The FAA's Aviation Safety Hub Changes the Waiver Intake, Not the Safety Case

The Federal Aviation Administration has moved the Part 107 waiver application process to Aviation Safety Hub. Previously submitted waiver applications require no action and will continue to be processed in FAADroneZone. The FAA says Part 107 airspace authorization applications will remain in FAADroneZone until further notice.

That is a meaningful change in where a new waiver request begins. It should not be mistaken for a change in the central work an operator must do. The FAA describes a waiver as an official document approving certain aircraft operations outside the limitations of a regulation. A drone pilot may request an operational waiver for a Part 107 operation that is not otherwise allowed, but must demonstrate that the operation can still be flown safely with alternative methods.

For a field team, that distinction matters. A new portal can make it tempting to start with the screen in front of the applicant. The better starting point is the proposed operation itself. What will happen, where will it happen, which rule creates the need for a waiver, what could go wrong, and what controls will make the operation safe? A submission is the record of those answers. It is not a substitute for developing them.

Begin by separating the operation from the application

A waiver request is easier to prepare when the team first writes a plain-language operating description that does not depend on portal terminology. Describe the aircraft activity, the location or location type, the people and assets that may be affected, the expected flight profile, the personnel involved, and the conditions that must be true before launch.

That description should be specific enough that a person who did not attend the planning meeting can understand the proposed work. "Inspection mission" is a broad label. It does not show whether the aircraft will be flown beyond the remote pilot's unaided ability to determine its position, altitude, attitude, and movement, whether it will operate near people, whether it will use a visual observer, or whether it will exceed a published operating limitation. Those details are what connect the work to the regulation at issue.

The FAA lists several rules for which an operational waiver may be needed when the operator cannot comply with the rule as published. The list includes operations from a moving vehicle or aircraft in populated areas, night or civil-twilight operations without anti-collision lighting, visual-line-of-sight operations, visual-observer requirements, multiple small UAS under one remote pilot, certain operations over people, specified operating limitations, and certain operations over moving vehicles.

A practical intake review can ask one question at a time: which normal Part 107 requirement cannot be met for this planned mission? If the team cannot answer that question clearly, it is too early to draft a safety explanation. If it can answer it, the planning work can focus on the particular rule rather than building a vague, oversized application.

Treat the FAA's questions as a mission-design checklist

The FAA's waiver guidance asks applicants to describe operational details. For the planned area, the FAA points to information such as latitude and longitude, a detailed map, maximum altitude above ground level, controlled airspace, other airspace within five miles of the flight area, and the kind of area over which the operation will fly. It gives examples ranging from rural and sparsely populated areas to congested areas, neighborhoods, city limits, large outdoor gatherings, restricted-access sites, and other environments.

Those prompts are useful before any formal submission begins. Put the location information into the mission package early. Do not leave the operating area as a client address, a general corridor name, or a verbal description. A map and a defined boundary help make the proposed operation reviewable by the organization itself. They also let the team spot where a proposed area may change the assumptions behind its safety controls.

The guidance also asks for small UAS details: aircraft type, energy source, maximum flight time, range, speed, dimensions, containment method, termination system, weight with payload, and information about loads that could drop or detach. None of these prompts requires a team to treat aircraft specifications as a marketing list. Each is an operating input.

For example, a team should be able to identify the actual aircraft configuration that will support the requested work, not merely a product family. It should document the payload and its connection to the mission. If the planned configuration changes after the application is prepared, the organization should have a clear way to decide whether the change affects the description, the risk assessment, or the controls it relies on. The aim is to maintain a truthful link between the submitted operation and the work the crew will actually perform.

Put people into the safety case

The FAA asks about the minimum level of experience for the Remote Pilot in Command, the minimum number of personnel needed, the training personnel will have before operating under the waiver, how they will be trained, how the responsible person will determine competence and operational knowledge, whether testing will be performed and documented, and how personnel will maintain knowledge and skill.

These questions point to an operational truth: a waiver safety explanation is not only about the aircraft. It is also about who performs each function and how the organization knows those people are ready. A roster alone does not answer that question. The planning record should tie roles to responsibilities that are relevant to the proposed operation.

One useful internal exercise is a role walk-through. Ask the remote pilot, visual observer if one is used, site lead, and any other required personnel to describe what they would do at key decision points. What information do they need before launch? What condition requires them to pause? Who is empowered to terminate or recover the flight? What must be recorded if the plan changes? The answers can reveal a gap between a well-written explanation and a field process that people can consistently use.

The FAA specifically says applicants are responsible for identifying operational risks and mitigations. Its examples of possible methods include operating limitations, technology, additional training, equipment, personnel, and restricted-access areas. The guidance says the applicant must identify hazards and propose mitigations, or the FAA will not be able to complete a safety analysis and will disapprove the application based on insufficient information.

That makes generic assurances a poor foundation. "The crew will be careful" is not a mitigation that shows how a risk will be controlled. A stronger explanation names a condition, explains why it matters to the proposed operation, identifies the control, and states who checks that control. The exact method will depend on the operation, but the form should stay concrete.

Build evidence before it is requested

The FAA says that complex operations may require information beyond the items addressed in its guidance. It also directs applicants to the Waiver Safety Explanation Guidelines and Guiding Questions. That is a reason to organize supporting material while the plan is being developed, rather than waiting until a reviewer asks for clarification.

A well-managed internal file can preserve the map, aircraft configuration details, role definitions, training evidence, operating procedures, risk discussion, and the version of the safety explanation submitted. It can also identify the owner of each item and the date it was last reviewed. The point is not to create paperwork disconnected from the operation. It is to ensure that the organization can trace every key claim in its explanation back to a real procedure, assigned responsibility, or documented control.

This discipline is especially helpful when work is repeated. A recurring mission type may justify reusable templates, but it does not justify copying details that do not fit the new location, aircraft, crew, or operating condition. A template should make review easier, not turn assumptions from an old job into unexamined facts on a new one.

Before submitting, hold a short challenge review with someone who did not author the application. Ask them to find the path from the requested operation to the regulation, the risk, the mitigation, and the field action. If they cannot follow the chain, revise the explanation. The test is practical: could a qualified crew use the document to understand what is different about this operation and what they must do to keep it within the proposed safety case?

Submission is a decision point, not the end of planning

The FAA directs applicants to create an account or log in to Aviation Safety Hub to submit a Part 107 waiver application. It states that a drone does not need to be registered to request a waiver, but it must be registered before any operation. For requests intended for civil twilight or nighttime use, the FAA says the applicant must include details explaining how additional risk will be mitigated, or the operation may be restricted to daylight.

The FAA says it will do its best to review and approve or disapprove waiver requests within 90 days of submission, while noting that processing times vary with the complexity of the request and the completeness of the initial application. If additional information is needed, the FAA will contact the responsible person through Aviation Safety Hub. The notice says that requests for information include questions, response instructions, and a time limit, and that an application will be canceled if the applicant does not respond within 30 days.

Those points make ownership important after submission as well as before it. Identify a responsible person who can monitor the application, recognize an FAA status-change email, locate the underlying planning material, and coordinate a timely response. A response should not require rebuilding the safety case from scratch because the original analysis, contributors, and evidence have disappeared into a mailbox.

The FAA also states that failure to adhere to waiver terms may result in a violation of the regulation being waived. In operational terms, the approval should be translated into a usable release process. The people dispatching, planning, and flying the work need a reliable way to confirm that the planned mission matches the approved operation and that any stated conditions are present. If it does not match, the team should stop and review rather than treating the approval as a general permission slip.

The practical takeaway

Aviation Safety Hub changes the application entry point for new Part 107 waiver requests. The more durable lesson is that a credible safety explanation begins before the form: with a defined operation, a clear understanding of the rule involved, visible hazards, specific mitigations, assigned personnel, and records that connect the plan to field execution.

Teams preparing a waiver should use the FAA's prompts as an internal readiness test. Can the organization show where it will operate, what the aircraft will do, who will perform each safety-critical role, what risks are expected, and how the operation remains safe when circumstances are not routine? If the answers are concrete before submission, the application is more likely to represent an operation the team can actually run.

Source: Federal Aviation Administration, Part 107 Waivers, updated June 22, 2026.