Certification of Airframes

[jtprouty]

Hi All,

It looks like the future will probably become more costly for those of us developing UAV/UAS airframes and systems. AOPA (Aircraft Owner's and Pilots Association) now has a say in the writing of the regs governing UAVs:

"After asserting for years that unmanned aerial vehicles (UAVs) should meet the same certification and operational standards as piloted aircraft before being allowed to operate freely in the National Airspace System, AOPA has been asked to participate on the FAA's aviation rulemaking committee to help develop those standards. "AOPA wants UAVs to be integrated seamlessly into the National Airspace System so that there isn't a negative impact on general aviation," said AOPA Senior Director of Regulatory Affairs Rob Hackman."

Quoted from the AOPA ePilot daily newsletter.

Jimmy

[patrickegan]

I’ve been playing phone tag with Mr. Hackman for the past few weeks, he’s the AOPA’s representative for the (s)UAS ARC. You have to understand that changes are coming, and we have to as a community come together and show that we can operate safely. Certification of airframes as most of the aviation community see’s it, would be cost prohibitive for us.

[jtprouty]

Hi Patrick,

I've been following the certification issue since it was first brought up. A former "friend" of mine a our flying club is in the FAA and is part of the certification process. I hadn't seen him uin quite some time and saw him again at the RC field in 2005. Rather than saying hello he walked up and said that he was on the cert team and that he is the guy that's "going to shut us down". It's the FAA's stance that they own the airspace from the ground up and control everything in it.

They have been kicking around the certification issue now for over 3 years and are getting closer to issuing thier findings and regulations. AOPA will, no doubt, push for the most stringent regulation of UAVs and their operators. I know at one point the FAA was pushing for the pilot of a UAV to hold a commercial pilot's license - just an example of over regulation. They are also considering that an aircraft mechanic with Inspection Authorization be required to certify that each airframe is airworthy after production. Luckily I hold both certificates so that won't be an issue for me. It will, however, drive up the cost for companies that don't currently have that certification capability.

Hopefully they will keep the certification for small UAVs reasonable enough to allow us "little guys" with limited assets the ability to produce the systems that we've been working so hard on.

Jimmy

[patrickegan]

Jimmy,

Thanks for the insight. Yes, there’s a lot of different ways this thing can go but I’ll say that I’m guardedly optimistic going in to the ARC. There’s a lot of frustration out there for people who like to operate within the law…

[clolson]

Jimmy,

Thanks for the insight. Yes, there’s a lot of different ways this thing can go but I’ll say that I’m guardedly optimistic going in to the ARC. There’s a lot of frustration out there for people who like to operate within the law…

I don't have anything new or brilliant to say, but I hate to let minor details like that stop me from commenting. :-)

I personally believe that a UAV being operated in a way where it could potentially get near to a full scale "manned" aircraft should be regulated pretty heavily and have strong safety requirements. The AOPA has a right to be concerned about this sort of competition for the airspace, not to mention the lives of pilots.

For UAVs that will never, ever be near full scale aviation or parachuters or ultralights or hot air balloonists, etc. then much of this FAA regulation and AOPA concern is incredible overkill and an unreasonable burden.

Maybe I'm the oddball around here, but I see both perspectives, and I'm hoping that whatever regulations eventually are passed down will allow for both types of operations.

The really tricky part about this is that it's very easy for someone to step from one of these worlds to the other ... to take an airfame that could never be a threat to anything, and fly it in a way or in a location that could hurt someone.

If the FAA does require a licensed pilot to operate a UAV, that has some merit. 1. the UAV operator will by definition be familiar with full scale operations, communications, safety, procedures, etc. 2. The FAA would then have some leverage over UAV operators in case they decided to be dumb or act in an unsafe manner or break the rules ... they could yank your ticket.

I was recently involved in a project where we flew our UAS off a NOAA ship 1000nm from the nearest point of land. The FAA required us to have a hand held radio tuned into (apparently any random) general aviation frequency. Our COA also required that we keep our UAS within visual line of sight. WIth our airframe, controllable line of sight was about a 1/2 mile radius. This was enough for us to do many flight tests, but not enough to do anything useful operationally. Surprisingly, we saw no general aviation on our entire trip. Once we were back inside Pearl Harbor (NOAA vessel) we did start seeing some helicopters overflying us.

So I am crossing my fingers hoping that the FAA mixes in a healthy dose of common sense into their regulations. But I am also hopeful that everyone doing this at the hobby level tries to understand the concerns of the FAA and the concerns of full scale pilots. They aren't all evil and stupid, they have valid concerns and the ultimate goal is to protect the safety of everyone who is flying.

Curt.

[patrickegan]

Curt,
I had an opportunity to speak with Rori at NASA Ames, he made a darn good case (preaching to the choir), for NOAA use of this technology. Our job is to show that this technology can be used safely and get people to realize that we aren’t all flying Predator. The next battles are public perception and acceptance.
Patrick

[jetblackaircra]

These horror stories about the FAA being excessively restrictive are no surprise to me. After working for McCauley Propeller Systems and dealing with a recent move from one ACO (aircraft certification office) to another for our certification process I have seen how when an FAA cert engineer is unsure about something, they tend to add more restrictions. They're trying to cover their ass. At McCauley we were constantly having to remind the people at the ACO that we had been building propellers for decades and that the restrictions and requirements they were trying to put on us would not only cause excessive cost to us, but were also completely unneccessary.

Keep in mind that the FAA does not just do as they please and not take any feedback from the industry. There are documents called NPRM (notice of proposed rulemaking) which describe changes the FAA plans to make in a certain area of the CFRs. They allow the public to reply with objections for a given period of time. If a large enough group of companies who are regulated by that area of the CFRs object to the same areas, they will restructure the rule to better suit the parties involved. They also do a cost analysis to see what the cost burden will be to the industry.

http://www.faa.gov/regulations_policies/rulemaking/recently_published/ (recent NPRMs)

Keep an eye on that page for when some UAV NPRMs are released. I'm sure if you subscribe to an aero-news email list it will show up on there too.

On the idea of A&Ps signing off UAV airframes... ...this makes sense on an airframe like the predator, but on small scale airframes it is ridiculous. A&P mechanics have no idea what makes a 7 foot span UAV airworthy. There needs to be some method, just like on certified aircraft, by which an FAA engineer, or a designee who works for the company making the UAV (DOA, DER, DMIR process) signs off on the engineering, manufacturing, and quality processes. Lets face it, just like in full-scale aircraft, the people designing and building these things know more about them than anyone else, including the FAA.

As for a certified pilot as an operator.... I want to know how they plan on integrating fully autonomous vehicles which do not require an operator. I'm aiming high. :-)

[jtprouty]

I also agree that there should be regulation of the flight operations of UAVs. Whenever I see someone post a video of themselves flying their model airplane much higher than they are supposed to it scares me as a private pilot. (Ever seen the video of the full sized helicopter passing UNDER an R/C plane with a video camera on it?) The FAA is watching these postings as well - actually saw them play videos of RC planes from the internet - most from RCGroups and RCUniverse - during their briefings on proposed legislation of our little niche.

My concern about AOPA getting involved in the process is over-regulation of the industry. AOPA has deep pockets and seems to get what it wants when it comes to regulations. They were instrumental in Jimmy Carter vetoing a bill that would have made aircraft mechanics "skilled" or "professional" labor. The pilots didn't want to pay us what we're worth and AOPA banded with them to stop the legislation.

As for needing your pilots license to be able to fly a UAV - I disagree. Requiring the UAV pilot to go through ground school and have recurrent training is a much better way of doing business (IMHO).

Jimmy

[jtprouty]

Jetblack -

I agree with not needing an IA to buy of on the construction of the UAVs. The FAA is looking at is as a way to let us sign off our own work. Concerning the full scale manufacturers - they have qualified A&P mechanics sign off all of the work as inspectors. The people building the planes under the factor license don't have to be certified but the people signing off that the work was done correctly do.

I agree that the FAA will look for feedback from the industry but I believe that they'll listen to the companies that are already established before they'll consider what we have to say. The big companies that are already in the business can afford more stringent regulation than we can and they would benefit from the regs keeping the competition down. We'll have to wait and see what they come up with.

Jimmy

[makemcool]

Please forgive my ignorance. I checked the UAV sticky, and didnt find anything to enlighten me. Is there a difference between a UAV and a standard RC model? If so, is it related to size, use of GPS for control, or some other element? Thanks for your patience.
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Ok, I went back and found what I assume is the answer...Apparently the main difference is an RC model is for pleasure, and a UAV is used for commercial purposes.

[matttay]

On the idea of A&Ps signing off UAV airframes... ...this makes sense on an airframe like the predator, but on small scale airframes it is ridiculous.

You hit the nail on the head here. I'm not sure why a 2 pound airplane flying at 400 feet AGL is a bigger threat than a 10 pound goose lingering around airports. Geese have been known to fly over 15,000 feet high to cross mountains.

Hopefully, if the FAA goes through with this then they will set up classes of operation, with certain classes requiring zero oversite. I think everyone here and at the FAA agrees that a 100 pound model flying at 80 MPH over cities needs to be treated differently than a 1 pound foamie model traveling at 40 MPH in the dessert.

What will cause the problem here is that there's range of folks in between those ranges that will fight like hell to get their interests unregulated, and the end result will be that EVERYTHING is regulated. Perhaps a compromise is that the intermediate class of operators shoudl be required to carry insurance. If indeed the safety record is good, then the insurance cost would be very small. If the safety record is poor, then the insurance cost will be high (and it would also indicate that the FAA should step in).

In any case, treating this as "all or nothing" will be a mistake. Folks should be very clear about what they feel should be unrestricted, and seriously consider what should require more oversite.

Personally, a two to three pound foam model with a max ceiling of 400 AGL and a cruising speed of 50 MPH is about the upper limit for me. Beyond that, I'd like some some assurance that you can afford to put me back together again if by chance it hits me in the back of the head.

[matttay]

Please forgive my ignorance. I checked the UAV sticky, and didnt find anything to enlighten me. Is there a difference between a UAV and a standard RC model? If so, is it related to size, use of GPS for control, or some other element? Thanks for your patience.
.................................................. ..................................................
Ok, I went back and found what I assume is the answer...Apparently the main difference is an RC model is for pleasure, and a UAV is used for commercial purposes.

No, a RC Plane has a pilot dedicated to the task of flying the plane 100% of the time and it is always in visual contact.

A UAV might have a computer flying the plane some of the time, and there is no guarantee that a pilot is in visual contact with the airplane.

[patrickegan]

No, the distinction in this case is “commercial use” , different levels of autonomy have nothing to do with the UAV/UAS classification or what is our current regulatory situation.

[kd7ost]

.................................................. ..................................................
Ok, I went back and found what I assume is the answer...Apparently the main difference is an RC model is for pleasure, and a UAV is used for commercial purposes.

Correct,

That is how it is being viewed.

Dan

[jetblackaircra]

Hopefully, if the FAA goes through with this then they will set up classes of operation, with certain classes requiring zero oversite. I think everyone here and at the FAA agrees that a 100 pound model flying at 80 MPH over cities needs to be treated differently than a 1 pound foamie model traveling at 40 MPH in the dessert.

...

In any case, treating this as "all or nothing" will be a mistake. Folks should be very clear about what they feel should be unrestricted, and seriously consider what should require more oversite.


I agree completely. Just like full sized aircraft, there are different requirements for aircraft of different sizes and missions. Take the recently added Light Sport Category. The FAA realized that this size aircraft with certain limitations can be safe enough to not require a current medical to fly it as well as allowing manufacturers to follow less strict guidelines for certification. The Light Sport aircraft are not certififed to CFR Part 23 or 25 like most are. A similar set of regulations on UAVs is fine with me. Give us weight/airspeed/altitude restrictions in order to get into certain categories of certification so that your 2 lb foamy going 40 mph only has to have a set of drawings approved by the ACO and a letter of conformity from the manufacturer (similar to Light Sport). But, when I build a 30 ft span, 1200 lb, 200 mph aircraft to do local law enforcement video surveillance or whatever, it has to follow much more strict rules closer to Part 23.

This is something I hope the FAA realizes... that a 2 lb airplane could get sucked into the intake of a jet or hit the windshield of a Cessna and probably not cause much damage. But, I'm perfectly fine with having to put a transponder and other traffic avoidance equipment (TCAS, cameras, strobes, etc.) in my UAV that weighs enough to cause some damage.

[chickenblender]

Ever seen the video of the full sized helicopter passing UNDER an R/C plane with a video camera on it?

Nope, haven't seen that. Any links? Not trying to mock a serious safety hazard, but that would be a very cool video.

Cory

[jtprouty]

Cory,

It's been a couple of years since I last saw that video. Don't remember where it was posted (RCGroups or RCUniverse) and a quick search didn't find it.

Jimmy

[Pinga_Dog]

The FAA has started to recognize that different size uav's need to be treated differently, just like different size airplanes have different certification (FAR part 23, 25, 27, and 29) requirements and different operating rules (FAR part 91, 121, 135). The FAA is working with ASTM to develop operational and airworthiness standards.

ASTM subcommittee F38 has been trying to develop these standards for a couple of years. Currently then are working on "Standard Specification for Design and Performance of an Unmanned Aircraft Systems - Class 1320" which encompasses 550 lb to 1320 lb vehicles and "Standard Guide for Mini-UAS Airworthiness" which is for line of sight models under 55 lbs. They are also working on operational rules, and pilot requirements.

These are self certification guidelines which we hope the FAA will accept as a means of airworthiness certification much like they have done with Light Sport Aircraft (LSA).

Unfortunately it is a slow process, and it takes time to educate the stakeholders (committee members including FAA) and "dumb down" the requirements to a level that provides adequate safety yet is practical for smaller companies to implement.

Stan

[jetblackaircra]

That's good news Stan.

Is there somewhere we can get more info about this? Somewhere to track their progress?

Mike

[Pinga_Dog]

http://www.astm.org/COMMIT/COMMITTEE/F38.htm

[macboffin]

You hit the nail on the head here. I'm not sure why a 2 pound airplane flying at 400 feet AGL is a bigger threat than a 10 pound goose lingering around airports. Geese have been known to fly over 15,000 feet high to cross mountains.

Hopefully, if the FAA goes through with this then they will set up classes of operation, with certain classes requiring zero oversite. I think everyone here and at the FAA agrees that a 100 pound model flying at 80 MPH over cities needs to be treated differently than a 1 pound foamie model traveling at 40 MPH in the dessert.

What will cause the problem here is that there's range of folks in between those ranges that will fight like hell to get their interests unregulated, and the end result will be that EVERYTHING is regulated. Perhaps a compromise is that the intermediate class of operators shoudl be required to carry insurance. If indeed the safety record is good, then the insurance cost would be very small. If the safety record is poor, then the insurance cost will be high (and it would also indicate that the FAA should step in).

In any case, treating this as "all or nothing" will be a mistake. Folks should be very clear about what they feel should be unrestricted, and seriously consider what should require more oversite.

Personally, a two to three pound foam model with a max ceiling of 400 AGL and a cruising speed of 50 MPH is about the upper limit for me. Beyond that, I'd like some some assurance that you can afford to put me back together again if by chance it hits me in the back of the head. Re Geeese at altitude, saw a pic on the Net of the front end of a 747, nose bashed in by a goose, most of which finished up under the co-pilots feet, incident recorded at 41,000 ft!

[chickenblender]

Re Geeese at altitude, saw a pic on the Net of the front end of a 747, nose bashed in by a goose, most of which finished up under the co-pilots feet, incident recorded at 41,000 ft!

Ack, and again you guys taunt me with amazing stories but no pictures! :D

Cory

EDIT: Googling "bird 747" found this picture (http://www.micom.net/oops/Bird-v-Plane.jpg).

[small_rcer]

On same site look at oop9.jpg for another bird strike photo.

And then Plane eats Pelican.jpg as well

Jim H

[matttay]

No, the distinction in this case is “commercial use” , different levels of autonomy have nothing to do with the UAV/UAS classification or what is our current regulatory situation.

The commercial use aspect seems a red herring. If someone can sell me a bottle of weight loss pills on late night TV for FREE + $20 shipping and handling, then I'm sure most commercial operators could fly for FREE and then charge a $200/hour photoshop fee.

If this is an FAA rule that eventually materializes, then wouldn't it be the FAA that is policing these and writing the violations? I have enormous respect and admiration for the current system the FAA has put into place, but I just don't see the FAA showing up at the launch point of a UAV flight and citing everyone there. They have much bigger things to worry about.

What everyone should be concerned with is what will happen IF (and there will be) there is an accident in which life is lost or property is damaged. In that case, whether or not you were flying for money won't be a factor. The overwhelming factor should be whether or not what you were doing was excessively risky and whether or not you took precautions. Remember that even if you were doing something LEGAL but you failed to take precautions and someone dies, then the charge can still be manslaugter.

After the legal issues will come the civil issues. What the law says or how the FAA classified your activity really doesn't matter. If the party you hurt thinks you have some money and they think it's easy to show that you were being negligent, then call the cleaners and let them know you are coming because a car will be taking you there shortly.

I really hope the FAA makes it clear that below a certain size/weight there's no concern if certain rules are followed. But it seems that no matter what the FAA writes as a rule, the only difference in how things play out IF there is an accident will be whether or not you pay a penalty to the FAA. Everything else will play out the same. Depending on the severity of the accident, you could be looking at everything up to and including jail and a several million dollar lawsuit. Of course, we carry this same risk everyday in driving a car...

[patrickegan]

Mattay,
You make some good observations. For sure we aren’t looking at an “IF” situation, “WHEN” it does happen my guess is the operator/pilot will get himself nailed shut.

[jetblackaircra]

Does anyone know if AMA insurance covers UAV operations as long as the aircraft follows the guidelines of the AMA?

[jtprouty]

It's my understanding that if you're flying and meeting ALL of the AMA rules that you should be covered. If the UAV has an autopilot malfunction and flies off you might not be covered. Also, if you are flying professionally (for pay or as a part of your job) you probably won't be covered.


Jimmy

[CenTexFlyer]

Does anyone know if AMA insurance covers UAV operations as long as the aircraft follows the guidelines of the AMA?

You should also check your homeowners insurance, because the AMA will only cover what your homeowners won't! So if your policy has a "business" clause in it and they don't cover, chances are the AMA won't either. You know the drill... monkey see, monkey do......

[patrickegan]

If it's not in the safety code, it's not covered. Autonomous aids (last time I checked) were verboten.

[lvspark]

I think rule 10 forbids

[patrickegan]

It really remains to be seen where the semi-autonomous crowd will fall. My feeling is that they think many of these niches will need to be sorted out, compartmentalized and administered.

We may very well look back upon this as the happy time!