Software as the Operator: A Reality Check on the FAA’s New Rules

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For years, the drone industry has lived and died by Part 107. It was a good start. It let people fly for work and put the pilot in charge of safety. But if you’ve tried to scale a drone program lately, you know that model is hitting a wall. You can’t fly thousands of missions across the country if you’re waiting on one human to make every single safety call.

VOTIX recently put out a white paper that says the FAA knows this. The agency is proposing two new sets of rules—Parts 108 and 146—that will change everything. It’s the biggest move in aviation since 2016. The main point is simple: software is becoming the operator. We’re moving from a world where we trust a person’s skills to one where we trust a system’s data.

1. The End of the Human-Centric Pilot, Beginning of the Human System Manager

Right now, the pilot does everything. They check the weather, look at maps, and decide if it's safe to fly. If something goes wrong, it's on them. Part 107 is all about the person holding the remote.

But as we move toward flying drones beyond the line of sight (BVLOS), that doesn't work. The new rules shift that weight to the system. The FAA wants to see safety demonstrated through consistent, clear data. They want to see a system that behaves the same way every single time, regardless of who's pushing the buttons.

2. Part 108: Code is the New Captain

The most interesting part of this shift is how Part 108 redefines "operating." In the new framework, the operator isn't just a person. It’s a system where humans supervise while software does the heavy lifting.

VOTIX points out five big ideas in this new world:

  • System Reliability: Safety comes from how the system is built, not just who is using it.

  • Audit Trails: Every flight has to leave a digital trail that the FAA can check.

  • Real-Time Logic: The software has to check the weather and the drone’s health while it's in the air.

  • Automation as Accountability: When the software makes a choice, it has to follow FAA rules.

  • Cybersecurity: If the software is the pilot, you have to make sure no one can hack it.

In this model, the pilot’s job changes. They don't fly the drone; they manage the system that flies the drone. Certification won't be about how well you can handle a joystick. It’ll be about how well your system handles the mission.

3. Part 146: The Data Backbone

If Part 108 is the "brain," then Part 146 is the "senses." This rule covers Automated Data Service Providers (ADSPs). These are systems that feed the drone information about other planes, weather, and restricted areas.

Think of it as a giant, high-speed conversation. The operator software asks the ADSP if the path is clear. The ADSP checks the data and says yes or no. The drone acts. This happens in fractions of a second. It cuts out the need for a human to constantly ask the FAA for permission to fly. If the data says it's safe and the system is certified, you just go.

4. Cybersecurity is Now a Safety Issue

In the old days, a "safety issue" was a broken propeller or a low battery. In the new world, a "safety issue" is a hacked data stream. VOTIX argues that under Part 108, cybersecurity is no longer just something for the IT department. It’s a core requirement for being allowed to fly.

If the software is making the decisions, that software has to be protected. We’re talking about ten layers of security—encryption, access controls, and data that can’t be changed. If your system is vulnerable to a hack, the FAA will see it as "unairworthy." It’s as simple as that.

5. The Three Phases of the Future

The white paper predicts three stages for the industry:

  1. The Compliance Race (1–3 years): Companies with professional software will move fast. Companies still doing things manually will get stuck.

  2. The Service Mesh (3–7 years): We’ll see large-scale drone networks working across cities and plants, all talking to each other automatically.

  3. Full Autonomy (7–15 years): Robots will do the work. Humans will just set the strategy from a distance.

6. What This Means for You

If you’re an asset owner, the message is clear. Stop thinking about drones as "equipment" and start thinking about them as "software systems." You can’t just buy a drone and hire a pilot and call it a day. You need a platform that can talk to the FAA, manage risk data, and provide a digital record that proves you’re safe.

The FAA isn't just making new rules for drones. They’re building a foundation for a sky full of autonomous machines. The pilot’s seat is being replaced by code. It’s time to make sure your code is up to the task.

The Big Takeaway: We’re moving from "Trust me, I’m a pilot" to "Trust me, here’s the data." The FAA is letting software take the wheel, but only if that software is secure and auditable. Don't get left on the ground because you're still relying on a manual checklist.