UA.V.E.K2: Drug and alcohol use.

ACS Area V — Operations Task E: Physiology References: ACAdvisory CircularCloseFAA guidance that explains acceptable ways to comply with rules or understand FAA procedures. 107-2; FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.-H-8083-2, FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.-H-8083-25; FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.-G-8082-22

Key Concepts

The Rule: Operations While Impaired (§107.27)

• You may not conduct a small UASSmall Unmanned Aircraft SystemCloseA small drone plus the control and communication links used to operate it. operation if any required crewmember—the remote PICRemote Pilot in CommandCloseThe certificated remote pilot responsible for the Part 107 operation., person manipulating the controls, or the visual observer (VOVisual ObserverCloseA person who helps the remote PIC see and avoid hazards during a drone operation.)—is unable to carry out their responsibilities safely. It is the remote PICRemote Pilot in CommandCloseThe certificated remote pilot responsible for the Part 107 operation.’s responsibility to ensure this before and during the flight. This prohibition applies to any cause of impairment (including drugs or alcohol) that degrades the ability to perform safely under §107.27.^[8]

What Impairment Undermines in UAS Operations

• Core see-and-avoid and aircraft management tasks demand unimpaired perception, attention, and judgment. Under part 107, the remote PICRemote Pilot in CommandCloseThe certificated remote pilot responsible for the Part 107 operation. must know the aircraft’s location; determine its attitude, altitude, and direction; yield the right-of-way to other aircraft; and maintain the ability to see and avoid other aircraft. Impairment directly compromises these required abilities, making the operation unsafe and unlawful.^[8]
• In broader NASNational Airspace SystemCloseThe shared U.S. airspace system that drones must operate within. operations, UASUnmanned Aircraft SystemCloseAn unmanned aircraft plus its control station, communication links, and supporting components. approvals require observers to provide “see-and-avoid” capability and ensure compliance with 14 CFRCode of Federal RegulationsCloseThe federal rulebook where Part 107, Part 89, Part 48, and other aviation rules live. §91.113. Any degradation of observer or pilot performance defeats this requirement and elevates midair risk.^[5]

High-Consequence Contexts: Over People and Moving Vehicles

• Operations over human beings fall under Subpart D. Category 1 aircraft must weigh 0.55 pounds or less throughout the operation and have no exposed rotating parts that would lacerate human skin. Such operations are permitted only as specified in §§107.110, 107.115, 107.120, 107.125, 107.130, and 107.140, and the rule limits open-air assemblies unless remote ID requirements are met. When human exposure risk is intrinsically higher, any impairment by the pilot or VOVisual ObserverCloseA person who helps the remote PIC see and avoid hazards during a drone operation. is unacceptable.^[3]
• Over moving vehicles, the rule is even more sensitive to judgment and control. Outside closed/restricted-access sites, only transit is permitted—no sustained flight—over persons not directly participating. Misjudgment due to impairment can easily turn a brief transit into prohibited sustained overflight.^[1]
• Category-based safety limits also underscore why unimpaired operation is essential. For example, a Category 2 aircraft must be designed so it will not cause injury equivalent to or greater than 11 foot-pounds of kinetic energy, have no exposed rotating parts that would lacerate human skin, and be free of safety defects, with required labeling and operating instructions. Poor decision-making or degraded attention from drugs or alcohol can lead to misuse outside these documented limitations.^[4]

Compliance and Certificate Implications

• If a pilot cannot meet safety responsibilities (e.g., due to ongoing substance issues), one option is voluntary surrender of the remote pilot certificate. If surrendered for cancellation, the certificate will not be reissued unless the individual again completes the requirements in §§107.61 and 107.63. This underscores the seriousness of maintaining unimpaired performance and regulatory compliance.^[3]
• Bottom line for test day and real-world flying: §107.27 bars operations when any crewmember cannot safely perform their role. The remote PICRemote Pilot in CommandCloseThe certificated remote pilot responsible for the Part 107 operation. must actively verify fitness for duty. This is critical not only for routine VLOSVisual Line of SightCloseThe requirement to see the drone well enough to know its location, attitude, altitude, and direction of flight. flights but especially for operations with elevated risk—over people or near moving vehicles—where impaired performance can rapidly lead to prohibited conditions and unsafe outcomes.^[8][1][3]