Wednesday, July 21, 2021

TC/DC

I don’t get why people, aka “drone experts, and visionaries” fall for these FAA ruses
again and again. In my estimation, this effort is another iteration of an expensive and
time-consuming industry trip down the rabbit hole. I know what you’re thinking,
that Egan guy is such a bring-down when he starts with the reality stuff. Sure, he’s
right most of the time, but my investors and then Congress start asking hard
questions, and well, I’m not too fond of that. Just a warning, you might want to head
the investors off at the pass on this one.

For those of you who may not know what all of this Type Certification means, from
the trailblazing 3DRobotics page –

What is Type Certification?

Type Certification, or “TC,” is the method by which the governing authority over
aircraft safety certifies a model (or “type”) of aircraft as safe and airworthy. The
United States the Department of Transportation, specifically the Federal Aviation
Administration (FAA) oversees this process. 

3DR, working with the FAA and  Auterion , a fellow partner in  Dronecode , has helped
create the certification process to achieve a TC for small unmanned aerial systems.
This new sUAS Type Certification streamlines the process used for standard aircraft
and makes it applicable to modern drone hardware. 

This new streamlined UAS Type Certification process, creates a regulatory path for
operations beyond the FAA Part 107 rule, including night flights, flying beyond visual
line of sight (BVLOS), and flights over people.

From the FAA webpage –

Certification

Certification is how the FAA manages risk through safety assurance. It provides the
FAA confidence that a proposed product or operation will meet FAA safety
expectations to protect the public. Certification affirms that FAA requirements have
been met.

14 CFR Part 21 defines three separate certifications: type, production, and
airworthiness.

Type certification is the approval of the design of the aircraft and all component parts
(including propellers, engines, control stations, etc.). It signifies the design is in
compliance
with applicable airworthiness, noise, fuel venting, and exhaust emissions
standards. The Los Angeles Aircraft Certification Office (ACO) is the main ACO for unmanned aircraft systems (UAS) type certification. You can contact their office for
more information.

Golly, software too? Doesn’t that sound great? It is almost the same promise that
Remote ID was going to usher in, which by the way is happening December 2020.

RID supposedly makes everything safe, so why would anyone go through the trouble
and expense of a TC when RID is going make all of our UAS September 2015 NAS
integration dreams come true?

It appears that the Detect and Avoid thing plus certification got lost somewhere in the PowerPoint again? Maybe everyone is just going all-in on the TC, so they don’t have to do the arbitrary and capricious dance with the Amazing Grogan again? All I will say here is don’t burn any bridges just yet.

One constant with the NAS integration effort is holding out for the Holy BVLOS Grail.
The stakeholders (Patagonia clad and Fortune 500) get strong assurances that the
$82 billion skies will open up. The bag holders only hear tales of the BVLOS grail
every time the FAA runs some ham-fisted regulation or policy idea up the flagpole.
That “stuff” only serves to limit Mom and Pop’s viability, disenfranchises the RC
hobbyist, and or fleece some poor VC SOB out of money and prestige. I assure
readers that I did consider the holiday season and tried not to use the “ham-fisted”
qualifier but we have a decent regulation and policy deficit.

September 15th, 2015 might serve as a useful reference point for drone technology
as the olde type certification will be a software and hardware snapshot in time.
(Unless you are Boeing and you’ve got the self-certification stamp of approval.) Just
imagine what the Chinese toy company will be selling three to five years from now,
and you’ll be working on the cutting edge of Drones as a Servicio with the tech of
Christmas past.

Whataboutism alert! Read down the FAA webpage, and things get real.


 Production certification is the approval to manufacture duplicate products under an
FAA-approved type design. It signifies that an organization and its personnel, facilities,
and quality system can produce a product or article that conforms to its approved
design.
 Airworthiness certification is necessary for operation of civil aircraft outside of 14 CFR
Part 107 or without an exemption under the Special Authority for Certain Unmanned
Systems (U.S.C. 44807). An airworthiness certificate can be either in the Standard or
Special class and signifies that an aircraft meets it’s approved type design (if
applicable) and is in a condition for safe operation.

Read even further down the page, and drone experts (consultants and lobbyists),
are saying send more money. VC investors should be asking who is hitting the
Pookie pipe, and how many tears per CEO’s house square foot must I cry?

It begs the question, who is going to take the fall, you’ve already fired your drone
expert? Does anyone remember the name of the guy that got bounced out of the FAA
UASIO and went to Aircraft Certification?

The TC thing harkens back to the launch of 14 CFR Part 107 and companies like 3DR
running out of steam (VC debt-equity swaps) just as the rules that didn’t allow for
BVLOS, over people, and at night flight kicked off. In this TC instance, we see
Amazon had a big shakeup in leadership and personnel. (Maybe someone just pulled
a Dave Vos, got tired of all of the money and prestige, and said, F-you?) 3DR now
operates out of the Berkeley Esri office.

Some of the other would be sky-king contenders will have another rude awaking coming and after those savvy tech investors have laid out a boatload of cash on bad advice. Why wouldn’t the FAA tell them they are wasting their time? Maybe they did, and this is just one more instance of buying some years of employment on uneducated investment dollars?

In the latest sUAS News podcast episode, our guest succinctly put it this way; “I feel
like there are a lot of companies out there that use regulatory concerns as a justification for a P&L that’s not as attractive as their investors may want.

“ – Tom Walker, CEO DroneUp. I don’t think I could have said it better myself!
I’m hearing the tired old mantra again… anything that enables more use of commercial unmanned technologies is a good thing. In my estimation, the cost is high, and the return low.

@TheDroneDealer on the Twitter

Patrick Eganhttp://patrickegan.net/
Editor in Field, sUAS News Americas Desk | Patrick Egan is the editor of the Americas Desk at sUAS News and host and Executive Producer of the sUAS News Podcast Series, Drone TV and the Small Unmanned Systems Business Exposition. Experience in the field includes assignments with the U.S. Army Space and Missile Defense Command Battle Lab investigating solutions on future warfare research projects. Instructor for LTA (Lighter Than Air) ISR systems deployment teams for an OSD, U.S. Special Operations Command, Special Surveillance Project. Built and operated commercial RPA prior to 2007 FAA policy clarification. On the airspace integration side, he serves as director of special programs for the RCAPA (Remote Control Aerial Photography Association).