Circular 328_en

ICAO Circular 328-AN/190 29
along with many more. Situations like these will involve technology and equipment not traditionally assessed in the
current airworthiness process.
6.23 Regarding the subject of continuing airworthiness, the remote pilot station should be treated similarly to the
RPA. Additionally, due to the operational nature of the RPAS on long-haul flights, the option of “In Flight Maintenance”
should be studied. It can be foreseen that the remote pilot station intended for later stages of the flight could be taken
out of service after the RPA has initiated its flight, a situation which would not necessarily prevent the RPA from
continuing. If the remote pilot station can be returned to service or an alternate one used, the flight may be unaffected.
NATIONALITY AND REGISTRATION MARKS
6.24 Annex 7 — Aircraft Nationality and Registration Marks, specifies the minimum Standards for the display of
aircraft marks to indicate appropriate nationality and registration. It is important for UA to comply with aircraft marks so
the UA can be identified in cases where they come in close proximity to other aircraft, are intercepted, or land at
aerodromes other than the designated landing site.
6.25 Some UA may have difficulty meeting the readily identified mark requirement as well as the height
requirements for both lighter-than-air and heavier-than-air aircraft as the airframe may be too small. Exemptions for
marks or alternative systems, such as labelling already used for aircraft parts that adequately allow identification may be
required for small UA. Requirements for changes to Annex 7 SARPs as regards to their applicability to UA will be
considered in due time.
RADIO NAVIGATION AIDS AND AIRBORNE NAVIGATION EQUIPMENT
6.26 As a general statement, all aircraft, whether manned or unmanned, must meet the navigation performance
requirements for the specific airspace in which they will operate.
6.27 RPA that utilize VLOS as the basis for navigation would not require an on-board means for determining
position or the ability to fly an instrument approach. Operations of these aircraft are usually conducted under VMC to
ensure the remote pilot can maintain continuous and direct visual observation of the RPA and its surrounding
environment.
6.28 RPA that traverse several airspace volumes may operate for the most part under IFR. Such RPA will have
to meet the communications, navigation, and surveillance requirements and have an appropriate aircraft operational
certification associated with the airspace.
6.29 In cases where small RPA have a requirement to fly beyond VLOS, they will need a means to meet
navigation capabilities for the airspace within which they are operating. This could involve an alternate means of
achieving the navigation performance.
SURVEILLANCE SYSTEMS
6.30 Unless exempted by the appropriate authorities, all UA will likely be required to be equipped with pressurealtitude
reporting transponders which operate in accordance with the relevant provisions in Annex 10, Volume IV —
Surveillance and Collision Avoidance Systems.