The FAA has taken an important step towards increasing the usefulness of the UAS test sites and expanding the path towards issuance of airworthiness certificates for UASs. On September 17, 2014, the FAA issued Order 8000.372, which sets forth the policy and procedures for the selection, appointment, orientation, training, oversight, suspension, and termination of designated airworthiness representatives (DAR) who will be associated with the UAS test sites. The DARs will be authorized to issue special airworthiness certificates in the experimental category for research and development and crew training at the test sites.
The DAR is not an FAA employee, but is empowered “to determine that the aircraft is in a condition for safe operation and complies with all applicable regulations before issuing an airworthiness certificate.” In order to become a DAR, the applicant has to submit a letter of affiliation with one of the six test sites, must demonstrate experience in “UAS-type activities,” and show that he has knowledge of all relevant regulations, directives, and guidance materials. The DAR applicant also has to submit a letter of recommendation from each company or organization he relies on in his application as support for his experience, as well as three character references. Finally, a DAR applicant must have one or more of the following:
- A current mechanic certificate with A&P ratings and a minimum of 2 years of experience building, modifying, maintaining or conducting repairs on a UAS.
- A minimum of 2 years of experience as a field technical representative or quality assurance inspector employed by a manufacturer who builds unmanned aircraft. This experience must include hands-on aircraft inspections and/or providing technical assistance to the manufacturer on the assembly and testing of their aircraft.
- Experience as an FAA inspector (manufacturing or airworthiness) who has issued at least three special airworthiness certificates for limited, restricted, experimental, or light-sport aircraft, or issued three special flight permits for any purpose.
- Two years of experience as a UAS operator in a civil operation or under public operations.
- Two years of experience as a UAS operator or maintenance technician on a Department of Defense UAS program, or any other Federal Government owned or operated UAS program.
The creation of a process to appoint UAS DARs at the test sites is a welcome step. It will help the test sites to live up to their promise and hopefully further speed UAS integration into the national airspace.
(Originally posted September 19, 2014)