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Standards

Certificates of Authorization

Collision Avoidance

Airworthiness Certification

Pilot Certification and Human Factors

MTCR & Export Control

   

Certificates of Authorization
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Airworthiness Certificates and Certificates of Authorization – Two UAV Passports to Flight


Airworthiness Certification

In September 2005 the FAA has granted the General Atomics Altair UAV the first experimental Airworthiness Certificate for a one year "file and fly" for use in commercial missions. The certification comes with restrictions on weather conditions and altitudes and Visual Flight Rules are in effect at all times. This is a watershed event – a major step forward in the certification adoption timeline and will act as a model system for the FAA to evaluate and fine tune the co-existence of manned and unmanned (HALE and MALE) flight in the USNAS. According to one source close to the process, Bell Helicopter and Northrop Grumman will also receive Experimental Civil use COAs in the very near future. See this page for further information on Airworthiness Certification.

Certificates of Authorization (COA)


Note: The COA process, as described below, is an interim mechanism. A proposed systems of SFARs described here is also being re-evaluated as to practicality and timing. It is not clear what the final system will look like but COAs will likely not be a part of it. Reading between the lines it may evolve to include on one hand a series of FAA Guidance’s covering small lightweight UAVs in a manner similar to those adopted for “Light Sport Aircraft” and on the other a system of Airworthiness certification similar to or identical to that granted to the General Atomics Aeronautical Systems Altair HALE UAV (above). The following discussion of COAs is included because it is the current system and for historical understanding.


The FAA has issued approximately 60 Certificates of Authorization (COA), of which 28 COAs were issued in CY 2004, according to the process described in following link -the DOD Mil 1209 Section 9 specification for Remotely Operated Aircraft (ROA) for restricted airspace flight. COAs are a waiver and represent a temporary procedural interim mechanism authorizing UAV flight, as the FAA, aided by the RTCA, ASTM, Access 5, and UNITE organizations, evolve regulatory airworthiness, collision avoidance standards and certification requirements to be implemented through SFAR regulations thus allowing routine UAV access to the NAS for commercial applications. UAV COA applications are up over 300% this year (2005) however no new civil use COAs have been issued in 2005. Further new COAs for civil commercial flight are currently on hold. The FAA is only evaluating Department of Homeland Security and Department of Defense COAs at this time (Nov 2005).


To quote from a UAV Fact sheet, the FAA describes the COA process and decisions based on the following principles:

  • "The COA authorizes an operator to use defined airspace for a specified time (up to one year, in some cases) and includes special provisions unique to each operation. For instance, a COA may include a requirement to operate only under Visual Flight Rules (VFR).
  • Most, if not all, COAs require coordination with an appropriate air traffic control facility and require the UAV to have a transponder able to operate in standard air traffic control mode with automatic altitude reporting.
  • To make sure the UAV will not interfere with other aircraft, a ground observer or an accompanying “chase” aircraft must maintain visual contact with the UAV." (End Quote)

300 "documented" UAV flights were undertaken in 2004 however this excludes routine military usage in restricted airspace. Many undocumented (read no COA - no filing) civil use flights were also flown. The FAA has recently clamped down on undocumented UAV flights (undertaken without COEs). Even military UAV flights are parsed.


A recent conversation with a regional FAA official, tasked as a point of contact for UAV waiver applications, resulted in the following comments.
  • Certificates of Authorization (COA) exemptions are granted after filing form FAA 7711-2, US Department of Transportation, Federal Aviation Administration. All applications require an airworthiness certificate to be considered for a Waiver to be considered. Waivers are generally granted on a flight by flight basis.
  • Certificates of Waiver for Civil (Commercial) Use are currently on hold. Only the Department of Defense and the Department of Homeland Security applications are being accepted for consideration.
  • Surprisingly, one prominent platform vendor, that has been in this business for many years, and has several mature, literally "battle tested" platforms, has been denied a COA for operations in the US NAS.
  • NASA has been denied a COA on at least one occasion.

UAVM Notes:


This trend leads UAV MarketSpace to the conclusion that little progress will be made in commercializing UAV technology in the US NAS until the FAA completes its certification review and promulgates a standard process and procedure for certification that assures that UAVs operating in the USNAS meet safety standards consistent to those required for piloted flight. Fortunately UAVM expects a Guidance to be issued by March 2006 to address this bottleneck.

Collision avoidance is to be one area of prominent concern for the FAA. A review published in Aerospace America, June 2002 (www.aiaa.org), on collision avoidance technology development sheds some light on progress in this area. Collision avoidance appears to be a relatively mature technology for use on HALE and MALE class UAVs, only requiring system integration and certification to move us ahead. Collision avoidance for SUAVs is another matter entirely in that in general Synthetic Aperture Radar and Transponder systems are too heavy to be considered in SUAV airframes. UAVM is tracking two RADAR based technology systems – both approaches are promising– stay tuned. The ASTM F-38 Committee has issued a published standard for DSA collision avoidance, (F2411-04 DSA Collision Avoidance) that requires a UAV to be able to detect and avoid another airborn object within a range of + or - 15 degrees Elevation and + or -110 degrees Azimuth and to be able to respons so that collision is avoided by at least 500 ft. This gives airframe and avionic/DSA electronics manufacturers a target for certification. It is likely that the ASTM standard will be incorporated by reference in eventual FAA certification requirements.

There is ongoing discussion within the FAA about DSA versus SA. Small light sport aircraft and many UAVs are built of composite structures that have a very light radar footprint. The concern is that without eyes in the sky, perhaps through an Electro Optical video system, alerting a UAV operator to an impending mid-air collision with piloted light sport aircraft, Para foils, or a parachutist, Radar or a SAR may not be sufficient. This is not a large technology hurdle to overcome for a remote operator however autonomous flight for a small UAV would not meet this requirement. These are healthy discussions and clear signs of measurable progress that are intended to meet the safety requirements for all stakeholders, not just the HALE and MALE proponents.

Finally, it should be self evident that September 11, 2001 changed the regulatory picture dramatically. It has clearly complicated the task of creating a rational structure for certification. It is not unthinkable that the SFAR-01 will include an operator vetting procedure.


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