Waiver Watch | Ep 36: Airobotics Durability & Reliability
Welcome to Waiver Watch!
Here is the agenda for this Episode 36:
Weekly Waiver Totals
Airobotics Durability and Reliability Type Certification
Summary of Durability and Reliability Type Certification program
1. | Weekly. Waiver. TOTALS
July 16-23, 2020 saw 13 waivers approved:
12 - Daylight Operations (107.29)
1 - Visual Observer (107.31)
California takes home 3 of the waivers this week including the 107.31 to Airobotics.
2. | 107W-2020-03340
Airobotics - Issac Sela
§ 107.31
This week, Airobotics receives another waiver to 107.31 to conduct operations beyond visual line of sight of the Remote Pilot in Command in support of their Type Certification effort.
Hold on.. Type Certification effort?
Yes - it appears that Airobotics has initiated the FAA’s Durability and Reliability Means of Compliance program. We have seen similar waivers for Matternet but this is the first for Airobotics. It also appears that this is just the beginning for Airobotics as described in Provision #8:
Operations conducted under this waiver must occur in accordance with the test plan for FAA type certification project TC17371LA-R. Operations authorized include operations necessary for sUAS set- up, sUAS preliminary testing, and test Type Certification test plan compliance;
During the Durability and Reliability program - the FAA conducts an initial site visit to see the aircraft in action and learn about the operations. This waiver is only good for 15 days so perhaps this waiver is supporting this activity and some initial flight hours.
This is great news though - Airobotics joins the ranks of Matternet, Flytrex, Zipline, Wing, and many small UAS companies that are pursuing Type Certification to unlock more advanced operations.
3. | FAA Durability and Reliability Means of Compliance
To achieve a § 21.17(b) Type Certification
What is this FAA Durability and Reliability Means of Compliance anyways? It is a new way for small electric unmanned aircraft to achieve a Type Certificate. The program is based on an aircraft make/model demonstrating safe operations compared to the traditional method of arduous design reviews and approvals. We’re going to summarize some of the key elements of the Durability and Reliability program:
A fleet (3 or more) of aircraft must complete a minimum number of flight hours in a test environment with no losses of control. The minimum number of flight hours is determined by the population density of the targeted operations and the human impact severity of the aircraft.
So for example - a drone delivery company would like to conduct operations in a city. A population density source might say that the average population density is 4000 people per square mile. The drone has a parachute that has been tested and reduces the probability of injury to <30% AIS 3. This company would need to complete 1,300 flight hours with no losses of control to demonstrate it is safe to operate in the city.
The aircraft make/model must undergo a series of failure mode tests that stress the system in worst case scenarios to ensure graceful degradation and containment.
For example - the aircraft must demonstrate that it can remain safe in the event of sustained C2 loss, sustained GPS loss, loss of a motor, and more.
The manufacturer must create a set of documentation and configuration management such as an Aircraft Flight Manual and maintenance program.
The manufacturer must also complete the Production Certificate in parallel with the Type Certification effort.
This program is a significant undertaking, but the reward will be worth the effort in unlocking more advanced operations and Part 135 operations (for the delivery companies). FAA has committed to getting the first sUAS through this program by the end of 2020 - stay tuned!
Wrap Up
Thanks for reading this week! Leave us a comment if you have any questions or would like us to write about any specific waivers next time! If you have a waiver and would like to join us on the show to talk about it and other waivers, drop us a note! Until then…
