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Chapter 6
AIRCRAFT AND SYSTEMS
CERTIFICATION
6.1 RPA are integrating into a well-established certification system and are subject to demonstrating
compliance in a manner similar to that of manned aircraft. The fact that these aircraft cannot operate without supporting
system elements (remote pilot station, C2 data links, etc.) brings new complexities to the subject of certification. One
cannot assume that a single RPA will always be flown from the same remote pilot station using the same C2 data link.
Rather, it is likely that each of these system elements will be changeable. It is even likely that for long-haul operations,
the remote pilot station and C2 data links will be changed during flight and that as a remote pilot station is released from
one aircraft it can then be used for another in real time.
6.2 Taking this new concept one step further, it is also likely that components will be located in different States.
The long-haul flight operating from one region of the world to another will face increasing C2 and communications
performance issues as the aircraft travels further from its remote pilot station. While the performance (e.g. data link
transaction time, availability) may not be detrimental in the oceanic and remote en-route environments, it will be different
in the congestion of the continental and aerodrome environments. To address these issues, it may be necessary to
handover piloting control from the “home” remote pilot station to one in the destination locale. Legal issues related to
certification, licensing and the recognition of documents in this new scenario would have to be addressed.
6.3 The remote pilot station, particularly looking at possible future scenarios, could be operated as a
commercial enterprise by a “remote pilot station operator”. This remote pilot station operator would be responsible for
obtaining approval from the State Civil Aviation Authority (CAA) to operate and maintain the remote pilot station. Among
the factors to be considered would be specific aircraft types that can be piloted from the remote pilot station. It should be
noted that the State of the remote pilot station operator would not necessarily be the same as the State of the Operator
of the RPA. Complex legal issues and agreements between States would have to be addressed prior to this scenario
becoming feasible.
6.4 From an operational point of view, it is desirable to have maximum flexibility in using remote pilot stations
when conducting a flight. Implementing this concept would lead to a flexible operational system configuration. Two
possibilities envisaged to facilitate this flexibility are described in 6.5 and 6.6.
6.5 The first option envisaged is that the certification of the RPAS is documented with the Type Certificate
issued to the RPA. The configuration of the RPAS as a whole would be included in the Type Certificate of the RPA,
under the responsibility of one unique Type Certificate holder. The remote pilot station associated with the aircraft would
be a separate entity, likely to be treated in a manner similar to engines and propellers in that it could have a Type
Certificate issued by the remote pilot station State of Design. The configuration of RPA and remote pilot station(s) would
be certified in conjunction with the RPA by the State of Design of the aircraft and documented in the Type Certificate
data sheet. The remote pilot station then is “part” of the RPAS. This would give the RPA State of Design responsibility
for the overall system design. The RPA State of Design would also have responsibility for providing any mandatory
continuing airworthiness information. The State of Registry would have responsibility for determining continuing
airworthiness of the RPAS in relation to the appropriate airworthiness requirements. More than one remote pilot station
could be associated with the RPA as long as the configuration is described in the Type Certificate. A Certificate of
Airworthiness would be issued for the RPA, and it would remain the responsibility of the operator to control the
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