Attaining Airworthiness Certifications for Unmanned Aerial Systems from the Federal Aviation Administration (FAA)
Note: Recently, I attended an airworthiness certification lecture with a friend of mine who is attaining an Aircraft Maintenance Professional (AMP) qualification, and the topics discussed got me thinking about the specific applications to what the FAA would think about UAV’s and the determination of “airworthiness.”
Generally speaking, when an aircraft is designed and proposed to be incorporated into commercial air systems or airspace, the FAA requires a certification be granted to that specific airframe to ensure appropriate safety standards and regulations have been embedded in the design (Federal Aviation Administration, 2016). Compliance with airworthiness directives (AD), FAA regulations and inspections are imperative in the safe operation of an aircraft, and 14 CFR 91.7 (Links to an external site.) specifically prohibits any person from operating an aircraft that is not in an airworthy condition (Aircraft Owners and Pilots Association, 2017).
Integration of the UAS into commercial aviation does not stop at just the design portion, but maintenance requirements as well. 14 CFR 91.407 emphasizes the operator’s additional responsibility by stating, "No person may operate an aircraft that has undergone maintenance, preventative maintenance, rebuilding, or alteration unless: (1) It has been approved for return to service by a person authorized under 43.7 (Links to an external site.)of this chapter; and (2) The maintenance record entry required by 43.9 (Links to an external site.)or 43.11 (Links to an external site.), as applicable, of this chapter has been made" (Seipel, 2013). Therefore, not only does the UAV need to be operated in conjunction with FAA directives for flight, but maintenance procedures and intervals in which maintenance is performed/documented as well. Technological advancements in sensory systems such as Sense-and-Avoid (SAA), and incorporation of NextGen capabilities such as Command, Control, and Communication (C3) will require specific maintenance upkeep and an unblemished documentation record indicating strict adherence to FAA policies if the UAV intends to be registered legally to fly in controlled airspace (Federal Aviation Administration, 2016). Adequate demonstrations of a UAV’s ability to safely work in an environment with manned aircraft, in all different types of operating conditions, will certainly be a task in order to incorporate these vehicles into the existing air network.
To specifically address how to attain 14 CFR 91.203 (a) and (b), the FAA explains in National Policy order 8130.34C the process of possession and display of an aircraft registration, airworthiness certificate and aircraft flight manual. The policy states that “because the aircraft is unmanned, the applicant must petition the FAA for relief from compliance with this requirement in accordance with 14 CFR part 11, General Rulemaking Procedures. If an exemption is granted, the aircraft registration, airworthiness certificate, and aircraft flight manual must be maintained at the location defined in the exemption” (Seipel, 2013). The National Policy further addresses the requirements for maintenance record entries, test data plans, documentation, and experimental certificate or special flight permits for unmanned aerial systems (Seipel, 2013). Successful completion of the appropriate requirements delineated and enforced from the FAA policies will result in legal integration of UAV’s into the national airspace system (NAS), so long as the operator abides by the rules and regulations set forth.
As a separate discussion point, one could assume that not only would the unmanned aerial vehicle (UAV) itself need to be built to conduct safe operations, but there may exist a potential future requirement for regulating the personnel operating the UAV (Aircraft Owners and Pilots Association, 2017). Military UAV operators are highly trained and skilled, and commercial/military pilots are required to be especially knowledgeable of FAA directives and flight rules, so why would personnel flying an FAA approved aircraft from the ground not be held to the same licensing or regulatory standard considering the potential interactions a UAV may face with manned aerial systems.
References:
Aircraft Owners and Pilots Association. (2017). Guide to Aircraft Airworthiness. Retrieved from https://www.aopa.org/go-fly/aircraft-and-ownership/maintenance-and-inspections/aircraft-airworthiness/guide-to-aircraft-airworthiness
Federal Aviation Administration. (2016). Unmanned Aircraft Systems (UAS) Frequently Asked Questions/Help [Fact Sheet]. Retrieved from https://www.faa.gov/uas/faqs/#krp
Federal Aviation Administration. (2013). Integration of Civil Unmanned Aircraft Systems (UAS) in the National Airspace System (NAS) Roadmap (FAA 2012-AJG-502). Washington, DC: U.S. Government Printing Office.
Seipel, J. (2013, August 2). Order 8130.34C, Airworthiness Certification of Unmanned Aircraft Systems and Optionally Piloted Aircraft. Retrieved from U.S. Department of Transportation, Federal Aviation Administration, Production and Airworthiness Division, AIR-200, https://www.faa.gov/documentlibrary/media/order/8130.34c.pdf.
Note: Recently, I attended an airworthiness certification lecture with a friend of mine who is attaining an Aircraft Maintenance Professional (AMP) qualification, and the topics discussed got me thinking about the specific applications to what the FAA would think about UAV’s and the determination of “airworthiness.”
Generally speaking, when an aircraft is designed and proposed to be incorporated into commercial air systems or airspace, the FAA requires a certification be granted to that specific airframe to ensure appropriate safety standards and regulations have been embedded in the design (Federal Aviation Administration, 2016). Compliance with airworthiness directives (AD), FAA regulations and inspections are imperative in the safe operation of an aircraft, and 14 CFR 91.7 (Links to an external site.) specifically prohibits any person from operating an aircraft that is not in an airworthy condition (Aircraft Owners and Pilots Association, 2017).
Integration of the UAS into commercial aviation does not stop at just the design portion, but maintenance requirements as well. 14 CFR 91.407 emphasizes the operator’s additional responsibility by stating, "No person may operate an aircraft that has undergone maintenance, preventative maintenance, rebuilding, or alteration unless: (1) It has been approved for return to service by a person authorized under 43.7 (Links to an external site.)of this chapter; and (2) The maintenance record entry required by 43.9 (Links to an external site.)or 43.11 (Links to an external site.), as applicable, of this chapter has been made" (Seipel, 2013). Therefore, not only does the UAV need to be operated in conjunction with FAA directives for flight, but maintenance procedures and intervals in which maintenance is performed/documented as well. Technological advancements in sensory systems such as Sense-and-Avoid (SAA), and incorporation of NextGen capabilities such as Command, Control, and Communication (C3) will require specific maintenance upkeep and an unblemished documentation record indicating strict adherence to FAA policies if the UAV intends to be registered legally to fly in controlled airspace (Federal Aviation Administration, 2016). Adequate demonstrations of a UAV’s ability to safely work in an environment with manned aircraft, in all different types of operating conditions, will certainly be a task in order to incorporate these vehicles into the existing air network.
To specifically address how to attain 14 CFR 91.203 (a) and (b), the FAA explains in National Policy order 8130.34C the process of possession and display of an aircraft registration, airworthiness certificate and aircraft flight manual. The policy states that “because the aircraft is unmanned, the applicant must petition the FAA for relief from compliance with this requirement in accordance with 14 CFR part 11, General Rulemaking Procedures. If an exemption is granted, the aircraft registration, airworthiness certificate, and aircraft flight manual must be maintained at the location defined in the exemption” (Seipel, 2013). The National Policy further addresses the requirements for maintenance record entries, test data plans, documentation, and experimental certificate or special flight permits for unmanned aerial systems (Seipel, 2013). Successful completion of the appropriate requirements delineated and enforced from the FAA policies will result in legal integration of UAV’s into the national airspace system (NAS), so long as the operator abides by the rules and regulations set forth.
As a separate discussion point, one could assume that not only would the unmanned aerial vehicle (UAV) itself need to be built to conduct safe operations, but there may exist a potential future requirement for regulating the personnel operating the UAV (Aircraft Owners and Pilots Association, 2017). Military UAV operators are highly trained and skilled, and commercial/military pilots are required to be especially knowledgeable of FAA directives and flight rules, so why would personnel flying an FAA approved aircraft from the ground not be held to the same licensing or regulatory standard considering the potential interactions a UAV may face with manned aerial systems.
References:
Aircraft Owners and Pilots Association. (2017). Guide to Aircraft Airworthiness. Retrieved from https://www.aopa.org/go-fly/aircraft-and-ownership/maintenance-and-inspections/aircraft-airworthiness/guide-to-aircraft-airworthiness
Federal Aviation Administration. (2016). Unmanned Aircraft Systems (UAS) Frequently Asked Questions/Help [Fact Sheet]. Retrieved from https://www.faa.gov/uas/faqs/#krp
Federal Aviation Administration. (2013). Integration of Civil Unmanned Aircraft Systems (UAS) in the National Airspace System (NAS) Roadmap (FAA 2012-AJG-502). Washington, DC: U.S. Government Printing Office.
Seipel, J. (2013, August 2). Order 8130.34C, Airworthiness Certification of Unmanned Aircraft Systems and Optionally Piloted Aircraft. Retrieved from U.S. Department of Transportation, Federal Aviation Administration, Production and Airworthiness Division, AIR-200, https://www.faa.gov/documentlibrary/media/order/8130.34c.pdf.
Anthony
ReplyDeleteIn your blog, I see no issues with military aircraft being able to meet these requirements for airworthiness. The military operates by strict standards to ensure that all of its aircraft are safe and are capable of conducting flights in a responsible manner. The issue comes in when you have brand new civilian entities coming into the system with many different types and sizes of UAV aircraft wanting to utilize and share the airspace with manned aircraft. The problem comes into being able to accurately classify these different types of aircraft in order to be able to assign airworthiness standards. Currently the FAA issues Special Airworthiness Certifications for aircraft operating within certain specific classes of UAS (FAA, 2016).
Several approaches have been initiated in order to do this. Currently, the military and civilian general aviation utilize a system which identifies the safety risks which are inherent in different types of aircraft. The notion is that certain types of civilian UAS could be classified in the same manner. Basically classifying aircraft on criteria and factors which are most important in the interest’s safety (Maddalon et al., 2013). This is probably one of the main reasons that smaller UAS under a certain weight category are currently not bound by specific airworthiness standards and are only required to be registered for use with the FAA.
References
FAA. (2016). Special Airworthiness Certification. FAA. Retrieved from: https://www.faa.gov/aircraft/air_cert/airworthiness_certification/sp_awcert/experiment/sac/
Maddalon, J., Hayhurst, K., & Morris, A. (2013). Considerations of Unmanned Aircraft Classification for. Hampton VA: NASA Langley Research Center .
Great job on your blog Tony!
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