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BVLOS and Performance Based Operations
Joel Jones, President, Remnant Technology, Inc.
The FAA has quietly but fundamentally shifted the philosophical foundation of UAS regulation. What began as a series of case-by-case exemptions and waivers under Section 44807 and Part 107 has evolved into a deliberate move toward performance-based, risk-managed operations under the proposed Part 108 framework for Beyond Visual Line of Sight (BVLOS) flight. This is not merely a new set of rules. It is a change in how the agency evaluates safety, scales commercial operations, and allocates regulatory oversight. Prescriptive limits are giving way to safety cases, Safety Management Systems, detect-and-avoid performance, population-density risk categories, and operator accountability through permits and certificates. Operators who continue to approach the regulatory environment as a checklist of permissions will struggle. Those who understand the underlying performance-based philosophy and can demonstrate it through robust operations manuals, training programs, risk assessments, and real-world data, will be positioned to move efficiently as the final rule takes shape. Drawing on experience conducting the first U.S. agricultural BVLOS flights, developing FAA-accepted harmonized operations and training manuals, and participating in national safety and policy discussions, this presentation examines the practical implications of the shift. Attendees will leave with a clearer understanding of what “performance-based” actually requires, how current exemption-based operations can transition into the Part 108 structure, and why mastering this philosophical change is essential for navigating the future regulatory landscape successfully.
Joel M. Jones is a pioneering leader in unmanned aircraft systems (UAS) with over a decade of experience in aviation education, regulatory compliance, and operational innovation. As Owner, President, and Chief Pilot of Drone Crop Services since 2022, he conducted the first Beyond Visual Line of Sight (BVLOS) UAS aerial application in the United States. He has written operations and training manuals for swarm, BVLOS, and night operations. Joel has authored multiple FAA approvals, including Section 44807 exemptions for UAS over 55 pounds, FAA 107.31 BVLOS waivers, FAA 107.35 “Swarm” waivers, FAA 107.36 hazardous materials waivers, and Section 927 waivers authorizing banner tow operations within airshow Temporary Flight Restrictions (TFRs). He worked with the California Farm Bureau on State Assembly Bill 1016, which updates aerial pesticide regulations to better reflect UAS operations, and is currently on the team assisting the California Department of Pesticide Regulation in adopting new requirements for private UAS applicators in the state. Since August 2018, Joel has served as a UAS Instructor at Orange Coast College in Costa Mesa, CA, teaching courses on FAA Part 107 and aerial agriculture, where he has helped over 70 students earn their FAA Remote Pilot certificates. A certified AUVSI TOPS 1&2 Mentor, he provides guidance on advanced UAS operations and moderates The Ag Drone Podcast (www.theagdronepodcast.com), fostering industry discussions on agricultural drone professionalism and safety. He has spoken and chaired the regulatory portions of the Spray Drone End User Conference since 2023, presented at the 2025 NAAA National Convention, delivered in-person comments on the BVLOS NPRM to the FAA Administrator, spoke on the future of BVLOS at the Midwest Drone Conference, and presented at PREP. In 2026 he performed UAS demonstrations at EAA AirVenture Oshkosh. His leadership also includes serving as an NAAA UAAS Committee Member, PERC UAS Committee Member, and FAA Safety Team Representative Drone Pro for the Little Rock FSDO.
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