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The Association for Unmanned Vehicle Systems International (AUVSI) said it supports the Federal Aviation Administration’s (FAA’s) plans to review type certification for unmanned aircraft systems (UAS), which is necessary with the arrival of remote and tracking identification.
In a filing with the FAA on a Notice of Policy for the type certification of certain UAS under part 21 of the federal aviation regulations, AUVSI also says the FAA should completely amend the type certification and product certification (TCPC) process by taking a more holistic approach to operations that are performed outside of existing regulations for small UAS, also known as drones.
The certification would replace the current requirements for waivers under part 107, which are the federal rules for operating small UAS, or authorization through part 135, the regulations for air carriers, to perform extended and complex operations, including beyond visual line of sight and flying at night, which are necessary to provide services such as UAS package delivery.
“AUVSI is pleased that the FAA wishes to recognize under the amended 14 CFR part 21, at amendment 21-60, for the issuance of type certificates for special classes of aircraft that feature performance based standards specific to UAS that are very unique, novel, and or with unusual features that the special category was designed to accommodate,” AUVSI says in the filing.
AUVSI also calls on the FAA to include in its assessment of type certification the Durability and Reliability (D&R) initiative and the FAA Modernization of Special Aircraft Certification (MOSAIC), which are due to be implemented by September 2023.
“AUVSI feels strongly that the FAA must now provide a clear vision and timeline on how it can deliver actionable guidance regarding the future TCPC process to remove uncertainty in the industry,” the association said. “And further information for applicants to demonstrate suitable mitigations for air risk to achieve both 14 CFR §107.205 complex operations, or those of a more demanding nature, such as 14 CFR part 135 on-demand operations, within either a proposed D&R or MOSAIC framework.”