manufacturing regulations for the uas industry...oct 19, 2018 · committee f38 on unmanned...

manufacturing regulations for the uas industry

2017

2 | Manufacturing regulations for the UAS industry

Table of ConTenTsList of Tables 3

Abbreviations 4

Executive Summary 5

Intro/Background 6

Research Method 6

Assumptions, Limitations, Scope and Delimitations 7

Findings 8

1. Spectrum usage, radios, batteries, materials, etc. 8

Radio Frequency 8

FAA Spectrum Guidance and Authorization 8

2. Military standards 9

Communication and Interface Standards 9

Airworthiness Requirement 10

3. Application of standards 11

ASTM International 11

Committee F38 on Unmanned Aircraft Systems 13

Radio Technical Commission for Aeronautics (RTCA) 14

4. Manned aircraft regulations and UAS correlation 15

5. Application of existing airworthiness standards 16

Unmanned Airworthiness Standards 16

Advisory and Rulemaking Committees (ARC) 16

6. Regulations on manufacture, installation, and use of sub-systems 18

7. Applicability of FAA’s COE for UAS, ASSURE, SAE, ARC, etc. 19

FAA Center of Excellence for UAS Research (ASSURE) 19

Society of Automotive Engineers (SAE) 20

Advisory and Rulemaking Committees (ARC) 21

8. Federal Aviation Regulations (FAR) guidance 22

Suggestions and Recommendations 24

This study was prepared under contract with the Wright State Applied

Research Corporation, Ohio, with financial support from the Office of

Economic Adjustment, Department of Defense and content reflects the

views of the authors and does not necessarily reflect the views of the

Office of Economic Adjustment.

Sinclair College | 3

Abbreviations

ARC Advisory and Rulemaking Committees

AFM Aircraft Flight Manual

API Application Programming Interfaces

ASSURE FAA Center of Excellence for UAS Research

ASTM American Society for Testing and Materials

BLOS Beyond Line-of-Sight

BVLOS Beyond Visual Line of Sight

C2 Command and Control

CA Civil Aviation Authority

CMCC Common Mission Control Center

CNPC Command and Non-Payload Communication

COTS Commercial off-the-shelf

Cseg Control Segment

Cseg Control Station

DAA Direct Access Arrangement

DoD Department of Defense

EMI Electromagnetic Interference

ER Essential Requirements

ETSI European Telecommunications Standards Institute

FA Function Allocation

FAA Federal Aviation Administration

FACE Future Airborne Capability Environment

FAR Federal Aviation Regulations

FCC Federal Communication Commission

List of Tables

Table 1: Communication and Interface Standards 9

Table 2: NATO Airworthiness Standards 10

Table 3: ASTM Standards 11

Table 4: ISO Standards 13

Table 5: RTCA Standards 14

Table 6: FAA Airworthiness Order 16

Table 7: NATO Airworthiness Requirements 17

Table 8: EMI Regulatory Bodies 18

Table 9: ASSURE Team Projects 19

Table 10: SAE Standards 20

Table 11: FAA Rulemaking Committees 21

Table 12: Potential Applicable 14 CFR Part Numbers 23


GA General Aviation

GAA Governing Aviation Authority

HMI Human Machine Interface

ICAO International Civil Aviation Organization

IEC International Electrotechnical Commission

IFR Instrument Flight Rules

ISM Industrial, scientific and medical

ISO International Organization for Standardization

ISR including Intelligence, Surveillance, and Reconnaissance

ITU International Telecommunications Union

JUAS Joint Architecture for Unmanned Systems

LOC Loss of Control

LOS Line-of-Sight

MOPS Minimum Operational Performance Standards

MTOW Maximum Take Off Weight

NAS National Airspace

NATO North Atlantic Treaty Organization

OFRSO Operational and Functional Requirements and Safety Objectives

OMS Open Mission Systems

OPA Optionally piloted aircraft

OSED Operational Services and Environmental Definition

PIC Pilot in Command

RC Radio Controlled

RTCA Radio Technical Commission for Aeronautics

SAE Society of Automotive Engineers

SATCOM Satellite Communications

SOA Service Oriented Architecture

STANAG Standardization Agreement

sUAS Small Unmanned Aircraft System

UA Unmanned Aircraft

UAS Unmanned Aerial Systems

UAV Unmanned Aerial Vehicle

UCI Unmanned Aerospace Systems C2 Standards Initiative

UCS Unmanned Control System

USAR UAV Systems Airworthiness Requirements

USAR-LIGHT Light Unmanned Aircraft Systems Airworthiness Requirements

VFR Visual Flight Rules

VO Visual Observer


executive summary

Currently, globally accepted regulations do not exist which specifically address the manufacturing

of Unmanned Aerial Systems (UAS). As the industry grows and advances the sector will require

regulations closer to those of manned aviation. In the absence of accepted standards and regulation,

organizations are preparing by adopting specifications from adjacent markets. It was the goal of this

study to identify regulations that do exist in these specific areas and communicate how they might

influence or affect the manufacturing of UASs.

An analysis of eight major questions related to existing standards in UAS was compared to manned

systems to determine if there were any areas where manned practices or military practices can be

leveraged to develop commercial standards for UAS.

The study showed that there are new regulations and standards in development. Much of the effort

has been software interoperability and communications. Many of the standards for UAS design,

manufacturing, and airworthiness are limited in detail partially due to the vastness in size differences

of the platforms. In the absence of an accepted universal standard, large platforms or those that

require runway support and are closest to traditional General Aviation (GA) aircraft will follow the

Federal Aviation Regulations (FAR) for GA aircraft whereas smaller UAS under 55 lbs. will follow the 14

CFR Part 107 for Small UAS (sUAS). This still leaves a gap in the moderate size UAS which will begin

to gain traction in the Beyond Line-of-Sight (BLOS) environment. Additionally, there are some new

regulations set forth by the likes of the International Organization for Standardization (ISO) International

and American Society for Testing and Materials (ASTM) International. These regulations are in the

early stages of development or recently published in nature and offer guidelines (but not detailed

specifications) to manufacturing organizations.

The biggest challenge is that conducting studies and providing standards and recommendations is a

business. Therefore, many organizations will develop standards and regulations in hopes that they will

be adopted and used in official regulations.

It is the researcher’s recommendation that the industry creates commercial classes of UAS that define

which regulations each aircraft must adhere, required certifications, and airworthiness standards to

meet. After adoption of those criteria then regulations and specifications will be matured over time.

In the meantime, manufacturers should remain aware of the various efforts to develop standards and

design, build, and support their vehicles in a way that they can adhere to the new standards as they

are enacted.


Intro/Background

Since the early 1900’s individuals and organizations have manufactured unmanned systems. Most

of the guidelines were based on manned aviation or practices in radio controlled (RC) model aircraft.

With the growth of unmanned systems and more importantly the difference in the size of unmanned

systems platforms, individuals and organizations are seeking guidance on the regulations that should

guide the UAS industry as it moves forward.

The challenge is that regulations do not exist that specifically address the manufacturing of UAS.

As the industry grows and advances the industry will require regulations closer to those of manned

aviation. In the absence of regulation, it is probably that organizations are preparing for these events

by adopting specifications from adjacent markets. It is the goal of this study to identify regulations

that exist in these specific areas and communicate how those regulations might influence or affect the

manufacturing of UASs.

Research Method

The research was conducted through a literature review of online sources and documents. The

researchers began with a list of questions on main topics and did a preliminary search in each area of

interest.

The team conducted an analysis that answers the following questions:

1. Federal Communication Commission (FCC) and Federal Aviation Administration (FAA) guidance on spectrum usage (frequencies used), radios, batteries, materials, etc. that could affect UAS manufacturing processes or components selection

2. Military standards that may exist and be applicable to civil UAS or component manufacturing

3. Possible application of standards like ISO to civil UAS or component manufacturing

4. Possible correlation between manned aircraft regulations and UAS applicable to civil UAS or component manufacturing

5. Possible application of existing airworthiness standards for manned or unmanned aircraft for civil UAS or component manufacturing

6. Applicable regulations regarding manufacture, installation, and use of sub-systems including but not limited to sensors, avionics, and motors and special considerations including EMI

7. Review of potential applicability of standing committee work (FAA’s COE for UAS, ASSURE, SAE, ARC, etc.) with attention to how it may inform UAS manufacturing or component manufacturing standards

8. FAR guidance that may inform UAS manufacturing or component manufacturing standards

The researchers then analyzed each question to determine the scope of the topic. During the analysis,

the researchers had the opportunity to observe new UAS project review and interview individuals with

recent development experience in several of the research areas. These meeting and observations

provided insight into areas that were of interest to large and small UAS. The researchers then created

a chart of each area of the UAS and aligned standards to each of the areas of interest. The team

prepared a summary of the areas.


assumptions, limitations, scope and Delimitations

The limitations for this project are due largely to the limited number of UAS manufacturing standards

which have been formally adopted and that no one group has emerged as the de facto standard for the

industry.

The limitations for the study are that there are currently several efforts in development in varying

stages of completeness. These documents may or may not have been released in draft form and

during the course of research may have changed significantly. Some of the standards identified

were just a number and title with an anticipated date for an upcoming meeting. Additionally, due to

many of the standards being protected by copyright and against release without compensation to

the standards organizations, the following document utilizes only titles, abstracts, and public reviews

of the documents and standards. This report should be used as a guide in the understanding of

what standards and regulations are being developed or have been accepted by regulating bodies.

Manufacturers and organizations, if interested, should purchase and review the documents in greater

detail prior to utilizing standards. A footnote of each standard with the organization and standard

number has been provided.

In scope and delimitations, the goal of the study is to identify regulations that exist in these specific

areas and communicate how those regulations might influence or affect the manufacturing of UASs.

The study was focused around eight main questions. These eight questions were researched with the

delimitations that the researchers would investigate the core subject area and in the findings, describe

areas for further investigation.

The author utilized footnotes vs. references so that the reader would have ready access to the

sources while reading the document. Due to the nature of the report, very little of the document is the

authors opinion with the majority coming from the footnoted sources. A footnote at the beginning of a

section indicates that the section information is from the footnoted source. A footnote at the end of a

paragraph indicates that the previous paragraph is from the footnoted source. The summary at the end

of each section is the author’s opinion of the findings.


1 U.S. Dept. of Transportation Federal Aviation Administration Advisory Circular 107-2 Small Unmanned Aircraft Systems (sUAS) dated 6/21/16 page B-3 section B.6.

findings

Federal Communication Commission (FCC) and Federal Aviation Administration (FAA) guidance on spectrum usage (frequencies used), radios, batteries, materials, etc. that could affect UAS manufacturing processes or components selection

Radio Frequency

Commercial UAS primarily utilize Line-of-Sight (LOS). Beyond Line of Sight (BLOS) is the operation of a

UAS utilizing satellite communications. Frequency spectrums both for LOS and BLOS are regulated by

the FCC.

FAA Spectrum Guidance and Authorization

The FAA provides the following guidance on sUAS Frequency Utilization in Federal Aviation

Administration Advisory Circular 107-2. Section B.6 states that “some operating frequencies are

unlicensed and can be used freely (e.g., 900 MHz, 2.4 GHz, and 5.8 GHz) without FCC approval.

All other frequencies require a user-specific license for all civil users, except federal agencies, to be

obtained from the FCC.”1

Summary

In general, the assigned spectrum for communications and data transmission has been established.

The biggest changes are in the use of unregulated frequencies for commercial sUAS as more and

more users are operating on these frequencies. Component manufacturers should adhere to the FCC

guidance on spectrum use. To reduce any delays in development it is recommended that new vehicle

manufacturers should utilize existing approved hardware from suppliers to ensure that their platforms

adhere to FCC and FAA standards.


Military standards that may exist and be applicable to civil UAS or component manufacturing

Communication and Interface Standards

There are currently multiple efforts relating to UAS communication and interface standards. The

following is a list of those efforts:

Initiative Goal Ownership Additional Notes

Unmanned Aerospace

Systems C2 Standards

Initiative (UCI)2

Establish a set of messages for

machine-to-machine, mission-level

command and control for airborne

systems

US Air Force3 Not Applicable

Open Mission Systems

(OMS)

Non-proprietary mission system

architectural standard4

Not Applicable Based on UCI framework

Joint Architecture for

Unmanned Systems

(JAUS)

International standard that defines

communication protocols for

unmanned vehicle systems

Society of

Automotive

Engineers (SAE)

AS-4 committee5

The standard defines

message formatting for

transport between system

services6

Future Airborne Capability

Environment (FACE)7

Software standard for the

interoperability of systems through

a common message language and

structure.

Department of

Defense

Not Applicable

NATO Standard Agreement

4586, Standard Interfaces

of UAV Control System for

NATO UAV Interoperability

NATO Standard Interface of the

Unmanned Control System (UCS)

Unmanned Aerial Vehicle (UAV)

interoperability

NATO Defines architectures,

interfaces, communication

protocols, data elements

and message formats

2 Unmanned Aerospace Systems C2 Standards Initiative (UCI) http://ucistandard.org/about-uci.html

3 Unmanned Aerospace Systems C2 Standards Initiative (UCI) http://ucistandard.org/about-uci.html

4 Open Mission Systems (OMS) http://ucistandard.org/oms.html

5 Department of Defense Emerging Needs for Standardization. SAE International 2016 Aerospace Standards Summit dated 09/21/2016.

6 OpenJuas, LLC http://openjaus.com/

7 Future Airborne Capability Environment http://www.opengroup.org/face

Table 1: Communication and Interface Standards


Airworthiness Requirement

A NATO Working Group has developed a set of requirements through the UAV Systems Airworthiness

Requirements (USAR)8.

Summary

There are multiple requirements from the military that may be applicable to civilian UAS. The challenge

is that in many areas there are multiple documents each being developed by closely related agencies.

This is especially true in communications and software where there are multiple requirements and

protocols in development. Each of the documents has their place in the industry but all cannot be the

de facto standard for use. Manufacturers will need to be aware of the new standards as they appear in

the future.

Standard Title DescriptionReferenced Standards

STANAG 4671 Unmanned Aerial Vehicles

Airworthiness Requirements

(USAR)9

Technical airworthiness requirements

for fixed wing UAS with a Maximum

Take Off Weight (MTOW) of greater

than 150 kg and less than 20.000 kg

Comparable with

specifications 14 CFR

1 Part 23 and EASA2

CS-23.

STANAG 4703 Light Unmanned Aircraft

Systems Airworthiness

Requirements (USAR-

LIGHT)10

Minimum set of technical

airworthiness requirements for fixed-

wing Light UAS with a maximum take-

off weight not greater than 150 kg.

Not Applicable

8 NATO sets standards for Unmanned Aerial Vehicles, 26 Sept 2007, http://www.nato.int/docu/update/2007/09-september/e0926b.html

9 NATO Standardization Agency: STANAG 4671, Edition 1: Unmanned Aerial Vehicles Airworthiness Requirements (USAR), 03.09.2009

10 NATO Standardization Agency: STANAG 4703 AEP-83: Light Unmanned Aircraft Systems Airworthiness Requirements (USAR-LIGHT), Final Draft, 04. September 2014

Table 2: NATO Airworthiness Standards


Possible application of standards like ISO to civil UAS or component manufacturing

ASTM International

ASTM International is an international standards organization that develops and publishes technical

standards. ASTM International has no role in requiring or enforcing compliance with its standards. The

standards, however, may become mandatory when referenced by an external contract, corporation, or

government.11

Committee F38 on Unmanned Aircraft Systems

ASTM created Committee F38 on Unmanned Aircraft Systems. This Committee addresses issues

related to design, performance, quality acceptance tests, and safety monitoring for unmanned air

vehicle systems.12

Committee F38 has issued the following standards that can be found in the ASTM Book of Standards

Volume 15.11 that relate to UAS manufacturing:

11 ASTM International https://www.astm.org/ABOUT/full_overview.html

12 ASTM Committee F38 on Unmanned Aircraft Systems https://www.astm.org/COMMITTEE/F38.htm

13 ASTM F2585 - 08 Standard Specification for Design and Performance of Pneumatic-Hydraulic Unmanned Aircraft System (UAS) Launch System https://www.astm.org/Standards/F2585.htm

14 MIL-STD-882E DEPARTMENT OF DEFENSE STANDARD PRACTICE SYSTEM SAFETY, 11 May 2012

15 ASTM F2851-10, Standard Practice for UAS Registration and Marking (Excluding Small Unmanned Aircraft Systems), ASTM International, West Conshohocken, PA, 2010, www.astm.org

16 14 CFR 47 Aircraft registration http://www.ecfr.gov/cgi-bin/text-idx?node=pt14.1.47

17 International Civil Aviation Organization (ICAO), 999 University Street, Montreal, Quebec H3C5H7, Canada, http://www.icao.int/index.html.

18 ASTM F2908-16, Standard Specification for Aircraft Flight Manual (AFM) for a Small Unmanned Aircraft System (sUAS), ASTM International, West Conshohocken, PA, 2016, www.astm.org

Standard Title Description Referenced Standards

ASTM F2585 - 08 Standard Specification for

Design and Performance

of Pneumatic-Hydraulic

Unmanned Aircraft System

(UAS) Launch System13

Design and performance

requirements for UAS launch

systems operating via a closed-

loop pressurized hydraulic,

or pneumatic system with a

hydraulic recovery, or both.

MIL-STD-882 Standard

Practice for System

Safety14

ASTM F2851 - 10 Standard Practice for

UAS Registration and

Marking (Excluding

Small Unmanned Aircraft

Systems)15

Marking of aircraft in accordance

with Annex 7 in the Convention

on International Civil Aviation.

14 CFR 47 Aircraft

registration16 and Annex

7 to the Convention

on International Civil

Aircraft Nationality and

Registration Marks.17

ASTM F2908-16 Specification for Aircraft

Flight Manual (AFM) for a

sUAS18

The minimum requirements

for an AFM for UAS designed,

manufactured, and operated in

the sUAS category as defined by

a Civil Aviation Authority (CAA).

Not Applicable

Table 3: ASTM Standards

Continued on next page ...


19 ASTM F2909-14, Standard Practice for Maintenance and Continued Airworthiness of Small Unmanned Aircraft Systems (sUAS), ASTM International, West Conshohocken, PA, 2014, www.astm.org

20 ASTM F2910-14, Standard Specification for Design and Construction of a Small Unmanned Aircraft System (sUAS), ASTM International, West Conshohocken, PA, 2014, www.astm.org

21 ASTM F2911-14e1, Standard Practice for Production Acceptance of Small Unmanned Aircraft System (sUAS), ASTM International, West Conshohocken, PA, 2014, www.astm.org

22 ASTM F3002-14a, Standard Specification for Design of the Command and Control System for Small Unmanned Aircraft Systems (sUAS), ASTM International, West Conshohocken, PA, 2014, www.astm.org

23 ASTM F3003-14, Standard Specification for Quality Assurance of a Small Unmanned Aircraft System (sUAS), ASTM International, West Conshohocken, PA, 2014, www.astm.org

24 ASTM F3005-14a, Standard Specification for Batteries for Use in Small Unmanned Aircraft Systems (sUAS), ASTM International, West Conshohocken, PA, 2014, www.astm.org

25 ANSI/ASQ Z1.4-2008 Sampling Procedures and Tables for Inspection by Attributes, American Society for Quality (ASQ), 600 N. Plankinton Ave., Milwaukee, WI 53203, http://www.asq.org

26 UL 1642 Standard for Lithium Batteries Applicable only to on cell suppliers, Underwriters Laboratories (UL), 2600 N.W. Lake Rd., Camas, WA 98607-8542, http://www.ul.com

27 ASTM F3201-16, Standard Practice for Ensuring Dependability of Software Used in Unmanned Aircraft Systems (UAS), ASTM International, West Conshohocken, PA, 2016, www.astm.org


ASTM F2909-14 Practice for Maintenance

and Continued

Airworthiness of sUAS19

Standard practice for the

maintenance and continued

airworthiness of sUAS.

Not Applicable

ASTM F2910-14 Standard Specification for

Design and Construction

of a sUAS20

Design, construction, and

test requirements for a

sUAS.

Not Applicable

ASTM F2911-14e1 Practice for Production

Acceptance of a sUAS21

Production acceptance

requirements for a sUAS.

Not Applicable

ASTM F3002-14a Specification for Design of

the Command and Control

System for sUAS22

Consensus standard in

support of an application to

a nation’s GAA for a permit

to operate a sUAS for

commercial or public use

purposes.

Not Applicable

ASTM F3003-14 Specification for Quality

Assurance of a sUAS23

Quality assurance

requirements for the

design, manufacture, and

production of a sUAS.

Not Applicable

ASTM F3005-14a Specification for Batteries

for Use in sUAS24

Requirements for batteries

used in sUAS.

ANSI/ASQ Z1.4-2008 Sampling

Procedures and Tables for

Inspection by Attributes25 and

UL 1642 Standard for Lithium

Batteries Applicable only to on

cell suppliers26.

ASTM F3201 - 16 Standard Practice for

Ensuring Dependability of

Software Used in UAS27

Ensure the dependability of

UAS software

ISO 9001 Quality Management

Systems Requirements, ICAO

9859 Safety Management Manual

and RTCA Standards RTCA

DO-178C and RTCA DO-326

Airworthiness Security Process

Specification.

Table 3: ASTM Standards Continued


International Organization for Standardization (ISO)

The subcommittee ISO/TC 20/SC 16 Unmanned aircraft systems28 charter is to develop standards

for nearly all aspects of UAS from design and development to material and manufacturing.29 The

subcommittee is currently developing the following standards:

28 How standards will target the drone industry, Elizabeth Gasiorowski-Denis, 27 March 2015 http://www.iso.org/iso/news.htm?refid=Ref1946

29 ISO/TC 20/SC 16 - Unmanned aircraft systems http://www.iso.org/iso/iso_technical_committee?commid=5336224

30 ASTM F2585 - 08 Standard Specification for Design and Performance of Pneumatic-Hydraulic Unmanned Aircraft System (UAS) Launch System https://www.astm.org/Standards/F2585.htm

31 ISO/TC 20/SC 16 - Unmanned Aircraft systems Standards Catalogue


ISO/AWI 21384-1

Unmanned aircraft systems

Part 1: General specification

System (UAS) Launch

System30

Not Available Not Applicable

ISO/AWI 21384-2


Part 2: Product systems Not Available Not Applicable

ISO/AWI 21384-3


Part 3: Operational procedures Not Available Not Applicable

ISO/AWI 21895 Categorization and

classification of civil

unmanned aircraft systems31

Not Available Not Applicable

Table 4: ISO Standards


32 DO-362 Command and Control (C2) Data Link Minimum Operational Performance Standards (MOPS) (Terrestrial) http://www.rtca.org/

33 DO-344 Volume 1 & 2 - Operational and Functional Requirements and Safety Objectives for Unmanned Aircraft System Standardshttp://www.rtca.org/

34 DO-320 Operational Services and Environmental Definition (OSED) for Unmanned Aircraft Systems, http://www.rtca.org/

35 DO-160G Environmental Conditions and Test Procedures for Airborne Equipment http://www.rtca.org/

Radio Technical Commission for Aeronautics (RTCA)

The FAA chartered the Radio Technical Commission for Aeronautics (RTCA) to provide technical

guidance and generates minimum performance standards in aviation. The RTCA creates special

committees to develop standards for various disciplines. RTCA Special Committee 228 on unmanned

aircraft systems has released the following standards:


DO-36232 C2 Data Link MOPS

(Terrestrial)

Provides performance requirements

for a safety-of-flight CNPC function

that enables an UAS pilot to safely

maneuver the aircraft from the ground.

Not Applicable

DO-34433 Operational and Functional

Requirements and Safety

Objectives (OFRSO) UAS

Standards

OFRSO addresses: Daytime and night

operations in all phases of flight.

Not Applicable

DO-32034 Operational Services and

Environmental Definition

(OSED) for UAS

Basis for assessing and establishing

operational, safety, performance, and

interoperability requirements for UAS

operations in the NAS.

Not Applicable

DO-160G35 Environmental Conditions

and Test Procedures for

Airborne Equipment

Standard procedures and environmental

test criteria for testing airborne electrical

and electronic equipment.

Not Applicable

Table 5: RTCA Standards

Summary

The development of standards is a business and therefore those industries that profit from the

development of standards are creating standards and regulations. The FAA utilizes RTCA and ASTM to

generate standards. ISO is an internationally recognized standards body for manufacturing. The FAA

specifically charters the RTCA and accepts ASTM standards. ISO standards are accepted standards

for quality by the FAA as well. The RTCA and ASTM standards are well developed thought some of

the standards due to the age of the industry may be broad in nature since they cover a large range of

platform sizes. The standards are good staring points but it is the author’s opinion that they will evolve

with time and lessons learned from the industry. Manufacturers need to be aware of the developing

standards to influence or adopt them as they are enacted.


Possible correlation between manned aircraft regulations and UAS applicable to civil UAS or component manufacturing

As stated earlier, there are numerous correlations between manned aircraft regulations and UAS

applicable to civil UAS or component manufacturing. Each question in this document refers to a

manned regulation being directly adopted or tailored to use in UAS. The challenge is that classes of

UAS are still not standardized between organizations, nations, and emerging standards. As the size

standards mature into additional groups and categories such as runway dependent, BLOS, etc. there

will be more direct correlations between manned and unmanned.

The most direct correlations are in 14 CFR. This analysis was conducted under question 8: FAR

guidance that may inform UAS manufacturing or component manufacturing standards.

Summary

All manufacturers of UAS large or small should be familiar with the 14 CFR because it is the basis for

operation of aircraft. These documents will most likely be the baseline or at very least the inspiration

for all future UAS documents. Manufacturers should anticipate regulations in the spirit of the 14 CFR

though the industry and governing bodies yet understand UAS and manned aviation are very different.

It is the author’s opinion that future regulations will be different from manned but in the same spirit.


Possible application of existing airworthiness standards for manned or unmanned aircraft for civil UAS or component manufacturing.

Unmanned Airworthiness Standards

Advisory and Rulemaking Committees (ARC) Unmanned Aircraft Systems

The FAA formed a UAS ARC to provide guidance on the creation of UAS requirements. The FAA has

the follow regulation efforts in UAS.

The above order is an existing regulation that until enactment of the 14 CFR Part 10737 was the only

regulation for a commercial organization to legally operate a UAS. With enacting of the 14 CFR Part

107, FAA order 8130.34C has limited applicability to sUAS. As stated earlier, A NATO Working Group

has developed UAV Systems Airworthiness Requirements (USAR).

36 8130.34C - Airworthiness Certification of Unmanned Aircraft Systems and Optionally Piloted Aircraft

37 14 CFR PART 107—SMALL UNMANNED AIRCRAFT SYSTEMS

Order Title Description Referenced Standards

8130.34C36 Airworthiness Certification

of Unmanned Aircraft

Systems and Optionally

Piloted Aircraft

Procedures for issuing either special

airworthiness certificates in the

experimental category or special flight

permits to UAS, optionally piloted

aircraft (OPA), and aircraft intended to

be flown as either a UAS or an OPA.

Not Applicable

Table 6: FAA Airworthiness Order


38 NATO Standardization Agency: STANAG 4671, Edition 1: Unmanned Aerial Vehicles Airworthiness Requirements (USAR), 03.09.2009

39 NATO Standardization Agency: STANAG 4703 AEP-83: Light Unmanned Aircraft Systems Airworthiness Requirements (USAR-LIGHT), Final Draft, 04. September 2014

Summary

There are numerous crossovers between manned and unmanned airworthiness requirements.

Currently there are only a few airworthiness documents specific to UAS. The author reviewed the

detail and specifications of the requirements in STANAG 4671 and 4703. Like in previous sections,

all manufacturers of UAS large or small should be familiar with the 14 CFR because it is the basis

for operation of aircraft. These documents will be the baseline for all future UAS documents.

Manufacturers should anticipate regulations in the spirit of the 14 CFR though the industry and

governing bodies understand UAS and manned aviation are very different. It is the author’s opinion that

future regulations will be different from manned but in the same spirit.

Requirements Title Description Referenced Standards

STANAG 467138 Unmanned Aerial

Vehicles Airworthiness

Requirements (USAR)

Technical airworthiness requirements

for fixed wing UAS with a Maximum

Take Off Weight (MTOW) of greater

than 150 kg and less than 20.000 kg

Closely comparable with

specifications 14 CFR 1

Part 23 and EASA2 CS-23.

STANAG 470339 Light Unmanned Aircraft

Systems Airworthiness

Requirements (USAR-

LIGHT)

Minimum set of technical

airworthiness requirements for fixed-

wing Light UAS with a maximum take-

off weight not greater than 150 kg.

Not Applicable

Table 7: NATO Airworthiness Requirements


Applicable regulations regarding manufacture, installation, and use of sub-systems including but not limited to sensors, avionics, and motors and special considerations including Electromagnetic Interference (EMI)

The EMI standards define the frequency range and limit unwanted radiation from electronics. There

are numerous regional, national, international, and industrial standards. The standards depend on the

product and the country in which the product is to be used. The following are the main standards and

(standards making bodies in the author’s opinion that are most applicable to UAS electronics). EMI

standards are a well-defined and broad area with many areas of interest. Manufacturers in this area

or groups concerned with EMI should undertake their own efforts in compliance as a first step in the

conceptual phase of development.

Summary

EMI standards are well documented for use in manned aviation. There are currently no standards

specific to unmanned systems and the author does not anticipate many changes. The FAA and

FCC, as well as the international organizations, have issued standards for airborne equipment. It is

anticipated by the author that these standards shall remain and that manufacturers should use the

currently accepted documents as the standards for manufacturing.

40 International Electrotechnical Commission (IEC) http://www.iec.ch/41 European Telecommunications Standards Institute (ETSI) http://www.etsi.org/42 FCC Rules and Regulations, Title 47, Part 15, Subpart B https://www.fcc.gov/general/rules-regulations-title-4743 MIL-STD-461G REQUIREMENTS FOR THE CONTROL OF ELECTROMAGNETIC INTERFERENCE CHARACTERISTICS

OF SUBSYSTEMS AND EQUIPMENT, 11 December 201544 DO-160G Environmental Conditions and Test Procedures for Airborne Equipment http://www.rtca.org/

Rulemaking Body Regulations and Responsibilities

International Electrotechnical Commission (IEC)40 CISPR 22

European Telecommunications Standards Institute (ETSI)41 Standards for Europe.

Federal Communications Commission (FCC) Title 47, Part 15, Subpart B42

Department of Defense (DoD) MIL-STD 461G43

RTCA/DO-160G Environmental Conditions and Test Procedures for Airborne

Equipment,” RTCA, Incorporated, December 16, 201444.

Table 8: EMI Regulatory Bodies


Review of potential applicability of standing committee work (FAA’s COE for UAS, ASSURE, SAE, ARC, etc.) with attention to how it may inform UAS manufacturing or component manufacturing standards

FAA Center of Excellence for UAS Research (ASSURE)45

The ASSURE team currently has the following efforts in progress. No standards have been

provided to date.

45 Bass, Ellen, J. Academic research within the FAA Center of Excellence: Assisting the FAA in the UAS rulemaking process. ASSURE COE, www.ASSUREuas.org

Project Description

A1-Certification Test Case to Validate sUAS

Industry Consensus Standards

Validation of the ASTM F38 standards, and expand to include issues

relating to flight test.

A2-Small UAS Detect and Avoid

Requirements Necessary for Limited

Beyond Visual Line of Sight (BVLOS)

Operations

Define an operational framework and conduct a comparison of approaches

that support development of Standards for sUAS DAA systems and

development of proposed operating rules, limitations, and guidelines for

sUAS BVLOS operations.

A3-UAS Airborne Collision

Severity Evaluation

Investigate system safety thresholds for key UAS characteristics for

identifying UAS as acceptably safe in credible encounter scenarios.

A4-UAS Ground Collision

Severity Evaluation

Determine hazard severity thresholds for UAS using safety characteristic

factors that affect the potential severity of UAS in collisions with people and

other aircraft on the ground or aircraft in the air.

A5-UAS Maintenance, Modification, Repair,

Inspection, Training, and Certification

Considerations

Develop standards for UAS maintenance, modification, repair, inspection,

and technician training, and to identify requirements for approved

certification standards for air vehicle and system maintenance providers

and maintenance technicians.

A6-Surveillance Criticality for Sense

and Avoid (SAA)

Determine the sufficiency of existing airborne surveillance equipment for

manned aircraft (e.g. transponders and/or ADS-B) for providing separation

provision and collision avoidance functions for UAS.

A7-UAS Human Factors Control

Station Design Standards

Address human factors safety concerns that are unique to UAS to support

development of standards, regulations, and guidance for civil UAS.

A8-Unmanned Aircraft Systems (UAS)

Noise Certification

Establish guidelines relating to UAS source noise to inform the noise

certification process.

Table 9: ASSURE Team Projects


Society of Automotive Engineers (SAE)

The JUAS working group transferred multiple standards to the SAE. SAE has created additional

standards. The table below is a list of the JUAS standards published by SAE.

Standard Title Description

SAE AS604046 JAUS Human Machine Interface

(HMI) Service Set

Defines a set of standard application layer interfaces called

JAUS HMI Services

SAE AIR5664A 47 JAUS History and Domain Model Capture for posterity the domain analysis that provides the

underpinnings for the work by the AS-4 Committee (Unmanned

Systems)

SAE AS5710A48 (R) JAUS Core Service Set Defines a set of standard application layer interfaces called

JAUS Core Services

SAE AS6060 JAUS Environment Sensing

Service Set

defines a set of standard application layer interfaces called

JAUS Environment Sensing Services

SAE AS6057 JAUS Manipulator Service Set50 defines a set of standard application layer interfaces called

JAUS Manipulator Service

SAE AS6062 JAUS Mission Spooling

Service Set51

defines a set of standard application layer interfaces called

JAUS Mission Spooling Services

SAE AS5684A (R) JAUS Service Interface

Definition Language52

Defines “a framework to identify interface classes for applying

open systems to the design of a specific hardware/software

system.”

SAE AS6009 JAUS Mobility Service Set53 Defines a set of standard application layer interfaces called

JAUS Mobility Services

SAE AIR5645 JAUS Transport Considerations54 Discusses characteristics of data communications for the Joint

Architecture for Unmanned Systems (JAUS)

SAE ARP6012 JAUS Compliance and

Interoperability Policy55

Recommends an approach to documenting the complete

interface of an unmanned system or component regarding the

application of the standard set

SAE AS5669A (R) JAUS / SDP Transport

Specification56

Specifies a data communications layer for the transport of

messages defined by the JAUS or other Software Defined

Protocols (SDP)

Table 10: SAE Standards

46 AS6040 JAUS HMI Service Set http://standards.sae.org/as604047 AIR5664A JAUS History and Domain Model http://standards.sae.org/air5664a/48 AS5710 JAUS Core Service Set http://standards.sae.org/as571049 AS6060 JAUS Environment Sensing Service Set http://standards.sae.org/as606050 AS6057 JAUS Manipulator Service Set http://standards.sae.org/as605751 AS6062 JAUS Mission Spooling Service Set http://standards.sae.org/as606252 AS5684 JAUS Service Interface Definition Language http://standards.sae.org/as5684a53 AS6009 JAUS Mobility Service Set http://standards.sae.org/as600954 AIR5645 JAUS Transport Considerations http://standards.sae.org/air5645/55 ARP6012 JAUS Compliance and Interoperability Policy http://standards.sae.org/arp6012a/56 AS5669 JAUS / SDP Transport Specification http://standards.sae.org/as5669a


Advisory and Rulemaking Committees (ARC) for Unmanned Aircraft Systems

The FAA has developed the following ARCs for UAS:

Summary

There are numerous standing committees providing guidance and input into standards and regulations.

The FAA has established committees such as the ARC and ASSURE to conduct studies and provide

recommendations. SAE, ISO, RTCA, and ASTM have all established committees to develop standards

for use by government and industry. It is critical that manufacturers be aware of those most directly

relating to their product lines. Awareness of, and engagement with, related committees will provide

advanced notice of possible regulations prior to publishing to industry.

57 SUAS ARC https://www.faa.gov/regulations_policies/rulemaking/committees/documents/media/SUASARC-4102008.pdf58 UAS ARC https://www.faa.gov/regulations_policies/rulemaking/committees/documents/index.cfm/ document/

information/documentID/30859 Performance Standards and Requirements for Micro Unmanned Aircraft Systems (Micro UAS) ARC https://www.faa.gov/

regulations_policies/rulemaking/committees/documents/index.cfm/document/information/documentID/2682

Committee Charter Reports

Small Unmanned Aircraft Systems

(2008)57

Outcome -Recommendations for

small unmanned aircraft systems

integration

Comprehensive Set of

Recommendations for sUAS

Regulatory Development

Unmanned Aircraft Systems ARC (2011) 58 Outcome -Recommendations for

small unmanned aircraft systems

integration

“Integration of Civil Unmanned

Aircraft Systems (UAS) into the

National Airspace System (NAS)”

Performance Standards and

Requirements for Micro Unmanned

Aircraft Systems (Micro UAS) ARC59

Chartered for the development

of recommendations for the flight

over people.

Recommendations for four categories

from Cat 1 to Cat 4 based on impact

thresholds and the danger to those

who could encounter the UAS.

Table 11: FAA Rulemaking Committees


Federal Aviation Regulations (FAR) guidance that may inform UAS manufacturing or component manufacturing standards

As stated earlier, there has been analysis and interpretation on which aviation regulations are

applicable between manned and unmanned. An analysis of 436 items in 2009 of the 14 CFR was

conducted. The analysis found that 30% Clearly Applies to UA operations, while 16% Does not Apply.

The remaining items either May Apply by Interpretation (42%) or Could Apply with Revision (12%)60.

The challenge is that 54% of 14 CFR are up to interpretation and in the past 7 years there have been

major changes in UAS. The authors revisited the analysis and continued the investigation with the

most recent changes in UAS such as Part 48 for the Registration and Marking Requirements for Small

Unmanned Aircraft. This is one example where new 14 CFR parts are being created to deal directly

with UAS.

New regulations will be enacted as the industry matures; it is the author’s opinion that in the future

there will be 14 CFR Parts that will either be revised or will be the foundation for UAS specific

guidelines. For instance, Part 21 which covers certification procedures for products and articles

has several sections that are applicable or could be applicable relating to certifications once type

certificates, production certificates, and airworthiness certificates are created. This section has heavy

future applicability. For larger UAS or optionally manned vehicles these standards currently apply. The

airworthiness part numbers 23, 25, 27, and 29 all may be applicable in the future but most likely will be

used as the foundation of future parts.

Part 33, which focuses on engine standards, has been used as guidance and may be adapted as a

future standard. The same is true with Part 35.

80 DOT/FAA/AR-09/7 Unmanned Aircraft System Regulation Review Air Traffic Organization NextGen & Operations Planning Office of Research and Technology Development Washington, DC 20591


Summary

The current parts of 14 CFR are the basis for operation of aircraft. There have been limited additions

the 14 CFR in unmanned systems but these requirements as stated earlier are the basis for our aviation

industry. Though they do not directly apply, they must be understood by manufacturers because any

new regulations will have heritage from the current regulations. Though they may be very different in

requirements, the spirit of the documents will be similar. Additionally, if the manufacturer is involved

in large UAS the 14 CFR are the closest to any standards available and therefore should be used as

guidance until replaced by future UAS specific regulations.

Table 12: Potential Applicable 14 CFR Part Numbers

The following table highlights 14 CFR part numbers that manufacturers should be aware of when

manufacturing UAS. Though UAS do not fall under these 14 CFR Part Numbers (except for Part 48),

manufacturers should anticipate future CFR’s to follow within the spirit of these regulations. The table

is an updated version of the table initially provided in the 2009 analysis during the Unmanned Aircraft

Systems Regulation Review.61

81 Performance Standards and Requirements for Micro Unmanned Aircraft Systems (Micro UAS) ARC https://www.faa.gov/regulations_policies/rulemaking/committees/documents/index.cfm/document/information/documentID/2682

14 CFR PART NUMBER APPLICABILITY

21 Certification Procedures For Products And Articles May Apply With Revision

23 Airworthiness Standards: Normal, Utility, Acrobatic,

And Commuter Category AirplanesMay Apply Dependent On Application

25 Airworthiness Standards: Transport Category Airplanes May Apply Dependent On Application

26 Continued Airworthiness And Safety Improvements For

Transport Category AirplanesMay Apply Dependent On Application

27 Airworthiness Standards: Normal Category Rotorcraft May Apply Dependent On Application

29 Airworthiness Standards: Transport Category Rotorcraft May Apply Dependent On Application

33 Airworthiness Standards: Aircraft Engines May Apply With Revision

34 Fuel Venting And Exhaust Emission Requirements For

Turbine Engine Powered AirplanesMay Apply By Interpretation

35 Airworthiness Standards: Propellers May Apply By Interpretation

39 Airworthiness Directives Apply

43 Maintenance, Preventive Maintenance, Rebuilding, And Alteration May Apply By Interpretation

48 Registration And Marking Requirements For Small Unmanned Aircraft Apply


suggestions and Recommendations

As stated earlier, current globally accepted

regulations do not exist which specifically

address the manufacturing of UAS. As the

industry grows and advances, the industry

will require UAS detailed and specific UAS

regulations for the different size classes and

types of operations. The goal of the study was

to identify regulations that exist in these specific

areas and communicate how those regulations

might influence or impact the manufacturing of

UAS’s.

The study showed that there are new regulations

and standards in development. Much of the

effort has been software interoperability and

communications. Many of the standards for UAS

design, manufacturing, and airworthiness are

limited in specifics due to the vastness in size

differences of the platforms. It is the author’s

opinion that we will see an evolution in standards

with large platforms or those that require

runway support. Receiving standards closest to

traditional GA aircraft and smaller (UAS under

55 lbs.) will follow the evolving 14 CFR Part 107

for sUAS. There will be a gap in the moderate

size UAS which will begin to gain traction in

industry as BLOS operations evolve and gain

approval. Additionally, with so many regulations

for UAS in the early stages of development or

recently published, we will undoubtedly witness

higher levels of regulations as they move from

committee to standards and become the norm by

government and industry.

Until these many standards and regulations

are formally adopted, users and manufacturers

are at risk of setting up processes that may or

may not adhere to the requirements. This has

been observed by the author in recent years

where companies were positioning themselves

to deliver products in various weight categories

and airworthiness standards that have not been

implemented. These challenges will be reduced

once the governing bodies and industry begin

adopting the base size standards for UAS. Once

classes and sizes are established, manufacturers

will better be able to position themselves for

the future.

In conclusion, it is the author’s recommendations

that the industry creates commercial classes

of UAS that define which regulations each

aircraft must adhere, certifications required,

and airworthiness standards to meet. After

adoption of those criteria then regulations and

specifications will be matured over time. In the

meantime, manufacturers should remain aware

of the various efforts to develop standards and

design, build, and support their vehicles in a way

that they can adhere to the new standards as

they are enacted.

manufacturing regulations for the uas industry...oct 19, 2018 · committee f38 on unmanned...

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