Missing from Part 107 is what caught my attention, and the motivation for this discussion. Missing is comprehensive directives in Part 107 regarding the sUAS quality of product (Airworthiness) as well as a requirement for any maintenance protocols. And, although AC107.2 does provide maintenance proposals, Advisory Circulars are “not mandatory and do not constitute regulation”. Thus, compliance with these suggestions is not mandatory. Furthermore, neither AC107.2 nor Part 107 address sUAS airworthiness. So, who is responsible for the airworthiness and maintenance of the sUAS, and by what or whose standards? Well, there are no Airworthiness standards for the sUAS because as you will soon discover, the sUAS by definition is not considered “airworthy.” The operational sUAS must meet only the criteria of “condition for safe operation” which is determined by the Remote Pilot In Command! Ah yes, this does seem a bit inconsistent I know. So stay with me as we explore this conundrum But before we go exploring and as a point of
interest, as well as some cool cocktail knowledge, what about the UAS that weighs over 55 pounds and the sUAS under .55 pounds? For the UAS (55 pounds +), aircraft certification and registration as well as pilot certification and UAS maintenance are covered under order 8130-34C and 49 U.S.C. sub 44807 as well as 14CFR Parts 21, 61, and 91. And for those sUAS that are under .55 pounds used by the hobbyists, there are three ways for recreational sUAS fliers to operate in
22
HelicopterMaintenanceMagazine.com February | March 2020
accordance with the FAA regulations. The choice is up to the individual operator: Option #1: Fly in accordance with the Special Rule for Model Aircraft (Public Law 112-95 Section 336). Option #2: Fly in accordance with 14CFR 101.41 & 101.43
Option #3: Fly in accordance with 14CFR 107 Also, for the hobbyists who fly the .55 to 55 pound
sUAS, it is recommended to fly in accordance with Part 107. Part 107 pilot requirements and responsibilities are found in Sub parts 107.12 ; 107.15 and 107.65 with AC-107-2 Chapter 6 dispensing details on the process. And registration instructions in Part 107.13 leading to reference Part 91.203 (a)2, with AC-107.2, Chapter 5.4-5.4.1 adding more detailed verbiage and guidance: “The Federal Aviation Administration (FAA) requests
drone owners to register each drone that is purchased weighing over .55lbs. If your drone is not registered properly you may be subject to the legal consequences defined in the U.S. Government drone regulation terms.” Thereby, operating under Part 107 each sUAS should be registered and pilots qualified and certified. The FAA expectation is that by having the sUAS aircraft operationally regulated and the sUAS pilot certified they, the FAA, will have control over this innovative technology, and thereby create a safer flight environment for all aircraft. It is this limited expectation by the FAA that I find unsettling. Because controlling the flight operations
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60 |
Page 61 |
Page 62 |
Page 63 |
Page 64 |
Page 65 |
Page 66 |
Page 67 |
Page 68
