Ditto. Besides those of us who build our own will be able to add new tech easier than those with off-the-shelf gear.Yes. The final rule is 5 years out.
Along the line of home built.Ditto. Besides those of us who build our own will be able to add new tech easier than those with off-the-shelf gear.
But regardless, didn’t the home builds only qualify for the 3rd level and restricted to a FAA zoned field?
To add would be daunting or may be unobtainable if it requires certified components... my understanding is "currently" even the current manufactured models are not upgradable unless performed by the original manufacture. I hope it softens, and allows a pathway for existing platforms to obtain electronics to meet requirements.Sort of.
A 'typical' home build will not meet the requirements of Part 89 (Remote ID of Unmanned Aircraft Systems) and can only be flown at the approved fields.
The NPRM does not preclude an individual from building a craft that meets the requirements and filing the necessary paperwork. But it will be a pretty daunting task.
or may be unobtainable if it requires certified components...
Correct, doesn't state certified, I stated "if it requires certified"... my interpretation as it "develops", the need to meet compliance will probably include some form of quality standard that would require indication/verification meeting that quality standard... that most likely won't be the home builder making statement it meets standards. The 2nd section sited on declaration of compliance (DOC), submitting a DOC will most likely require validation of some sort to limit or control the compliance, but currently that is an unknown for requirements and electronics.The NPRM does not specify, or even mention that I have seen, anything about "certified" parts or modules. It does say that the craft must meet "performance standards" See the following.
§ 89.510 Production requirements.
(a) General production requirements. After [DATE 24 MONTHS AFTER THE EFFECTIVE DATE OF THE FINAL RULE], no person may produce an unmanned aircraft system unless:
(1) The unmanned aircraft system is designed and produced to meet the minimum performance requirements for standard remote identification unmanned aircraft systems established in § 89.310 or for limited remote identification unmanned aircraft systems established in § 89.320 and in accordance with an FAA-accepted means of compliance.
And further:
The FAA is proposing in § 89.520 that a person responsible for the production of standard remote identification UAS and limited remote identification UAS be required to submit a declaration of compliance for acceptance by the FAA. The declaration of compliance would affirm that the UAS meets the minimum performance requirements for remote identification by meeting all aspects of an FAA-accepted means of compliance (e.g., a consensus standard) for UAS with remote identification equipment. The FAA would rely on the declaration of compliance to show that the UAS complied with the applicable remote identification requirements at the time the UAS was produced. The FAA would not consider a declaration of compliance under this proposed rule to be an airworthiness certification.
To add would be daunting or may be unobtainable if it requires certified components...
Correct, doesn't state certified, I stated "if it requires certified"... my interpretation as it "develops", the need to meet compliance will probably include some form of quality standard that would require indication/verification meeting that quality standard...
Think of it as constructing a home built airplane, you can purchase all the parts from manufactures, but it still requires an IA to inspect and sign off to be flight worthy. Who knows, In the future FAA may require you to have an annual too, lol.Since the FAA had previously approved of the use of that module, it will likely be approved when used in another build. The module is not "certified" though.
In my opinion, interpretation... disagree.I'm as critical of some of the details in the proposal as anyone. And, if you read carefully, you notice that in most cases, the FAA has chosen to go far beyond what was proposed by the ARC (Aviation Rule making Committee).
But some of your assumptions go out in the weeds pretty quickly. I would suggest that to present a respectable rebuttal, it's best to stick to what is in the NPRM.
Straight forward yes or no answer poll.
Thanks in advance for you participation.
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