 108 Has a Second Rulebook and TSA Is Writing It
TSA is recruiting BVLOS operators for closed technical roundtables on the security programs Part 108 will require. The intake deadline is October 19, and the useful preparation starts now.
The security half of Part 108 now has a schedule
On September 4, 2026, the Transportation Security Administration published a notice in the Federal Register (91 FR 56894) inviting BVLOS operators and their associations to request seats at a series of closed technical roundtables. Requests have to reach TSA by October 19, 2026. The subject is not airspace or aircraft performance. It is the security program that covered operators will have to run once the FAA's Part 108 rule is published, and this notice is the first official signal of how TSA intends to build the model language for it. That matters to anyone flying long linear assets today under a waiver. The authority you hold now and the security program you will need later are not the same document, and the work does not start when the rule lands.
Two obligations, and one of them is new
The joint FAA and TSA notice of proposed rulemaking issued in August 2025 proposed two security elements: vetting of certain covered personnel, and an approved security programme for some operators. The September notice keeps both, and adds a useful admission. TSA expects that procedures companies have already built while flying under FAA waivers or exemptions may satisfy parts of the eventual security program. That is an argument for treating your current paperwork as an asset rather than a formality. What the notice does not contain is the model language operators need to write against. TSA says it is still finalising its requirements alongside the FAA, and that the roundtables will be held after both final rules publish, so attendees can first work out whether the rule reaches them.
Who gets in, and how Participation is narrow by design.
Every attendee has to be validated as representing a drone operator or a trade group, no organisation gets more than two seats, and attendees need approval to handle Sensitive Security Information plus a signed non-disclosure agreement before the session. The sessions are closed to the public. They are also not a federal advisory committee: TSA wants individual views and information rather than a group recommendation, and no comment docket is attached. Operators already flying under waivers or exemptions are expressly invited, as are operators who plan to apply for a Part 108 permit or certificate. Two seats per company means the person in the room should be the person who can describe controls in operational detail. Who is vetted, and how. How a launch site is secured when it is a rural valve station with no gate. How a lost link is handled. Who calls whom when an aircraft ends up somewhere it should not be.
Three dates that actually govern
The first is OIRA review. The final Part 108 rule reached the Office of Information and Regulatory Affairs on July 10, 2026, and was still listed as pending on September 4. The meeting log kept by the Office of Information and Regulatory Affairs shows sessions on this rule scheduled as late as September 16, which argues against publication before the middle of the month. The second is the review window. Day 90 of the standard 90 day review falls on October 8, 2026. Treat that as an outer marker, not a publication date. The third is TSA's intake. Requests are due October 19, 2026, and TSA has said it may adjust that period after its own final rule publishes. If the FAA rule slips into an extension, the security process slips with it.
What to do before October 19
Build the security file now, in the form a reviewer would ask for it: one page per control, with evidence attached. What identifies your personnel and how that is verified. How a launch and recovery site is secured. What your aircraft broadcasts, what your ground station logs, and how long you keep it. Who you notify, and how quickly, when an RF environment changes mid mission or an aircraft is interfered with. The teams that get the most from a closed roundtable arrive with specific practices and evidence, because that is what TSA says it is collecting. Start that inventory this month rather than after publication, while the requirements are still being written and before the October 19 window closes.
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