Initial Experimental Airworthiness Certification Guidance for UAS. UAS Experimental Certification Process and Guidance

This paper addresses the regulatory processes and requirements already in place by which an applicant might obtain experimental airworthiness certification for a civil Unmanned Aircraft System (UAS). It is more extensive and subsequent to an earlier, similar deliverable, PD007, which was an interim study of the same topic. Since few regulatory airworthiness and operating standards exist for UAS like those for traditional manned aircraft and since most UAS have historically been developed and operated under military auspices, civil use of UAS in the NAS is a new and unfamiliar challenge requiring specific and unique considerations. Experimental certification is the most basic level of FAA approval toward routine UAS operation in the NAS. The paper reviews and explains existing FAA requirements for an applicant seeking experimental airworthiness approval and details the process for submission of necessary information. It summarizes the limited purposes for which experimental aircraft may be used and addresses pertinent aspects of UAS design, construction and operation in the NAS in harmony with traditional manned aircraft. Policy IPT position is that UAS, while different from manned aircraft, can use the same initial processes to gain civil operating experience under the experimental approval. Particular note is taken of those UAS-unique characteristics which require extra attention to assure equivalent safety of operation, such as the UAS control station and sense-and-avoid. The paper also provides "best practices" guidance for UAS manufacturers and FAA personnel in two appendices. The material in Appendix A is intended to provide guidance on assuring UAS safety to FAA, and provides FAA personnel with a suggested list of items to review, with a focus on UAS unique factors, prior to issuance of an experimental airworthiness certificate. Appendix B provides an outline for a program letter which a manufacturer could use in preparing the application for an UAS experimental airworthiness certificate.