The Tactien Group details the regulatory pathways available to utilities and operators preparing for scalable Beyond Visual Line of Sight (BVLOS) operations, including Section 44807, Part 91 and the anticipated Part 108 framework. Read more >>
After more than a decade of waiting for scalable BVLOS authorization, Part 108 could become the first formal, standardized regulatory framework for routine BVLOS operations. The proposed framework is expected to define performance-based requirements for routine commercial BVLOS operations, bringing greater standardization to a regulatory environment that has long consisted of exemptions and waivers. However, organizations do not necessarily need to wait for Part 108 before pursuing BVLOS operations, as the path to readiness varies according to operational intent, aircraft type and risk tolerance.
Regulatory Pathways to BVLOS Readiness
Section 44807 of the FAA Reauthorization Act allows the Administrator to grant exemptions for Unmanned Aircraft System (UAS) operations that fall outside Part 107 but can be considered safe under existing aviation standards. For organizations with a strong operational safety case, this route can provide earlier access to BVLOS operations for specialized applications such as linear inspection, utility patrol and controlled-area operations.
Part 91 provides another potential pathway and is often associated with Public Aircraft Operators (PAOs) conducting specific governmental or public service missions. Select utilities, especially those working through state or public partnerships, may be able to conduct BVLOS operations under customized Certificates of Authorization (COAs), which may offer a faster route than private-sector pathways.
Determining the most appropriate regulatory route requires consideration of each organization’s risk profile, operational maturity and mission requirements. Some utilities may benefit from pursuing Section 44807 or Part 91 pathways, while others may be better positioned to transition directly to Part 108 once the rule is finalized. Preparing for Part 108 requires organizations to understand how existing programs align with the proposed framework and identify areas that must be addressed.
Tactien’s Part 108 Program Prep service supports this process through regulatory landscape assessments, gap analyses, evaluations of alternative pathways and implementation strategies that align operations, documentation and partnerships toward future approval.
The company emphasizes that BVLOS readiness is an active process rather than a matter of waiting for new rules to arrive. By evaluating Section 44807, Part 91 and Part 108 pathways, utilities can identify an approach suited to their compliance needs, scalability and return on investment. Tactien helps utilities and operators understand the regulatory options available today and map readiness plans that support the development of scalable, compliant BVLOS operations.
The Value Vault
The Tactien Group’s Value Vault includes topic-specific resources that outline examples of the company’s work, its approach to complex challenges and the frameworks it develops. Preparing for Part 108 Operations is one of the resources available to view or download.
Read ‘Preparing for Part 108: Your Guide to BVLOS Readiness’ for more information.







