Mission records tied to each release decision.
Flight date, route, crew, aircraft, and the operational state at release. Evidence that you operated inside your waiver envelope.
Part 108 Transition Brief
Map your BVLOS waiver risk before Part 108 is final.
The NPRM proposes ending new BVLOS waivers. The treatment of existing waivers remains unresolved. This brief maps three possible paths and the records to prepare under each. Your Certificate of Waiver special provisions define today's dispatch gate. The question is what comes next.
Three possible paths
The NPRM does not resolve how existing BVLOS waivers transition. Three outcomes are plausible.
Each path carries different record requirements. The final rule may land on one of these, a hybrid, or something else. Operators can prepare by keeping the records that matter under any outcome.
Scenario
What it means
Record posture
Streamlined conversion
Existing waiver holders convert to Part 108 authority through a defined application path. Conversion may require evidence of operational history, safety record, and recordkeeping maturity.
Build Part 108 evidence now. Show operational continuity and compliance history at conversion.
Honored through expiration
Waivers remain valid until their stated expiration. After expiration, operators must apply for Part 108 authority. No automatic conversion path exists.
Maintain waiver compliance records until expiration. Prepare Part 108 application evidence in parallel.
Hard sunset
A fixed date ends waiver authority regardless of expiration. All operators must hold Part 108 authority by that date or cease BVLOS operations.
Accelerate Part 108 readiness. Build the full evidence record before the cutoff.
Today's dispatch gate
Your special provisions already define what you must check before release.
A Part 107 BVLOS waiver includes special provisions tailored to your operation. Those provisions are your current operating envelope: airspace limits, altitude restrictions, time-of-day constraints, equipment requirements, crew roles, and operational boundaries. Under ยง107.7, you must produce records of compliance on request. This is the dispatch gate you already operate under. BVLOS compliance software checks those waiver special provisions before release.
- Airspace and altitude Where and how high your operation is authorized
- Equipment and configuration Required aircraft systems and DAA equipment
- Personnel and roles PIC, VO, and crew qualifications for the operation
Records to keep now
The records that survive any transition path are the ones you should build today.
Regardless of which scenario the final rule adopts, certain evidence categories appear in all three. Operators that keep these records in normal operations will be better positioned for conversion, application, or accelerated compliance.
What was installed and accepted for each flight.
Serial numbers, firmware versions, installed components, and configuration snapshots that show the aircraft matched your accepted system.
Who was qualified and current for each operation.
Training records, currency status, and role assignments for PIC, VO, and any required operational roles.
How you tracked hazards and corrective actions.
Open findings, incident reports, and corrective action records that demonstrate safety management maturity.
See Part 108 Recordkeeping Software for how Ledger maps proposed recordkeeping requirements to objects you can build today.
Waiver risk
The risk is not Part 108 itself. The risk is transition without evidence.
Operators that treat their waiver period as informal time will arrive at Part 108 with folders of unconnected logs. Operators that keep connected records during waiver operations will have a compliance history to reference. The final rule will not invent your operational record for you.
Waiver compliance today
Part 108 evidence in shadow
Conversion-ready posture
What to do next
Build the transition record while you keep flying.
- Track waiver special provisions as dispatch rules
- Connect each flight to the records that released it
- Run proposed Part 108 checks in shadow mode
- Generate evidence packs for any reviewer
Stay informed on Part 108 transition.
Get updates when the final rule package clears OIRA or when this brief is updated with new regulatory developments.