Blanket VLOS Waiver?

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I'm licensed under Part 107 but I only fly for a public county agency.

We're a public park district that focuses on conservation and preservation of natural resources. We just started using drones this year for mapping and, of course, some marketing purposes.

We have close to 20 properties that we maintain ranging from around 3 acres to over 1300 acres. Some of these properties are heavily wooded and it's extremely difficult to maintain VLOS on many of our mapping missions. There are a few missions we just plain CANNOT do because we can't maintain VLOS.

When 107 first rolled out, the application for waivers was constructed in such a way that you could essentially apply for a blanket waiver. So you could essentially pick how long you wanted the waiver to last (up to 2 years) and provide all the other safety/contingency/emergency procedures and 90 days later you get your waiver.

Some time in the past few months though, the application has changed and it seems like its set up only for specific date/time/location operations. So instead of the PILOT being granted the waiver, the specific OPERATION is being allowed to perform outside the certain 107 laws.

This is problematic for us because we have so many properties for which we would need a waiver from the VLOS rule and we obviously can't predict the weather 90 days in advance.

Does anyone have any recent experience with applying for waivers like this?


ALSO: Since we are a public organization, can we still apply for a blanket COA/COW? The information even on the FAA's website seems conflicting as to whether or not we would have to fly under 333 or if that even applies at all any more.

Any guidance on this issue would be greatly appreciated!
 

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