Robert Rahm |
October 17, 2026 
The FAA’s new Order JO 7200.23E, Processing of Unmanned Aircraft Systems Requests, takes effect October 31, 2026. It cancels the April 2023 version (JO 7200.23D) and updates how Service Centers handle Part 107 airspace authorizations, Part 91 COAs, and related requests.
The change most relevant to commercial inspection pilots is paragraph 3-5: Requests for Vertical Structure Inspections Above the UASFM Altitude Values. A small unmanned aircraft conducting a visual line of sight inspection of a cell tower, communications tower, or high-rise building can be authorized above the published LAANC grid ceiling without coordination with the controlling air traffic facility, if specific conditions are met.
Exact Criteria for Above-Grid Tower Inspections
The order states that ATC facility coordination is not required when the operation:
- Remains within a 100-foot radius of the structure and no more than 100 feet above its uppermost portion.
- Stays outside two nautical miles of any landing surface (airport, heliport, seaplane base, or vertiport) unless a separate authorization covers it.
- Maintains at least 500 feet below and 2,000 feet horizontally from clouds.
- Has minimum flight visibility of three statute miles observed from the control station.
Requests must go through FAADroneZone, even at LAANC-enabled facilities. The resulting airspace authorization must include the exact criteria language in the Schedule of Flight Operations. Authorizations can be site-specific or broad-area (including nationwide for qualifying operators) and may last up to 24 months.
Bridges and power lines are excluded because they have horizontal spans. The pilot remains responsible for compliance with all other Part 107 rules, including the 400-foot structure exception in 14 CFR 107.51, Remote ID, and night operations if applicable.
This policy builds on an earlier 2025 notice but is now written into the standing order that Service Centers follow when processing FAADroneZone requests.
Class E Surface Area Rules
Paragraph 3-3 addresses Class E surface areas (the dashed magenta rings around many smaller airports). Where no facility-specific UAS Facility Map exists, the order applies concentric rings measured from the Airport Reference Point:
- Within 2 NM: no authorization without prior ATC coordination.
- 2–3 NM: 100 feet AGL.
- 3–4 NM: 200 feet AGL.
- Beyond 4 NM: 400 feet AGL.
A 1,000-foot ceiling is required. Facility maps override these defaults when present. This is the first time the order spells out the Class E surface process in detail.
Multi-Day Approvals and Other Notes
At or below grid altitude in LAANC airspace, multi-day authorizations are now primarily reserved for first responders when they reduce paperwork. Non-first-responder multi-day requests above grid altitude need facility manager approval, a defined project with start and end dates, and can include up to a 14-day weather buffer with ATC agreement. Standard LAANC requests remain single-day.
All Part 91 drone approvals must now include a waiver of the see-and-avoid rule in 14 CFR 91.113(b). Part 107 operational waivers move to the Aviation Safety Hub. COA extensions are capped at 60 days.
Practical Takeaways for Part 107 Pilots
If you inspect towers or high-rises in controlled airspace, submit the request through FAADroneZone well before the job. Confirm the structure qualifies (vertical only), plot the 100-foot radius and 2 NM airport exclusion, and verify cloud and visibility minima. The authorization will not replace the need for a Part 107 certificate, registration, or site-specific permissions from the structure owner.
The order is public: https://www.faa.gov/documentLibrary/media/Order/2026-09-22_Order_JO_7200.23E_Processing_of_Unmanned_Aircraft_Systems_Requests_FINAL_v3.pdf FAA orders page: https://www.faa.gov/regulations_policies/orders_notices/index.cfm/go/document.information/documentID/1045676