A Part 107 license (which requires a knowledge test and background check) is required in order to use a drone commercially in the US. If one has lost an FAA aircraft pilot license (that is, a license to fly human-piloted aircraft), does that make one ineligible to hold a Part 107 license or is drone licensure based only on whether one is capable of operating a drone?

If only certain types of license loss (e.g. medical disqualification versus revocation for violating regulations) count, under what conditions would a prior loss result in ineligibility to hold a drone license?

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    $\begingroup$ Consider adding a us or us-legal tag to make clear, that your question is scoped for the US and to allow filtering for that criterion (as opposed to other countries legal rules). $\endgroup$
    – MEE
    Apr 14, 2020 at 19:56
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    $\begingroup$ @MEE-ReinstateMonica I would say the [faa] tag covers that (the FAA is the relevant US authority) $\endgroup$
    – Machavity
    Apr 14, 2020 at 20:03
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    $\begingroup$ Asked a broader question about the IACRA on Aviation.SE $\endgroup$
    – Machavity
    Apr 15, 2020 at 13:43

2 Answers 2


I can't find anything that says losing your general aviation license would prohibit you from being unable to obtain a drone pilot's license. In fact, the two seem separate in every regard but one: The Integrated Airman Certification and Rating Application (IACRA) . Per the Part 107 page you need to make an IACRA application. That application will ask if you have ever had an IACRA revoked

Have you ever had an Airman Certificate Revoked?

It's unclear what answering Yes will do (they want you to explain why it was revoked), but it doesn't seem to be an automatic disqualifier.


I've actually posed this question to an FAA Safety Team employee. These guys are top notch and know their specific field of speciality, however there is an important nuance which needs to be understood work respect to his answer.

Also, I posited the question from a slightly different perspective, however I would be highly confident that this answer would apply to your question. I emailed and asked an FAA Safety Team employee (as opposed to one of the hard to differentiate FAA Safety Team Volunteers) that if the FAA chooses to levy enforcement action(s) upon an FAA Private, Commercial, or ATP certified pilot as a result of this pilot committing a violation of a defined FAA regulation while the pilot was operating under 14CFR Part 91, could the enforcement action be extended to other FAA issued certificates held by the pilot such as a 14CFR Part 145 Airframe & Powerplant (A&P) Aircraft Mechanic Certificate or a 14CFR Part 107 Remote Pilot Certificate.

Having held some form of FAA certification for over well over 3 decades, was certain I know what the answer would be, because I had heard it time and time again. And the FAA Safety Team employee responded with exactly what I thought, absolutely. But like I stated before, this "absolutely" carries with it a number of very important caveats.

First, while I appreciated the response, the response is consistent with all previous answers received when the question has been answered, the truth is that individual's answer to me is just barely better than conjecture. How could that be, he's a no kidding, Federal Paycheck receiving FAA Civil Servant employee, how in the hell could I suggest that his answer was anything but The FAA's version of divine intervention?

Because his job title sounds like the right guy, but he's not the got who would be making the decision, it had likely ever made that type of decision. The FAA Safety Team managers are primarily tasked with spreading the good word, about safety. They coordinate all the Safety Seminars, they can be asked to provide recurrent training to those who have been violated, but that's them doing a favor for a colleague, the colleague who actually wields the stick of enforcement.

Those individuals are called FAA Safety Inspectors. They are the highest authority, above all the Designated Inspectors, when it comes to taking a practical flight exam. If you're a drone pilot and you're unsure if that tell, here's an opinion most won't like to hear. For every single pilot certification, applicants are required to show a 70+ on a proctored 60 - 100 question written exam (should sound familiar). But then, they are required to sit across from either a Designated Examiner or FAA Safety Inspector at a table and answer up to 3 hours worth of direct verbal worsening (called the oral exam, but that's a bit salacious to use), and then followed by what's called the Practical Exam. Based on what specific pilot certification, rating, or type certificate being sought, the practical exam Soraya takes place in the air flying an aircraft the applicant is familiar with and usually lasts over an hour performing a series of requisite manuevers which must be demonstrated within a defined set of standards.

These FAA Safety Inspectors are a group of FAA employees who are in no way affiliated with the FAA Safety Team managers, falling under a completely separate division, or what the FAA colloquially calls a separate "Line of Business", or LOB.

I've been told my entire career that even my A&P could legally, and in some cases would be suspended for serious enough violations being enforced upon a completely unrelated certificate.

However, the second caveat is FARRR now important to fully understand when you are pondering such things. The FAA always has been, always will be, and will do everything in it's power to try and indoctrinate the new sUAS crowd, run as a self regulating, honor based system of checks and balances, who will do nearly everything in their power to avoid resorting to issuing violations of certificated pilots. This may seem hard to believe, but trust me, I've been here a while.

In fact, in my opinion, it takes a pretty special kind of violation of regulations to result in forcing their hand, and even then they will put an emphasis on retraining in lieu of suspensions or revocations of a certificate. There are a few sure ways that they have absolutely no choice, at least from where I stand.

1st, Any violation of the DC-SFRA or Presidential TFR, even popup, they literally have no choice but to suspend your certificate, but also recognize that they will also be advocating on your behalf to the US Secret Service who can get a little trigger happy with the criminal charges.

2nd, Any obvious and willful violations of Class D, Class C, Class B, and/ or Class A airspace, without ATC clearance, and without offering any reasonable justification. This can also happen with repeated, obviously not getting it airspace violations.

3rd, Your violation(s) caused a severe breakdown in the flight safety of your aircraft and any others in the vicinity. If your actions result in the injury of loss of life of other people, your certificates are going to be the last of your problems. I see this being the case the first time a drone operator is foolish enough to get their platform sucked into an engine intake. 22,000 RPM turbine vanes don't have a great record of resiliency in such events, something similar killed 3 people on a Southwest Airlines B-737 a year or so ago.

3rd, If you treat the FAA Safety Investigaters with a heavy dose of wanton disrespect because you're angry they are violating your, they will drop a bookshelf on you and just watch as you struggle to find your footing, and good on them. This bookshelf is of course figuratively speaking and meant to represent worse than getting the book thrown at you.

Here's the deal, if you're called by an Inspector to discuss some violation you may or may not have committed with a drone or manned aircraft, don't snap into the defensive posture and start to deny deny deny. These folks are absolutely here to figure out what happened, ensure you're aware of the regulations, ensure you're clear on what part of your operation was being investigated as the violation, and how to ensure it won't likely issue again on your watch. They have no desire to suspend or revoke anyone's certificates, because they are fully aware that as is often the case with named pilots, this is often the individual's means of making a living.

So, the answer is yes, any enforcement actions resulting from any in-flight regulatory violation of one certificate can have detrimental effects on all other certificates. it could, but the caveat is unless you're really obtuse about or have no intentions of following anyone's roles or regulations

The interesting thing about Party 107 Certificates are the numbers. This actually frustrates me for a number of reasons. Before the Party 107, I have always held at any given time, three separate FAA Pilot Certifications. My Commercial, my Flight Instructor, and my A&P Mechanic certification. Every single one of those really gave no relation to the others, the Instructor Cert being related to Commercial Pilot Cert, I'll concede, but nothing else. Despite these differences, every one of my FAA certificates were adorned with the same number.

Every single one, except now for my Party 107 Remote Operator Certificate. The rumor was back in the day that this was done many years ago to ensure investigators were aware of all certificates. It's BS because my 107 is listed right next to my Commercial Certification record at the FAA.

However I'm quite frustrated that the FAA didn't harmonize the pilot databases, as this former alienates the drone members of the industry, and that's asinine.

I think that answered the question asked.


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