Designation: F2690 – 08

Standard Guide for

Suggested Procedures for Applying for a Flight Authority
for an Unmanned Aircraft System: Part I and Part II1
This standard is issued under the fixed designation F2690; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.

INTRODUCTION

Civil Aviation Authorities (CAAs) generally require that any person operating an Unmanned
Aircraft System (UAS)2 hold a Flight Authority (FA) issued by the CAA. At this time procedures and
requirements for FAs for UAS are under development. Similarly, development of UAS is in an early
stage, with several hundred types proposed by a multitude of organizations and individuals. In many
cases, proponents of UAS do not enjoy an extensive experience in aviation regulations and are
ill-equipped to interact with the CAAs on important safety issues. Following some discussion of
general issues in Sections 1 and 2, the remainder of this guide is divided into two parts, as discussed
below.

1. Scope Certificate before operating in the National Airspace System

1.1 This document is provided as an introductory guide to
assist developers in interactions with CAAs. Part I provides
guidance for obtaining a FA for experimental and developmen-
tal work, while Part II describes some of the issues to be
addressed when seeking a Type Certificate. Many readers will
not need to read Part II as it relates to a much more rigorous
and structured procedure that is expected to be applied when
the developer wishes to have the UAS used in commercial
operations. The material presented here is primarily based on
existing practices, procedures and regulations of the U.S.
Federal Aviation Administration. Many countries adopt FAA
procedures directly, while others, such as the European authori-
ties, Australia and Canada, work with the FAA to ensure that
regulatory practices are harmonized to the maximum extent
practical. The guidance presented here is anticipatory, since it
is likely that new regulations specific to UAS will be issued in
due course; the contents of this document builds on existing
regulations while looking forward to future changes.3
1.2 The FAA requires that a civil UAS, with the exception
of those that are Public aircraft, must obtain an Experimental
1
This practice is under the jurisdiction of ASTM Committee F38 on Unmanned
Aircraft Systems and is the direct responsibility of Subcommittee F38.01 on
Airworthiness.
Current edition approved Aug. 1, 2008. Published September 2008. DOI:
10.1520/F2690-08.
2
The Federal Aviation Administration has adopted the acronym UAS to
emphasize that the flight component is an aircraft, and it is part of the system. Other
jurisdictions continue to use the term vehicle. In this guide, the term aircraft will be
used, except where referring to an existing document.
3
The most up-to-date official FAA policies and developing procedures are
available from Federal Aviation Administration (FAA), 800 Independence Ave., SW,
Washington, DC 20591, http://www.faa.gov.
(NAS). The procedures for obtaining a civil Certificate of
Airworthiness (CofA) are contained in 14 CFR Part 21 of the
Federal Aviation Regulations (FAR Part 21).4 Civil UAS that
expect substantially routine access to the NAS, operating for
compensation and hire, will need to undergo a full FAR Part 21
Type Certification, followed by the issuance of an FAA
standard CofA. The existing procedures for Type Certification
are discussed in Part II of this Guide. Based on experience with
conventional civil aircraft certifications, the procedures and
requirements associated with the type certification process and
issuance of a standard CofA are demanding, costly and
time-consuming. Since UAS represent a new class of aircraft,
the procedure will no doubt be rigorous.
1.3 Many of the regulations and standards required for full
application of standard airworthiness certification to UAS have
not yet been developed. For an interim period, as the FAA and
others develop and implement a civil UAS regulatory frame-
work, the FAA is allowing individual civil UAS to have limited
access to the NAS when they satisfy requirements for a FAR
Part 21 Experimental Certificate. With an Experimental Cer-
tificate, operational use of the UAS is strictly defined and
substantially limited, and the associated airworthiness require-
ments are less demanding than they would be for full, standard
certification, consistent with the operational limits.
1.4 This is clearly a time of transition for civil UAS
regulation. It is also a time of transition for the communities of
users and manufacturers of civil UAS, many of whom have
relatively little experience in the regulated civil aviation
4
In this document the designation 14 CFR Part XX will be replaced by “FAR
Part XX”.

Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959, United States.

1
 F2690 – 08
domains. This document is meant to provide a bridge for these
UAS practitioners, as the era of regulated commercial UAS
emerges.
1.5 Objectives—The objectives of this recommended prac-
tice document are to:
1.5.1 Present, in a single, manageable document, an over-
view of the aircraft certification procedures that will be adapted
to the needs of UAS as the civil UAS regulatory framework
takes shape. The procedures will be based largely on the
procedures presently applied by the U.S. FAA;
1.5.2 Describe the procedures and requirements, based on
currently available policy information, that govern the issuing
of a FAR Part 21 Experimental Certificate for a UAS; and
1.5.3 Describe, in some detail, the processes that are antici-
pated for achieving Type Certification of a UAS.
1.6 Outline—This document will begin with an overview of
the regulatory structure as it currently is applied, followed by
a discussion of some specific issues that relate to acquiring
approval for operation of a UAS. This discussion includes a
general description of Flight Authorities. This is followed by
Part I, a review of procedures that presently apply to gaining
approval for experimental operation of a UAS; and Part II, the
procedures that may be expected to apply to a Type Certificate
for a UAS. Flight Authorities obtained by following procedures
in Part I may not permit operations for hire and compensation.
Part II is provided for applicants who may wish to obtain full
certification of their system in anticipation of commercial
operations within the airspace under the jurisdiction of the
appropriate CAA. Proponents who may wish to pursue full
Type Certification should first become familiar with the con-
tents of Part I.
2. Referenced Documents
2.1 ASTM Standards:5
F2505 Practice for Application of Federal Aviation Admin-
istration (FAA) Federal Aviation Regulations Part 21 Re-
quirements to Unmanned Aircraft Systems (UAS)
2.2 FAA Standards:3
14 CFR Part 21 Certification Procedures for Products and
Parts
14 CFR Part 91 General Operating and Flight Rules
14 CFR Part 34 Fuel Venting and Exhaust Emission Re-
quirements for Turbine Engine Powered Airplanes
14 CFR Part 36 Noise Standards: Aircraft Type and Airwor-
thiness Certification
5 10
For referenced ASTM standards, visit the ASTM website, www.astm.org, or
contact ASTM Customer Service at service@astm.org. For Annual Book of ASTM
Standards volume information, refer to the standard’s Document Summary page on
the ASTM website.
2
FAA Order 8130.2F Airworthiness Certification of Aircraft
and Related Products
FAA Order 8130.34 Airworthiness Certification of Un-
manned Aircraft Systems
FAA Order 8110.4C Type Certification: Appendix 12
FAA Advisory Circular AC 21-12 Application for a U.S.
Airworthiness Certificate
FAA Advisory Circular AC 21.40 Application Guide for
Obtaining a Supplemental Type Certificate
FAA Advisory Circular AC 23.1309-1C Equipment, Sys-
tems and Installations in Part 23 Airplanes
FAA Interim Operational Approval Guidance 08-
01 Unmanned Aircraft Systems Operations in the U.S.
National Airspace System
FAA AIR-160 Interim Operational Approval Guidance 08-
01 Unmanned Aircraft Systems Operations in the U.S.
National Airspace System
2.3 Canadian Standards:6
Transport Canada Advisory Circular 500-15 Certification
Plans
Transport Canada Civil Aviation Regulation (CAR) Section
602.41
Transport Canada Civil Aviation Staff Instruction The Re-
view and Processing of an Application for a Special Flight
Operations Certificate for the Operation of an Unmanned
Air Vehicle (UAV)
2.4 Other Standards:
ICAO ANNEX 16 Noise Standard7
CAP 722 Unmanned Aircraft System Operations in UK
Airspace - Guidance8
Civil Aviation Safety Regulation (Australia) Part 101 Un-
manned Aircraft and Rocket Operations9
Civil Aviation Safety Authority (Australia) Advisory Circu-
lar AC 21-43(0) Experimental Certificate for Large Un-
manned Aerial Vehicle9
NPA No. 16/05 Policy for Unmanned Aerial Vehicle (UAV)
Certification10
SAE Aerospace Recommended Practice
ARP4761 Guidelines and Methods for Conducting the
Safety Assessment Process on Civil Airborne Systems and
Equipment11
6
Available from Transport Canada Civil Aviation, 330 Rue Sparks Street Ottawa,
Ontario, CANADA, K1A 0N5, www.tc.gc.ca/CivilAviation/menu.htm.
7
Available from ICAO, 990 University Street, Montreal CANADA, H3C 5H7,
www.icao.int/.
8
Available from UK Civil Aviation Authority, http://www.caa.co.uk/.
9
Available from Civil Aviation Safety Authority, CASA Operations HQ, 12-14
the Circuit, Brisbane Airport, Qld, Australia, 4007, www.casa.gov.au/.
Available from European Aviation Safety Agency (EASA), http://
www.easa.europa.eu/ws_prod/index.html.
11
Available from Society of Automotive Engineers (SAE), 400 Commonwealth
Dr., Warrendale, PA 15096-0001, http://www.sae.org.
 F2690 – 08
PART I
3. Background
3.1 At this time, regulatory agencies are developing proce-
dures and requirements for UAS that will assure an acceptable
level of safety consistent with that demonstrated by other
components of the aviation community. Risks to other users of
the airspace and risks to persons on the surface are the targets
of these future regulations. The specific requirements to be
applied are presently undefined, and not all Civil Aviation
Authorities (CAAs) have determined how they will classify
UAS to identify which will be subject to certification, or which
systems will be substantially unregulated. While developing
regulations and requirements, some CAAs are dealing with
certification of civil UAS on a case-by-case basis. Neverthe-
less, certifying authorities, such as the Federal Aviation Ad-
ministration (FAA) or the European Aviation Safety Agency
(EASA), expect organizations applying for certification of a
UAS to demonstrate a reasonable level of understanding of the
general procedures to be followed to achieve certification.
3.2 Some CAAs have developed preliminary procedures for
issuance of very restrictive flight authorities for UAS. The
EASA has decided that it will be responsible for UAs of Gross
Take Off Weight of 150 kg or more, while lighter aircraft are
regulated by individual countries (NPA No. 16/05). For ex-
ample, the UK CAA has established a policy for aircraft of
takeoff weight less than 150 kg (CAP 722 and Haddon and
Whittaker12). In the U.S., the FAA has imposed no weight
limitation for Special Certificates of Airworthiness, Experi-
mental for UAS. Guidance for application for Special Certifi-
cates of Airworthiness for UAS can be found at FAA Orders
8130.2F and 8130.34, and Advisory Circular AC 21-12.3 The
authorization typically restricts the flight to low altitudes, not
near other aircraft, and to daytime operations within visual
range. Other agencies impose similar restrictions. The FAA has
recently clarified its policy regarding UAS operations in the
National Airspace (NAS) through the publication of an impor-
tant policy document. (See FAA AIR-160 Interim Operational
Approval Guidance 08-01).
3.3 Experience has shown that some organizations propos-
ing new UAS products are relative newcomers to the aviation
industry and are unfamiliar with the extensive body of regula-
tory information and the extensive safety related infrastructure
that is relevant to the products for which they seek certification.
In some cases, operators have attempted to modify existing
model aircraft by adding sensors, other payloads and autopi-
lots, without recognizing the regulatory requirements appli-
cable to the proposed operations. The initial development of a
new or modified UAS platform, especially those that are
“small” (e.g., typically less than a few hundred pounds), may
be accomplished by an organization that does not have a large
company infrastructure complete with an extensive cadre of
experienced aeronautical engineers. Nevertheless, the potential
risk associated with operating a UAS demands strict applica-
tion of proven aeronautical technologies and safety assessment
12
Haddon, D. R. and Whittaker, C. J., “UK-Caa Policy for Light UAV Systems,”
UK Civil Aviation Authority, 2004.
3
methods. Even though the proposed design may not be
required to achieve full Type Certification, the certifying
authority can be expected to impose a process that demands
adherence to rigorous safety standards. This Suggested Proce-
dures document aims to provide guidance to proponents of
UAS that have limited experience in dealing with aircraft
certification.
3.4 While this document focuses attention on procedural
issues related to airworthiness certification, operational consid-
erations are equally important. Except for a standard CofA,
flight authorities will only be issued when operational ques-
tions have been addressed. This document will include a
discussion of airworthiness procedural items, based in large
measure on the FAR Part 21 (Certification Procedures for
Products and Parts) and a brief discussion on operational
matters, following the relevant regulatory issues addressed in
FAR Part 91 (14 CFR Part 91).
3.5 The recommendations in this document are intended to
be generic and not dependent upon the size, weight, speed, or
other physical or performance parameter of the aircraft. It is
recognized that regulating agencies may decide to not regulate,
or only “lightly” regulate UAS for which the assessed risk is
acceptably low. The following discussions do not apply to
systems that fall in this “low risk” category.
3.6 In many jurisdictions, state or government-owned air-
craft are authorized to fly by the application of regulations
specifically applicable to Public aircraft. In the U.S., for
example, flight authorities for Public aircraft are provided
through the Certificate of Authorization (COA) procedure,
defined in FAA Order 7610.4, for special military operations,
or FAA Order 7210.3 for civil Public Use operations. These
special procedures will not be discussed here.
3.7 Requirements for registration and marking will not be
discussed in this document. Similarly, requirements related to
noise and emissions will not be discussed in this document.
4. Preliminary Issues
4.1 Most countries worldwide accept, or adopt (sometimes
with modifications) the regulations and airworthiness standards
issued by the FAA or by the EASA. As mentioned earlier, the
material presented herein is largely based upon the FAA model,
recognizing that many CAAs tend to follow the procedures and
practices of the FAA. Major differences from FAA practices
that are known to exist among the CAAs will be identified.
4.2 The starting point for understanding the procedures for
obtaining a FAA Certificate of Airworthiness is found in FAR
Part 21 “Certification Procedures for Products and Parts”. A
similar procedures document, IR 21, is issued by EASA. A
version of FAR Part 21, modified to include references and
procedures appropriate to UAS has been prepared by ASTM
and is available as Practice F2505. Practice F2505 includes all
of FAR Part 21, some of which is not relevant to developers or
operators of UAS.
4.3 The present “Recommended Practice” document fo-
cuses on the “core rules” from Practice F2505 (or, equivalently,
FAR Part 21), setting aside the items that are inapplicable, or
 F2690 – 08
not urgently required for developmental projects, and supple-
menting these with selected advisory and guidance material
taken from a variety of sources.
4.4 There is an extensive body of regulatory material
invoked by FAR Part 21, in the form of supplementary
standards, such as the so-called design FARs: FAR Parts 23;
25; 27; 29; 33; etc. Compliance with the relevant regulations is
mandatory. In addition, there exists advisory material, includ-
ing Advisory Circulars (ACs), issued by the FAA, or Alternate
Means of Compliance (AMC), issued by EASA, as well as
FAA Orders and similar policy documents issued by the CAAs.
In general, the “official” documents, issued by CAAs, fall into
the following categories: (i) Regulations (Rules); (ii) Standards
(mandatory); and (iii) Advisories (not mandatory). It is impor-
tant for UAS developers to be aware of these documents, and
be familiar with the parts that affect their project. Applicants
seeking approval for UAS designs are urged to review the
documents, especially the Orders and Advisory Circulars listed
in Section 2.
4.5 For UAS developers under FAA jurisdiction, FAA Order
8130.34 contains detailed information that will be of impor-
tance in preparing to seek FAA approval. The Safety Checklist,
included in that document as Appendix C provides a compre-
hensive list of items of safety importance for any UAS design
proposal.
4.6 The procedures to be followed by an applicant for
airworthiness approval, defined in either FAR Part 21 or
Practice F2505 (or in Europe by IR 21), comprise a wide range
of topics presented under the following headings:
(1) General Applicability
(2) Type Certificates
(3) Changes to Type Certificates
(4) Supplemental Type Certificates
(5) Production Under Type Certificate Only
(6) Production Certificates
(7) Airworthiness Certificates
(8) Provisional Airworthiness Certificates
(9) Delegation Option Authorization Procedures
(10) Approval of Parts, Materials, Processes and Appli-
ances
(11) Export Airworthiness Approvals
(12) Designated Alteration Station Authorization Proce-
dures
(13) Approval of Engines, Propellers, Materials Parts and
Appliances: Import
(14) Technical Standard Order Authorizations
NOTE 1—Item 7 defines and describes Experimental Certificates that
are used for UAS, while Items 1–4 and 10 are generally relevant to full
Type Certification. Item 1 is also relevant to a Special CofA.
4.7 Section 1.3 indicated that there are two potential paths
for gaining approval for operation of a UAS within unrestricted
airspace. The first of these possibilities is to obtain a Special
Certificate of Airworthiness Experimental, UAS, in accordance
with 4.6 (7), above. The second path is to seek full Type
Certification that could lead to a Standard Certificate of
Airworthiness. The procedures for applying for a Special
Certificate of Airworthiness Experimental, UAS is described in
Section 6.
4
4.8 To be permitted to fly the Unmanned Aircraft, a Flight
Authority, such as a Certificate of Airworthiness, is required.
Flight Authorities are discussed in Section 5 below. The aircraft
may also require a Registration by the CAA. Regulating
agencies issue a number of different classes of Certificates of
Airworthiness; for example, those issued by the FAA are listed
in Section 5.2 below. In the U.S., “state9 (Public Use) aircraft
can also be operated based upon a Certificate of Authorization
(COA) issued by the FAA. In this case, the operator is typically
the applicant for a COA, whereas in the more general case
(civil, commercial) it is the designer/manufacturer (who may
also be the operator) who makes application for approval to the
CAA.
4.9 The second path to approval is the Type Certificate
(TC), and changes to these, including Supplemental Type
Certificates (STCs), Items 2, 3, 4 and 10 of section 4.6 above.
A Type Certificate is required to obtain a standard CofA; a
Type Certificate is not a flight authority. A Type Certificate is
issued after an extensive evaluation of the system design,
including system safety assessments; evaluations of flight
characteristics; the structural design; design and construction
of components, subcomponents and parts; design and installa-
tion of the powerplant, including fuel and lubrication systems;
design and functioning of systems; and establishment of
operating limitations. The procedures for acquiring Type Cer-
tification are discussed in Part II, below. Organizations propos-
ing to develop a new UAS type are cautioned to avoid
underestimating the cost and the time required to achieve Type
Certification. It’s important to recognize that a Type Certificate
is the product of a design and manufacturing activity: it
confirms that the Type Design complies with the applicable
airworthiness standards. On the other hand, other forms of
flight authority may impose operational restrictions and limi-
tations for flight operations.
NOTE 2—These two paths will be discussed in more detail in Sections
6 and 7, following a brief discussion of Flight Authorities in Section 5.
5. Flight Authorities
5.1 Flight Authorities—A flight authority, issued by the
CAA, is required prior to flight. A flight authority may be (i) a
Standard Certificates of Airworthiness, (ii) a Special Certificate
of Airworthiness, or (iii) a Special Flight Permit. The Special
CofA and Special Flight Permits will usually include opera-
tional restrictions. The several “classes” of flight authority will
be described below. A flight authority, which applies to a
specific aircraft (“tail number”) may, in some cases, be
restricted to a single, specific flight. The flight authority may
also require that a “Noise Certificate” be obtained.
NOTE 3—The Type Certificate as described above applies to the aircraft
type (for example, B747, A320, Cessna 172) and is not a flight authority.
Standard Certificates of Airworthiness are issued in respect of an aircraft
that has been Type Certified.
5.2 Certificates of Airworthiness—Following current FAA
practice, a Certificate of Airworthiness (CofA) may be issued
as follows (other regulatory authorities follow similar prac-
tices):
5.2.1 Standard CofA—This is based upon the Type Certifi-
cate and is applicable to all airframes of that type. The CofA
 F2690 – 08
will also reflect any modifications or additions of equipment
that have been made to the aircraft.
5.2.2 Special Airworthiness Certificates:
(1) Primary aircraft category
(2) Restricted
(3) Limited
(4) Light-sport aircraft category
(5) Provisional
(6) Experimental
5.2.3 Other categories, issued by some authorities, such as
certificates for owner-maintained, amateur-built aircraft.
5.3 Other Flight Authorities—Other Fight Authorities is-
sued to manned aircraft include flight permits for special
operations, such as one-engine inoperative ferry permits, air
shows and promotional demonstrations.
5.4 Special Airworthiness Certificate for Unmanned Air-
craft Systems—The U.S. FAA is developing requirements for
the issuance of a Special Airworthiness Certificate for UAS
(See FAA Order 8130.34 and FAA Interim Operational Ap-
proval Guidance 08-01). Current FAA policy is to issue an
Experimental Certificate for an Unmanned Aircraft System.
The FAA limitations on operations of UAS include within
visual range, daytime only and not in the vicinity of other
aircraft (FAA AIR-160 Interim Operational Approval Guidance
08-01). Other CAAs are developing similar requirements and
guidance material. Developers of UAS should contact the CAA
to obtain the latest information concerning requirements for
UAS. Early consultations with the regulating authority will
help to identify potential certification issues and avoid delays
as the process continues.
NOTE 4—The Special Airworthiness Certificate for Unmanned Aircraft
Systems is a unique document, specifically created for a UAS. The term
CofA may be a misnomer, but is retained because of the international
acceptance of the concept of a CofA.
6. Obtaining a Special CofA, Experimental (UAS) (FAA)
or Special Flight Authority (Other) CAAs)
6.1 At this stage of development of rule-making, the proce-
dures to be followed to obtain a Flight Authority vary from
jurisdiction to jurisdiction and are subject to change as the
CAAs gain experience with these systems. For example, in the
UK, the CAA document CAP 722 is the regulatory basis, while
the policy for “light” (less than 150 kg, Maximum Gross Take
Off Weight) is defined in a UK CAA policy paper.12 In Canada,
UAS operations are regulated by the issuance of a Special
Flight Operations Certificate (SFOC) (CAR Section 602.41
and Transport Canada Civil Aviation Staff Instruction). The
Australian Civil Aviation Safety Authority (CASA) Advisory
Circular 21-43(0) describes the procedures for obtaining an
Experimental Certificate for a Large UAV, while the regula-
tions for UAS are found in Civil Aviation Safety Regulation
(Australia) Part 101. In the US, the applicant must first contact
the FAA to obtain a registration number for the aircraft under
consideration.13
13
This application is to be made to FAA Registration Branch, AFS-750, Mike
Monroney Aeronautical Center, P.O. Box 25504, Oklahoma City, OK, 73125- 0504.
The applicant should also obtain a copy of the latest version of the FAA Order
concerning UAS, FAA Order 8130.34.
5
6.2 The following paragraphs are based upon current pro-
cedures in the United States and in Canada. The basis for the
FAA procedures is found in FAR 21 Sections 191 to 195 and in
FAR 91 at Section 319. In Canada, a Special Flight Operations
Certificate is used to authorize flight of a UAS. The Canadian
procedures are found in CAR Section 602.41 and Transport
Canada Civil Aviation Staff Instruction. The FAA process does
not permit commercial operations. The Canadian SFOC pro-
cess may approve operations for compensation or hire.
6.2.1 In preparing for discussions with the regulating au-
thority, the applicant for a Special Airworthiness Certificate for
Unmanned Aircraft Systems should be prepared to respond to
numerous questions that relate to the safety and expected risks
associated with the UAS proposal. The questions will be aimed
at both airworthiness and operational matters. The following
list includes some items that the applicant should address:
(1) Description of the aircraft, including principal dimen-
sions, physical layout and propulsion system;
(2) Description of and type (internal combustions, electri-
cal, etc.) of powerplant;
(3) Analysis and test methods used to assure structural
integrity;
(4) Description of manufacturing, production and quality
assurance provisions;
(5) Assessment of assurance levels for flight critical
software;
(6) Maintenance procedures, and qualifications required to
perform maintenance;
(7) Description of methods used to ensure the aircraft is fit
and safe for flight;
(8) Description of the means for guidance and control of
the aircraft;
(9) Description of the Ground Control Station, up- and
down-links (command and control);
(10) Emergency procedures, including emergency flight
termination and loss of command and control links;
(11) Description of expected flight performance of the
aircraft;
(12) Type of launch and recovery (conventional runway,
launcher, parachute, etc.);
(13) Proposed types of operations, including expected
regions or areas of operation;
(14) Expected duration of operations;
(15) System for interacting with Air Traffic Control;
(16) Description of any unique design features or incorpo-
ration of unique technologies;
(17) Description of the procedures to be used for confor-
mity control;
(18) Listing of documents and test reports prepared to
support the design safety features;
(19) Procedures to deal with lost aircraft causing damage,
injury or death;
(20) Classes of airspace to be used;
(21) Contacts (names, telephone, etc.) for key operating
personnel;
(22) Describe experience level, training or other qualifica-
tions of key operating personnel;
(23) Security of Ground Control Station;
 F2690 – 08
(24) Use of SATCOM or other command and communica-
tions systems;
(25) Arrangements for liability insurance;
(26) Other items that the CAA deems relevant.
6.2.1.1 The foregoing list is representative of the kinds of
issues the CAA may raise and should not be considered as
definitive or complete. Appendix C to FAA Order 8130.34 is an
extensive list of safety items to be considered.
6.2.1.2 While formal Functional Hazard Assessments
(FHA) and System Safety Assessments (SSA) have not been
explicitly identified in currently available guidance material, it
is anticipated that these will be included as they are exception-
ally helpful to the CAA. The applicant is urged to become
familiar with the conceptual basis for these assessments (See
FAA Advisory Circular AC 23.1309-1C and SAE Aerospace
Recommended Practice ARP4761).
6.2.1.3 Working Group 73 of EUROCONTROL has also
proposed the concept of “Safety Screening” prior to undertak-
ing the FHA. In addition, preparation of a “Safety Case for
UAS Operations” has also been proposed.14
6.2.2 Functional Hazard Assessments, together with System
Safety Assessments, are rigorous procedures that aircraft and
aircraft system designers use to identify potential hazards, and
to focus on specific system elements the failure of which may
be catastrophic or hazardous. The Preliminary System Safety
Assessment (PSSA), performed following the FHA, is a critical
step, as it will help to provide early identification of potential
trouble spots. With the knowledge gained by conducting the
FHAs, PSSAs and SSAs, designers can then incorporate
features that will avoid the identified failure possibilities. The
FHA procedures and the PSSA and SSA processes are de-
scribed in FAA Advisory Circular AC 23.1309-1C and SAE
Aerospace Recommended Practice ARP4761. Very briefly, the
procedures and processes guide the designer through a series of
steps in which the features of a system (the overall system,
such as the UAS, and subsidiary systems, such as an autopilot)
are examined in detail, identifying the purpose (function) of a
system or subsystem, followed by a detailed analysis of the
system operation, identifying each possible failure mode for
14
A Concept for UAS Airworthiness Certification and Operational Approval in
the Context of Non-Segregated Airspace (DRAFT) EUROCAE WG 73.
PART II
7. Suggested Procedures for Type Certification of a UAS
7.1 Type Certification, General—If the applicant wishes to
proceed to obtain a Type Certificate for the proposed UAS, the
following paragraphs contain useful guidance information.
While regulations for Type Certification of UAS have not yet
been promulgated, it can be anticipated that procedures will be
similar to those in place for conventional aircraft. It is also
likely that a Type Certificate will be required for system
designs that will result in multiple units (a significant produc-
tion run) for multiple and diverse applications by potential
6
each component. One of the common tools used for this
process is the Fault Tree Analysis (FTA), a top-down approach
that posits a high-level failure, then traces the subsystems and
components that may contribute to the top-level failure. The
FTA is capable of providing quantitative assessments, based
upon the probabilities of failure of the system components. The
Failure Modes and Criticality Effects Analysis (FMECA), in
contrast to the FTA, is a bottom-up approach. Here, the
designer assumes the failure of a low-level component (resis-
tor, relay, valve, fastener) and seeks to identify the possible
outcomes following the component failure. Both FTAs and
FMECAs may be required, recognizing that a UAS is a
complex system of systems.
6.2.3 The CAA may wish to witness some of the preflight
test procedures, as well as observe the first flight. A first flight
readiness checklist should be prepared. Arrangements for test
flights should include specific test plans to establish the
operating characteristics of the aircraft and its various systems.
The test flying program may require the approval of the CAA.
The operational limitations for aircraft operating with experi-
mental Certificates of Airworthiness are defined in FAR Part
91.319. Additional limitations will be added when a Flight
Authority is issued.
6.2.4 The foregoing paragraphs have focused attention on
procedures and steps to be followed when seeking initial
approval of a proposed UAS so that flight testing may be
carried out. These approvals are typically highly restrictive,
and typically do not permit operations for compensation
(commercial operations). For UAS to become commercially
viable, it must be possible to operate with few restrictions, and
have access to the nonsegregated airspace. To achieve this
objective, regulating agencies must be assured that integration
of UAS into the airspace can be accomplished without com-
promising existing safety levels and without increasing risk to
third parties. Convincing, well-documented cases, backed up
with test data, analyses and operating experience will be
required. It is expected that the rigorous procedures of formal
type certification will be required by the authorities. The next
paragraphs, comprising Part II of this guide, are provided for
applicants who anticipate seeking full approval for commercial
operations of their UAS.
users. If the objective is simply to obtain a flight authority for
only a small number of systems for a limited class of
applications, a Special Certificate of Airworthiness, Experi-
mental (described above) may be sufficient.
NOTE 5—Again, it is important for the applicant to be well-informed
concerning the applicable regulations. The CAA expects the applicant to
have some knowledge of certification procedures, and be familiar with the
concepts discussed in many of the references cited in Section 2. For
example, FAA Orders 8130.2F, 8130.34, 8110.4C, Advisory Circulars AC
21–12, AC 21.40, AC 23.1309-1C, AIR-160, Transport Canada Advisory
Circular 500-15, CAR 602.41, and Haddon and Whittaker12 contain
 F2690 – 08
essential information. To propose a set of standards that could serve as a
Basis of Certification (see 7.10) requires a familiarity with the airworthi-
ness standards, such as FAR 23 and FAR 25 for fixed wing aircraft, and
FAR 27 and FAR 29 for rotary wing aircraft.
7.1.1 At the concept development stage, the developer
should identify a Basis of Certification (BoC) for the system.
The BoC is a core component of the certification process. The
BoC will define the airworthiness regulations and standards
that will apply to the UAS; it is discussed in more detail in
7.10. For conventional, manned aircraft, the BoC is selected
from the “design FARs,” FAR Parts 23, 25, 27, or 29. Type
Certification is a lengthy and rigorous process, and is a major
cost factor in developing a new design. For UAS, it may be
necessary to define an entirely new set of requirements to form
a BoC. This approach is accommodated by FAR 21.17(b) that
deals with “special classes of aircraft.”
7.1.2 Following Type Certification, the developer, or other
users of the type design may wish to alter the design, by adding
components or systems, or otherwise modifying the design.
The developer to whom the TC was issued (the “TC holder”)
has the choice of either a change to the type design or obtaining
a Supplemental Type Certificate (STC) for the design change.
An organization that is not the holder of the TC may also seek
to have a change approved as an STC. In either case, the
modification will be extensively reviewed, against the BoC for
the type. Note that a Type Certificate is not a Flight Authority;
a Standard Certificate of Airworthiness may be issued based
upon the Type Certificate.
7.2 Certification Plan:
7.2.1 The Certification Plan is used by the applicant to
inform the CAA about the UAS development Project. The
Certification Plan should contain sufficient detail to (i) famil-
iarize the CAA with the proposed project, and (ii) demonstrate
to the CAA that the applicant possesses the expertise and
knowledge to conduct a credible project. Although there may
have been some preliminary discussions with the CAA before
the Certification Plan is submitted, the presentation of the
Certification Plan is usually the first formal opportunity for the
applicant to outline how the Project will address the procedures
required to obtain certification of the UAS.
7.2.2 While there is no fixed format for a Certification Plan,
the following paragraphs give a brief outline of the key
components that the CAA will expect to find in the Plan.
Reference should be made to documents such as the FAA
Advisory Circular AC 21-40 and Transport Canada Advisory
Circular 500-15. While FAA AC 21-40 specifically addresses
STCs, much of the information is broadly applicable to
preparing an application to a CAA for obtaining some form of
flight authority for a UAS. (see 14 CFR Part 21, FAA Orders
8130.2F and 8130.34).
7.2.3 Although some CAAs encourage informal, prelimi-
nary “concept briefing” meetings, the first formal meeting with
the Regulatory Authority is sometimes referred to as the
“Initial Type Board Meeting”. This is one of several formal
meetings between the applicant and the regulator, during which
items of concern are identified, along with means by which the
concerns can be addressed. Topics for discussion at the Initial
7
Type Board Meeting are introduced below. This list is not
all-inclusive: other items may be introduced during this, or
later meetings.
7.2.4 Any features or components of the system design for
which the demonstration of compliance with the standards may
appear to require special consideration will become the subject
of “Issue Papers” (FAA Order 8110.4C). Issue papers are used
to focus attention on potential non-compliance items. These
will enable the regulator and applicant to work out an accept-
able plan for demonstrating compliance in unusual cases.
7.3 Project Description—Provide a brief introductory para-
graph giving an overview of the project.
7.4 Outline of Project—Describe the Project, indicating the
primary objectives, the scope of the undertaking and the
proposed technologies, as well as the systems that will require
approval by the regulatory authority.
7.5 Statement of Operating Intent—Describe how the appli-
cant proposes to use the UAS, including the expected areas of
operation, types of operation (high level surveillance; napof-
the-earth sensing; aerial photography; crop spraying; etc.) and
typical features such as operation in support of law-
enforcement agencies, mineral exploration, forest fire spotting,
etc.
7.6 Unique Design Features—Explain any features or con-
figurations of the proposed UAS that are non-conventional
(canard; unusual materials; non-conventional powerplant, etc).
Include a brief explanation of how the proposed roles drive the
non-conventional approach.
7.6.1 Many features of a UAS design will be unique, and
will need to be subjected to demanding, rigorous evaluation to
assure safety. System reliability is a major component of safety,
so reliability methods will be required. In addition, evidence of
completion of Functional Hazard Assessments (FHAs) (refer to
section 6.2.2 above) and related methodologies, including
Systems Safety Assessments, will be expected by the regula-
tory authorities. Guidance for these methodologies is found at
SAE Aerospace Recommended Practice ARP4761.
7.7 Scope of Approval Sought—Define the scope of activity:
day VFR; night VFR; all IFR. Related items, such as the
following, may be introduced at this point:
(1) Classes of airspace for which approval is sought;
(2) Expected regions of operation;
(3) Types of operation proposed;
(4) Expected duration of operations; etc.
7.8 Level of Involvement (LOI) by Certifying Authority—
Determine the CAA’s Level of Involvement. The regulatory
authority will review the application for certification and
establish the extent to which the CAA will examine and review
the development of a UAS. This may include items such as:
7.8.1 Establishing the means by which compliance is to be
shown (for example: analysis; test; drawings; similarity);
7.8.2 Defining testing procedures;
7.8.3 Delegating authority for findings of compliance;
7.8.4 Defining extent of participation in qualification proce-
dures (such as test witnessing by the CAA);
7.8.5 Reviewing of compliance reports, drawings and test
specifications;
 F2690 – 08
7.8.6 Establishing the flight testing program and proce-
dures;
7.8.7 Reviewing risk management methods; and
7.8.8 Outlining Instructions for Continuing Airworthiness
(ICAs).
7.9 Operational Restrictions—Identify additional restric-
tions that must be observed, especially during the flight test
phase of the project. The aircraft must be shown to comply
with all relevant requirements of FAR Part 91 or the equivalent
requirements defined in the regulations of other CAAs. In the
event that compliance cannot be fully established, the CAA
will impose limitations, such as areas of operation; visual range
operations only; requirement for chase aircraft; requirement for
radar or other monitoring; emergency recovery procedures; and
exclusion from specified airspace.
7.10 Basis of Certification—The Basis of Certification for a
UAS that is to be Type Certificated comprises a number of
components. These are listed in the following paragraphs.
7.10.1 Conventional Airworthiness Standards (FAR Part 23,
EASA CS 23 or similar)—A number of airworthiness standards
exist, each of which may include items that are generally
applicable to a UAS. However, the range of configurations,
sizes, propulsion systems and command and control systems is
so broad that no one standard is entirely appropriate. Moreover,
at this time, no standard for a UAS has been created. In due
course, a suitable standard(s) may be written. In the meantime,
UAS developers should review the standards that presently are
used, and consult with the CAA concerning which elements of
the several standards should be applied.
7.10.2 Project-Specific Standards Proposed—Since each
UAS design is expected to include unique features and
technologies, directly applying an existing standard will not
generally be appropriate. In the absence of a CAA-issued
airworthiness standard, the final result will comprise a collec-
tion of items adopted from existing standards, supplemented by
additional requirements, such as standards for Ground Control
Stations, launch and recovery facilities, emergency recovery
systems, etc.
7.10.3 Special Conditions—Special conditions may be im-
posed by the CAA when it is found that the existing regulations
and standards do not adequately address the safety issues
related to the unique or novel features of the design. In the case
of a UAS, this may include details such as unique launch and
recovery features or command and control systems. (The FAA
regulation is found at FAR Part 21.16).
7.10.4 Equivalent Safety Items—From time to time, the
CAAs may determine, for airworthiness standards that are not
complied with, that an equivalent level of safety has been
assured by appropriate compensating factors. (The FAA regu-
lation is found at FAR Part 21.17(b) and FAR Part 21.261).
7.10.5 Exemptions or Waivers Sought—Applicants for Type
Certification may seek alleviation, in the form of an Exemption
or a Waiver, from airworthiness standards prescribed by the
CAA.
7.11 Unique UAS Features—For UAS, this evaluation
would include the GCS and command and control links, as
well as unconventional launch and recovery systems. In
addition, procedures for continuing airworthiness and provi-
8
sions for meeting noise and environmental requirements will
be evaluated. The evaluations will be conducted to ensure that
the relevant requirements defined by the Basis of Certification
(BoC) are met.
7.12 Compliance with Noise and Emissions Standards—At
present, there are no provisions for civil, commercial opera-
tions of UAS in the U.S. Other jurisdictions may be more
permissive, but it is expected that unmanned aircraft will be
required to meet standards for noise and emissions. Current
standards found in FAR Part 34 and 36 are representative. Note
that the ICAO Noise Standard is ANNEX 16; the correspond-
ing FAA requirement is FAR Part 36 which differs slightly
from the ICAO Standard.
7.13 Compliance Documents—During the Initial Type
Board Meeting, the regulating agency and the applicant will
agree on the list of documents that will be required to show
compliance with the requirements identified in the Basis of
Certification. These documents may include items such as: Test
Plans and Test Results; Drawings and sketches; formal Reports
detailing design features; Software Assurance procedures to be
used; Materials evaluations; and Operating Manuals. For each
requirement the means and method of compliance must be
documented.
7.14 Compliance Record—The Compliance Record is typi-
cally a matrix document that records how each of the indi-
vidual requirements in the Basis of Certification has been
addressed, including identification of the supporting documen-
tation and the identification of the individuals who have
responsibility for determining that compliance has been shown.
The Initial Type Board Meeting should establish these respon-
sibilities, including any “delegations” that the regulatory au-
thority may make concerning findings of compliance. The final
result is a comprehensive record of the processes and proce-
dures by which the product is certificated as airworthy.
7.15 Maintenance—The applicant must provide mainte-
nance instructions that will enable operators to maintain the
aircraft in an airworthy state throughout its life. This includes
details on inspection and overhaul intervals, repair and replace-
ment of components, along with information concerning the
qualifications required of maintenance personnel. Applicable
airworthiness standards include the requirement to specify
Instructions for Continuing Airworthiness (ICA). These in-
clude the items above, along with procedures for establishing a
Maintenance Review Board and airworthiness limitations. The
ICA provides for the continued serviceability and safety of the
system through properly conducted maintenance, repair and
overhaul of the aircraft and its associated off-board systems.
7.16 Post-Certification—The applicant for an airworthiness
certification for a UAS must create an acceptable plan that will
ensure that the product can be maintained in an airworthy state
throughout its useful life. This means supporting the Continu-
ing Airworthiness Instructions with corrective action when
required as a result of service experience. In particular, the
applicant must demonstrate the capability to address safety
issues by working with the regulatory authority in creating
Airworthiness Directives to correct design deficiencies or to
 F2690 – 08
revise maintenance schedules, etc. This postcertification activ-
ity will require adequate record-keeping, as well as mainte-
nance of design capability to deal with airworthiness corrective
action.
8. Summary
8.1 The recommended practices described in this document
are intended to guide prospective applicants for flight approval
and product certification of a UAS by Civil Aviation Authori-
ties. Given the current rapid evolution of the UAS “universe”
and the need for timely regulatory response by the CAAs,
developers can expect that there will be some variability in
procedures. Some CAAs will deal with applications on a
“one-off” basis, while others may delay approval pending
formal issuance of regulations. Some jurisdictions are well
advanced, having approved limited commercial operations.
The gaps, however, are substantial. In the absence of regula-
tions, standards are being created to provide guidance. A
number of standards developed by ASTM International are
listed in Section 2.
8.2 In the early stages of development of any “new” activity,
the period of initial growth is characterized by a lack of
standardization. In aviation, standards are the cornerstone of
the overall safety of the industry, hence it is important to
develop safety standards at an early stage. During this period of
rapid change it is essential that the stakeholder, designers,
builders, modifiers, operator and maintainers, pay careful
attention to safety issues. This emerging UAS industry will not
be well served by unsafe practices, and in particular, will be
seriously compromised by accident or incident events. Safety
must be the focus and the responsibility of all participants.
9. Closure
9.1 This guidance document has been prepared based upon
available material and regulatory developments available at the
time of writing. It is clear that, in this rapidly changing
environment, some of the material will become outdated rather
quickly. Revisions will be processed using conventional ASTM
procedures.
9.2 One planned feature is the addition, when available, of
CAA-specific Appendices that comprise detailed, step-by-step
guidance for applicants wishing to access their Civil Aviation
Authority. At this time, information is still in a state of rapid
change, so the addition of these suggested Appendices must
await availability of procedural requirements from the CAAs.

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