§107.15 Condition for safe operation. “(a) No person may operate a civil small unmanned
aircraft system unless it is in a condition for safe operation. Prior to each fl ight, the remote pilot in command must check the small unmanned aircraft system to determine whether it is in a condition for safe operation.
(b) No person may continue
fl ight of the small unmanned aircraft when he or she knows or has reason to know that the small unmanned aircraft system is no longer in a condition for safe operation.” However, If you want recommendations for an ongoing maintenance program AC107-2 does a respectable job on this subject in Chapter 7 and Appendix C of the AC. So the information is there, that is if you are aware of
and read AC107-2. Although, as there is no reference to AC107-2 in 14CFR Part107, for the inexperienced sUAS operator maintenance is subjective. And as a matter of fact, the actual subject of “maintenance” is not even mentioned in Part 107. Part 107.15 addresses only who is responsible for the condition for safe fl ight. So, with a vast amount of the new sUAS pilots also new to the NAS community sUAS maintenance information can remain undiscovered. After all, even we aviation types have found that navigation of the FAA Regulations and Advisory Circulars can be intimidating and circuitous, so consider what the inexperienced sUAS owner is encountering. And thus, in the absence of a defi nitive regulation or even a reference to a detailed recommendation about maintenance you will get an ignorant operator, and a probable unsafe operation. A validation of this premise is illustrated by the graph above. The supporting information for the graph was
harvested by a company invested in the secure control of drone integration into the NAS. The resulting data was collected from interviews of over 100 pilots who were actively involved during both authorized and unauthorized sUAS operations. This graph, published in 2018, is a notable snapshot of the experience level of the sUAS pilot. What is not known is what percentage of this group is certifi cated via Part 107. A good guess would be the 3.2%…And being even-handed here, as the part 107 sUAS pilot experience has been increasing, the 3.2% has also been slowly growing, replacing the population of the clueless and the careless operators. Ok what about the sUAS not being considered
Airworthy? And what is the diff erence between “Airworthiness” and “Condition for Safe Operation”? Well, as promised here are the defi nitions of these terms.
Airworthy: per FAR 91.7 means that the aircraft
must conform to its type design / Certifi cate (TC). TC is attained when the aircraft and its installed components are consistent with the approved drawings and specifi c instructions which includes any STC or approved alterations. Safe for Operations: refers to the physical condition of the aircraft relative to its wear and deterioration. As you can see they are not interchangeable conditions when describing an aircraft. Per Part 91.7 a manned aircraft must meet both
criteria prior to fl ight. Per Part 107.15 an sUAS must meet only a condition of Safe Operation. This is because as I said earlier, by defi nition an sUAS is not an airworthy aircraft out of the box! Why? Simply put — there is no FAA certifi cation oversight of the manufacturers or the sUAS vehicles they produce. The OEM’s quality standards are assumed but unknown. There are no mandatory published operational or calendar life limits on the sUAS components. And thus, per 14CFR Part107 total responsibility for an operationally safe sUAS lands squarely upon the discretion and experience of the sUAS Remote PIC. In short the 2,000,000 plus sUAS aircraft fl ying are therefore not by defi nition “Airworthy.” But, are they safe for fl ight? That is determined by the sUAS pilot. So how come FAA has no regulatory oversight of
the sUAS OEM and their products. It appears that along with an open-handed confi dence in the quality and reliability of the sUAS technology, economics also played a big part. Because should the FAA enforce a TC requirement for this aircraft, it has been posited there would be negative fi nancial ramifi cations to both the sUAS OEM and the consumer. There is also concern that the rigorous methods to complete a TC are also time consuming as well as expensive and would stifl e the progress of this technology to the industry and the marketplace. While I agree the process is time consuming, there is a reason the process for a TC is time consuming — How ‘bout Safety of Product! and with an sUAS population of over 2,000,000 and growing, perhaps a little delay in production would be a good thing right now. Well by now I guess it is obvious that as a certifi ed A&P with 40+ years in rotorcraft maintenance, I am apprehensive about the sUAS manufactures’ quality control system and the dearth of FAA oversight. I am taken aback that a recently certifi ed sUAS pilot, perhaps new to aviation and ignorant to the fl ight induced stresses on the sUAS, is the fi nal authority on the safe
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HelicopterMaintenanceMagazine.com February | March 2020
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