If your agency is building a drone program, sooner or later someone will ask whether you need a Certificate of Waiver or Authorization, better known as a COA. It is one of the most misunderstood pieces of the public-safety drone world: often confused with a Part 107 certificate, often assumed to be harder than it is, and often skipped by agencies that would benefit from having one. This article explains what a COA actually is, how it differs from Part 107, the general process of getting one, and why a public-safety agency would want to hold one in the first place.
A Part 107 certificate authorizes a person. A COA authorizes your agency. That single difference is the reason most serious public-safety drone programs eventually pursue one.
What a COA actually is
A Certificate of Waiver or Authorization (COA) is an authorization issued by the FAA's Air Traffic Organization that lets a public agency operate drones as public aircraft operations, under its own organizational authority rather than under an individual pilot's certificate. It is the framework the FAA built for government entities, such as police and fire departments, that need to fly on their own terms for their public mission.
The key idea is that a COA is granted to an organization. When your agency holds a COA, the authority to fly, and the responsibility for how those flights are conducted, sits with the department. Your agency sets and certifies its own standards for pilots, aircraft, and maintenance against the terms written into the certificate, instead of relying on each operator's personal credential.
"Public aircraft operations" is a legal status, not just a description. It means the aircraft is operated by a qualifying government entity for a governmental function that is not commercial. Establishing that status is the first real step in the COA process.
COA vs. Part 107: they are not the same thing
This is where most of the confusion lives. Part 107 and a COA solve different problems, and many agencies end up using both.
| Part 107 certificate | Public aircraft COA | |
|---|---|---|
| Who holds it | An individual pilot | Your agency |
| What it covers | Civil (commercial) small-drone operations under a fixed rule set | Public aircraft operations scoped to your agency's mission |
| Who sets the standards | The FAA, uniformly for everyone | Your agency, against terms in the certificate |
| Continuity | Leaves with the pilot if they transfer or retire | Stays with the department |
| Airspace | Per-operation authorization (often via LAANC) | Can grant standing access in your jurisdiction |
In practice, plenty of public-safety programs run both at once: pilots hold Part 107 for day-to-day flexibility, while the agency holds a COA for the organizational authority and for the operations Part 107 does not cover. The two are complementary, not mutually exclusive.
Who is eligible
A COA is not open to everyone. It is specifically for public aircraft operators: entities that are part of, or operating on behalf of, a government. That includes the armed forces, the federal government, and the governments of a state, the District of Columbia, a tribal government, or a U.S. territory, along with the political subdivisions of those governments, which is where most police departments, sheriff's offices, fire departments, and other municipal agencies fall.
A private business, by contrast, cannot hold a public COA. Commercial operators fly under Part 107 and, where needed, request waivers or authorizations to specific rules. If you are a government agency, the COA path is what unlocks operating as public aircraft.
What a COA can authorize
Not all COAs look alike. The authority is written to fit the operations your agency actually runs, which is one of the main advantages over the fixed Part 107 box. Common forms include:
- Jurisdictional COA. Ongoing authority to operate in the controlled airspace over your jurisdiction, rather than requesting a fresh authorization for every flight.
- Tactical beyond visual line of sight (BVLOS). There is a public-safety tactical BVLOS pathway that lets qualifying agencies fly beyond the pilot's line of sight for time-critical missions. It is only open to agencies that already hold a COA, so the COA is the foundation for that capability.
- Special Governmental Interest (SGI). An expedited authorization layered on top of an existing COA for no-notice, time-sensitive emergency operations, so a critical mission is not waiting on a standard review timeline.
If your program anticipates ever flying BVLOS or running Drones as a First Responder (DFR) operations, holding a COA now positions you for those capabilities later. The advanced pathways are built on top of it.
The general process of getting one
The process is not complicated once you know the path, but it involves aviation terminology and FAA expectations that most agencies only encounter once. Broadly, it runs in these stages:
- Establish public aircraft eligibility. Before you can file, the FAA has to recognize your agency as a qualifying public entity. This is done with a Public Aircraft Declaration Letter, in which the agency declares its eligibility for public aircraft operator status and attests that it will not conduct these operations for commercial purposes.
- Get access to the application system. COA requests are filed through the FAA's online application system for public aircraft operators. (The FAA is transitioning its COA processing into a FAADroneZone-based system, so the exact portal depends on your agency type at the time you file.)
- Build the application package. This is the substantive part. It includes your concept of operations, the operating area, aircraft documentation, emergency procedures, and a pilot qualification plan. A cleanly written package that anticipates the FAA's questions tends to move faster.
- FAA review. The FAA conducts an operational and technical review and may attach provisions or limitations to keep your operations safe alongside other airspace users. For a complete application, the FAA generally targets a response within about 60 days, though it varies with complexity and their queue.
- Issuance, then upkeep. Once issued, your unit operates under the terms of the certificate. Public aircraft COAs are generally issued with a 48-month validity period, and they can be renewed and amended as your program changes.
Why an agency would want one
Given that many agencies start out flying under Part 107, why take on a COA at all? A few reasons carry the most weight for public-safety programs:
- The authority stays with the department. Pilots transfer, retire, and move between shifts. A COA keeps your authority to fly with the agency, so the program does not depend on any one person's certificate.
- You control the standard. Your agency certifies its own pilots, aircraft, and maintenance against written standards you set, rather than being locked into a one-size-fits-all rule.
- Scoped to your missions. A COA can carry provisions written specifically for what your agency does, instead of forcing your operations into the fixed Part 107 framework.
- Standing airspace access. A jurisdictional COA gives ongoing authority to operate in your controlled airspace, rather than a fresh request for every flight.
- Speed when it counts. Once you hold a COA, expedited emergency amendments for no-notice critical missions move quickly.
- The door to tactical BVLOS. The public-safety tactical BVLOS pathway is only available to agencies that already hold a COA, so it is the prerequisite for that next level of capability.
Frequently asked questions
Do we need a COA, or is Part 107 enough?
It depends on how your program is set up. Part 107 authorizes an individual pilot and is simple to stand up for everyday work. A COA authorizes your agency, which lets the department hold the authority and self-certify its own pilots, aircraft, and standards. Many public-safety programs run both. If you are unsure which fits your missions, that is exactly the kind of question a short scoping conversation resolves.
Can a private business get a COA?
No. Public aircraft COAs are for qualifying government entities. Commercial operators fly under Part 107 and request waivers or authorizations to specific rules where needed.
How long does the COA process take?
For a complete application, the FAA generally targets a response within about 60 days, though it varies with the complexity of the request and their current queue. Cleanly prepared applications tend to move faster because they raise fewer questions.
How long is a COA good for?
Public aircraft COAs are generally issued with a 48-month validity period and can be renewed and amended as your program evolves.
Can a COA authorize flights beyond visual line of sight?
Yes. There is a tactical BVLOS pathway built specifically for public safety, and it is only available to agencies that already hold a COA. The COA is the foundation that pathway is built on.
What is a Public Aircraft Declaration Letter?
It is the document in which your agency declares that it qualifies as a public aircraft operator and attests that it will not conduct these operations for commercial purposes. Establishing this status is the first step before a COA can be filed.
Getting help with your filing
Most agencies file a COA once, so there is little chance to get good at the process. If you would rather not learn FAA paperwork from scratch, our team prepares, submits, and manages COA applications for public-safety agencies end to end, from the declaration letter through FAA review to issuance, and we stay on for renewals and amendments as your program grows. You can read more on our COA filing service page, or reach out for a discovery call.
This article is general information about the FAA COA process, not legal or regulatory advice. FAA processes and requirements change over time, so confirm current details for your agency's specific situation before you file.
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