Certification of UAS for Commercial Operation

Week 9 has finally arrived for ERAU- ASCI 530 UAS studies. During this time frame I was tasked to prepare and submit an analysis demonstrating my understanding of the course topics associated with UAS design, operations, or regulation. Since I work with the FAA I chose to focus my analysis on the regulatory aspects of UAS certification. My primary focus was that of how current UAS manufacturers do not have an FAA approved quality system and how they have misinterpreted the different quality aspects in industry as being acceptable standards in allowing commercial operation of their systems in the NAS. For those that read this paper I hope that it answers some basic regulatory questions with regards to certification requirements for UASs and find that my recommendation in lieu of non-published FAA guidance is a viable option in accepting systems produced pre/post non FAA approved quality system. I would like to add that I have learned much and look forward to continuing my MAS/UAS education as time permits.

Abstract
Current unmanned aerial systems (UASs) are built to satisfy customer requirements, most not all, are built to military specifications. However, none of these UASs are manufactured by or under an approved quality system, with approved parts or processes. The manufacturers rely on parts and materials that are often referred to as commercial off the shelf parts (COTS). COTS parts have not yet proven to have a level of airworthiness (i.e., safety) to allow for commercial operation of UAS within the National Airspace System (NAS). Currently, Federal Aviation Regulations (FARs) have not yet been established to address this critical issue. The intent of this paper is to show how the implementation of FARs will assure the airworthiness of UAS for commercial use in the NAS.

Summary
In November of 2012, the Federal Aviation Administration (FAA) published the FAA Modernization and Reform Act of 2012 (Final, 2012).Within the Reform Act, Sect 332. Integration of Civil Unmanned Aircraft System (UAS) into National Airspace System (NAS), addressed specific aspects regarding certification issues regarding UAS stating, “Providing airworthiness approval for sUAS will require careful analysis and consideration of which certification rules may be used to expeditiously approve the vehicles. We will review the current processes that have been used or are currently in use to approve sUAS” (Final, 2012, p. 5). However, since there are currently no regulations that specifically address the type –certification approvals of unmanned aerial vehicles (UAV)s or their supporting systems, it was clear that the special evaluation teams of the FAA would have to call upon their knowledge and skills to develop hybrid approvals scaled to UAS needs which could allow limited commercial operations (Final, 2012).
The absence of standards, regulations and procedures to govern the safe integration of civil-use for UAS into civilian air space are key factors limiting growth in the non-military UAS sector (Chesebro, 2011). In the short-term, existing military UAS manufacturers likely will dominate civil-use UAS markets if they are able to leverage their capabilities and technologies in the adaptation of existing platforms or development of new systems for civil purposes (Chesebro, 2011). Meanwhile operation of small civil UAS in the USA is as a model aircraft (Austin, 2010).
Key to any domination of market access and sustainability is having an understanding of that market. Recently, it was noted by an FAA program office, during type certification of two UAS projects, that both applicants lacked a clear understanding of the certification requirements necessary for type-certification of UAS for commercial purposes in the NAS. This misunderstanding was due in part to the applicants (manufacturers) impression that because they had an operating platform approved/accepted by the military, it must clearly meet the requirements of the FAA. Clearly neither applicant had an understanding of the requirements needed for the market, operating commercial UAS in the NAS. Since there are no clear UAS Federal Aviation Regulations currently defined, this case analysis will address those that are in place for manned aircraft. It is from these proven safety rules that UAS guidance will be derived.

Issue Statement
Current unmanned aerial systems are designed and built to satisfy customer requirements, most not all, are built to some international standard or military specification. In 2001, a report was generated by the FAA that specifically addressed aspects of commercially off the shelf (COTS) parts in airborne software. The intent of the report was to provide findings about the state of the industry relative to the design objectives identified in guidance document DO-254 and to focus on the implications for the use of COTS electronic hardware components in safety critical airborne systems (Thornton, 2011). The report addressed how the use of complex electronic hardware components in airborne systems poses a challenge to the meeting of safety requirements because, for complex components, complete verification is, at best, very difficult and, at worst, not achievable (Thornton, 2011).
And yet, these manufacturers rely on parts and materials that are often referred to as COTS parts. However, none of these UASs are currently manufactured by a Federal Aviation Administration (FAA) approved facility, to an approved type design with an FAA approved quality system, rarely using approved parts or processes. It should be noted that a primary responsibility of the FAA is to ensure the safe design and operation of the system(s) are established prior to issuance of the Certificate of Airworthiness (Austin, 2010).

Significance of Issue
UAS come in a variety of shapes and sizes and serve diverse purposes (Dorr, 2013). Whether it be their military use in the dull, dirty and dangerous applications of reconnaissance, surveillance and the technologically improved realization of weapons delivery, to that of the civilian/commercial roles that were discussed in R. Austin (2010) Unmanned Aircraft Systems UAVS Design, Development and Deployment such as aerial photography, agricultural applications, ranching, monitoring of coastlines, customs, conservation, and used by public service and power companies the list of applications continues to grow. Regardless of size, the responsibility to fly safely applies equally to manned and unmanned aircraft operations (Dorr, 2013). Equally the responsibility for manufacturers to establish processes and procedures must be in place to prevent injury to persons, animals, and damage to property due to failures of the UASs and also to prevent injury or damage caused by collisions between UAV and other airborne vehicles in the NAS (Austin, 2010).
In 2013, the FAA published their UAS Roadmap, wherein they proclaim their proven certification process for aircraft that includes establishing special conditions when new and unique technologies are involved (First, 2013). Also further establishing, in those parts of the NAS that have demanding communications, navigation, and surveillance performance requirements, successful demonstration of UAS to meet these certification criteria will be necessary (First, 2013). It should be understood however, that those demands for UAV operating within the NAS are primarily for these systems operating within the vicinity of other vehicles and have yet to be defined for those smaller or small unmanned aerial systems (sUAS) operating within Class G airspace. This low-lying airspace does not require communications with air traffic control and is of little concern to larger aircraft, thus, there are few regulations that apply to craft in this airspace.
These sUAS will undoubtedly find a niche in civil operations within this segment of the NAS. Unlike the manned aircraft industry, the UAS community does not have a set of standardized design specifications for basic UAS design that ensures safe and reliable operation in typical civilian service applications (First, 2013). This can also be interpreted to say that currently the UAS community has not been regulated in certification for commercial (civil) operation in the NAS.

sUAS
“Except for some special cases, such as small UAS (sUAS) with very limited operational range, all UAS will require design and airworthiness certification to fly civil operations in the NAS” (First, 2013, pg. 13). A case can be made that sUAS will not be regarded in the same light as that of the larger UAS that require more robust systems and operate using full-on navigation, communication, ground control stations (GCSs), launch & recovery systems, support equipment/personnel and transportation as required. This analysis being made, sUAS operating within the Class G airspace may very well be operating within line-of-sight (LOS) capabilities only. By comparison, the system configuration of larger UAS may provide capabilities for beyond-LOS or BLOS. The certification of which would require written guidance and regulatory oversight equal to that of manned aircraft today, but has yet to be fully developed and released. Without any clear UAS regulatory guidance for the FAA certification teams and the operator to refer to, it will require that both parties work together to ensure the safe design and operation of the system to issue the Certificate of Airworthiness for the complete system once it has been determined that the system meets its requirements for safety and is deemed airworthy (Austin, 2010). Manufacturers in the aviation industry not yet certified by the FAA rely on International quality systems recognized within the industry in hopes of having their product standout among competitors not having any quality rating(s) what so ever.

Quality Standards
Before the Federal Aviation Regulations (FARs) can be presented which define the requirements in establishing a manufacturing quality system some of the more prominent quality standards often misinterpreted as being acceptable in meeting FAA manufacturing regulatory requirements must first be reviewed.
ANSI
One of the more common standards used in manufacturing, the American National Standards Institute (ANSI) is a private non-profit organization that oversees the development of voluntary consensus standards for products, services, processes, systems, and personnel in the United States (Wiki, 2013). This organization ensures the overall specifications and operations of products are consistent, that people use the same definitions and terms, and that products are tested the same way (Wiki, 2013). ANSI also performs audits and subsequent accreditation of those found to be in conformance to standards – including globally-recognized cross-sector programs such as the ISO 9001 (quality) and AS 9100 management systems (ANSI, 2013).
COTS
“A commercial-off-the-shelf (COTS) product is a software system that can be adapted to the needs of different customers without changing the source code of the system.” (Hashmi, 2012, pg.1). To expand the definition, COTS can be either software or hardware and consists of the following articles; Operating Systems, Databases, Graphics Packages, Busses, Processors, Disk Drives and Peripherals (Hashmi, 2012). To many sUAS manufacturers, a COTS product is a quick and cost effective answer in R&D parts procurement for their operating platform. Unfortunately, they are also under the impression that COTS parts are built to an acceptable quality standard. As previously discussed and to be outlined further, unless COTS parts are presented by the original equipment manufacturer (OEM) as part of the original design package submitted for Type –Certification, and found to be airworthy, they do not fall under the FAA approved quality system for which the sUAS is manufactured and no quality controls for the manufacturer of the COTS have been established. However, in meeting the lowest bidder/quickest to develop requirements of everyday government bids the enticement to use COTS parts cannot be overlooked as they do provide the following benefits 1) as with other types of reuse, more rapid deployment of a reliable system may be possible 2) Other companies may already use the applications so experience of the systems is available. 3) Some development risks are avoided by using existing software 4) Businesses can focus on their core activity without having to devote a lot of resources to IT systems development 5) As operating platforms evolve, technology updates may be simplified as these are the responsibility of the COTS product vendor rather than the customer (Hashmi, 2012). Of course there are always problems associated with benefits attributed to shortcuts to design and development costs, some of the more significant issues might be 1) The COTS product may be based on assumptions that are practically impossible to change. The customer must therefore adapt their business to reflect these assumptions. 2) Choosing the right COTS system for an enterprise can be a difficult process, especially as many COTS products are not well documented. Making the wrong choice could be disastrous as it may be impossible to make the new system work as required. (It should be noted that this particular issue is primarily due to the COTS being manufactured in an uncontrolled quality environment, not something that a UAS manufacturer wants to have introduced into their system and have commercially flown in the NAS) 3) The COTS product vendor controls system support and evolution. They may go out of business, be taken over, or may make change that cause difficulties for customers (Hashmi, 2012). Bottom line, “If the vendor is unable to keep up with client problems, system bugs, or closes shop, the early savings can easily become an unexpected expense” (JSC, 2013).
Mil-Spec
What are military specifications (mil-spec)? Quite simply, they’re standards established for defining essential technical requirements of purchased materiel for the military or for substantially modified commercial items to be used by the military (MAC, 2013). These standards have been established to guarantee interoperability, commonality, reliability and cost of ownership to ease the strain on logistics systems, but they fail to meet the stringent standards set forth by the FAA in establishing that an article or product is indeed deemed airworthy (MAC, 2013). What mil-specs aren’t are a guarantee the product defined is the absolute best that it can be in terms of materials used or processes used for manufacturing (MAC, 2013). So why do we have Mil-Spec? To put it in context; for those UAS that have been accepted by the military or a civilian operator and certified to Mil-Spec standards it allows for the interchangeability of one UAV wing to be installed on another UAV system. But that doesn’t mean that it has gone thru the rigorous certification testing required of a type-certification program conducted under the auspice of an FAA approved quality system.
ISO 9001
“The ISO 9001 family addresses various aspects of quality management and contains some of ISO’s best known standards. The standards provide guidance and tools for companies and organizations who want to ensure that their products and services consistently meet customer’s requirements, and that quality is consistently improved” (ISO, n.d.). Within any quality system proper documentation is the key. For example, has the engineering department properly annotated the drawing title block to include company name, address, tolerances, notes, page, engineers by name, hierarchy and of course revision letter of the latest approved drawing applicable to the title block? How this is done is defined by the company’s internal quality processes and procedures, International Standardization of Organization (ISO) 9001 a documentation scheme is an accredited International Quality Management System (QMS) that provides written procedures for all aspects of the product development and manufacturing processes to include engineering documentation (Webb, 2001). Initial and renewal ISO 9001 accreditation is achieved by external audits performed annually, by qualified International examiners. Their primary focus is on the manufacturer’s quality system (Webb, 2001). A common quality slogan in industry is “Say what you do and do what you say.” In other words, document what you actually do, and then do what you wrote down (Webb, 2001). In situations where safety is an issue, such as reviewing quality systems where unmanned systems are manufactured, the manufacturer must remember that the auditor has been trained to go by the book (Webb, 2001). Given the unchartered territory with which the UAS may operate the manufacturer should count on it. Company and regulatory personnel together must identify and establish the safety-mark effort, but R&D, manufacturing, purchasing, distribution, quality control, and field service must all work as a team for the effort to be successful (Webb, 2001). The R&D group needs to design products, components or subassemblies whenever possible, far too often this group relies on those products already developed and classified as COTS parts. It is when COTS parts are used in the system that the component must be flagged and evaluated by compliance and agency personnel creating unknown variables in the continued airworthiness of the part (Webb, 2001). It has been shown that manufacturers that have a robust quality system in place save both time and money (Webb, 2001).
AS9100
AS9100 was developed in a supporting role to ISO 9001 by addressing the additional expectations of the aerospace industry (Barker, 2002). AS9100 requirements are established to be complementary to contractual and applicable law and regulations. Those implementing a quality system compliant with AS9100 must ensure that the additional requirements of their customers, regulatory agencies (such as the FAA and the JAA) and local, state and national laws are also referenced within the system’s documentation (Barker, 2002). The AS9100 standard includes extensive supplementation in design-and-development functions. Design outputs are supplemented to provide identification of key characteristics, and the data essential for the product that will be identified, manufactured, inspected, used and maintained is detailed.
Aspects of AS9100 and key components of Product Safety and Quality Control are clearly described by Barker (2002):
Manufacturing a product as sophisticated as an airplane or space vehicle requires special attention during the production processes. It’s important, for example, to ensure that the correct revision of the engineering documentation is being used and documented within the work instructions, and that work performance is recorded. Controlling production processes is essential to demonstrate that operations have been correctly performed. This is especially important when conducting special processes that don’t lend themselves to after-the-fact inspection techniques.
The industry frequently relies upon tooling and other production equipment, including computer-controlled machines, to fabricate and assemble products. This equipment often forms the basis for product acceptance. In these cases, it’s essential to demonstrate the integrity of these tools and machines and to develop a process that will ensure adequate oversight of the entire process.
Aircraft are designed to perform for 50 years or more, and properly maintaining the aircraft is essential for continued safe operation. Thus, servicing requirements are an important part of the total quality system. These include maintenance and repair manuals as well as the actual servicing work. Again, record-keeping is important in documenting the work performed, the equipment used and the people doing the work.
Some products require traceability of a part or all of their components. This requirement may be imposed by contract, regulatory agency or internal need. In any case, AS9100 provides the essentials of an effective traceability program.
Using measuring devices of known accuracy–and this may include computer-assisted measuring and test equipment–is essential in the verification process. Maintaining a calibration history of this equipment and documented proof that it’s reviewed and verified periodically underlies the entire metrology system.
Detailed first-article inspections are frequently performed to demonstrate product conformance to engineering requirements. Documenting the actual inspection and test results is an established method of demonstrating initial item acceptance.
When things don’t go as planned, AS9100 gives directions for controlling and disposing nonconforming material. This includes specific requirements for contacting the customer for authorization when using or repairing a product that doesn’t conform to engineering requirements (pg. 2).
As can be seen, the requirements within AS9100 are very thorough. In so doing it enforces a quality atmosphere of the manufacturer that allows for the traceability of materials, parts, appliances, products, aircraft, engines and or propellers from “womb to tomb”. It is by far the closest non regulatory certification that encompasses those quality control requirements of Part 21.

FARs
Although not explicitly stated, certain Federal Aviation Regulations (FARs) have been written that require civil aircraft (i.e., aircraft not flown for military/public use) be properly certified in order to operate in the NAS for commercial purposes. These FARs as presented below are interpreted in the context of promoting aviation safety to ensure that only those civil aircraft, properly certified, are found to be airworthy. In the case of UAVs, this interpretation includes those supporting UASs essential for the safe operation of the civil aircraft or UAV.
Since an airframe cannot fly until it is built, an analysis of the regulatory requirements of the manufacturing quality system should be of first order.
Part 21
Part 21-Certification Procedures for Products, Articles, and Parts, will show the certification requirements of an aircraft found to be airworthy and approved to operate as a civil aircraft in the NAS. Excerpts from Part 21 are taken from the following reference: Sec. 21.1, (Apr 16, 2011).
Sec. 21.1 Applicability
(b) For the purposes of this part--
(1) Airworthiness approval means a document issued by the FAA for an aircraft, aircraft engine, propeller, or article which certifies that the aircraft, aircraft engine, propeller, or article conforms to its approved design and is in a condition for safe operation;
(2) Article means a material, part, component, process, or appliance;
(3) Commercial part means an article that is listed on an FAA-approved Commercial Parts List included in a design approval holder's Instructions for Continued Airworthiness required by Sec. 21.50;
(4) Design approval means a type certificate (including amended and supplemental type certificates) or the approved design under a Part Manufacturer Approval (PMA), Technical Standard Order (TSO) authorization, letter of TSO design approval, or other approved design;
(5) Product means an aircraft, aircraft engine, or propeller
Subpart G Production Certificates
Sec. 21.135
Requirements for issuance.
An applicant is entitled to a production certificate if the Administrator finds, after examination of the supporting data and after inspection of the organization and production facilities, that the applicant has complied with Secs. 21.139 and 21.143.
Sec. 21.139
Quality control.
The applicant must show that he has established and can maintain a quality control system for any product, for which he requests a production certificate, so that each article will meet the design provisions of the pertinent type certificate
Sec. 21.143
Quality control data requirements; prime manufacturer.
(a) Each applicant must submit, for approval, data describing the inspection and test procedures necessary to ensure that each article produced conforms to the type design and is in a condition for safe operation, including as applicable--
(1) A statement describing assigned responsibilities and delegated authority of the quality control organization, together with a chart indicating the functional relationship of the quality control organization to management and to other organizational components, and indicating the chain of authority and responsibility within the quality control organization;
(2) A description of inspection procedures for raw materials, purchased items, and parts and assemblies produced by subsidiary manufacturers, including methods used to ensure acceptable quality of parts and assemblies that cannot be completely inspected for conformity and quality when delivered to the prime manufacturer's plant;
(3) A description of the methods used for production inspection of individual parts and complete assemblies, including the identification of any special manufacturing processes involved, the means used to control the processes, the final test procedure for the complete product, and, in the case of aircraft, a copy of the manufacturer's production flight test procedures and check off list;
(4) An outline of the materials review system, including the procedure for recording review board decisions and disposing of rejected parts;
(5) An outline of a system for informing company inspectors of current changes in engineering drawings, specifications, and quality control procedures; and
(6) A list or chart showing the location and type of inspection stations.
(b) Each prime manufacturer shall make available to the Administrator information regarding all delegation of authority to subsidiary manufacturers to make major inspections of parts or assemblies for which the prime manufacturer is responsible.
Sec. 21.175 Airworthiness certificates: classification
(a) Standard airworthiness certificates are airworthiness certificates issued for aircraft type certificated in the normal, utility, acrobatic, commuter, or transport category, and for manned free balloons, and for aircraft designated by the [FAA] as special classes of aircraft.
(b) Special airworthiness certificates are primary restricted, limited, light-sport, and provisional airworthiness certificates, special flight permits, and experimental certificates.
Part 91 General Operating and Flight Rules
Sec. 91.7 Civil aircraft airworthiness
(a) No person may operate a civil aircraft unless it is in an airworthy condition.
(b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur
Sec. 3.5 Statements about products, parts, appliances and materials
(a) Definitions. The following terms will have the stated meanings when used in this section: Airworthy means the aircraft conforms to its type design and is in a condition for safe operation
(d) The provisions of §3.5(b) and §3.5(c) shall not apply if a person can show that the product is airworthy or that the product, part, appliance or material is acceptable for installation on a type-certificated product
Expectations
Sub sec. 21.1 states that products such as aircraft, engine, propeller or articles are deemed airworthy if found to conform to their approved design and are in a condition for safe operation and that design approval has been issued under a type certificate (including amended and supplemental type certificates) or the approved design under a Part Manufacturer Approval (PMA), Technical Standard Order (TSO) authorization, letter of TSO design approval, or other approved design. Having established the basis of what a product is and the requirement for the design approval the requirements can now be clarified in how to proceed in presenting the approved design and apply for application to produce on the basis of having an approved quality system. Sub sec. 21.135 states that an applicant is entitled to a production certificate if the FAA finds that they have complied with 21.139 and 21.143. Both of which are clear requirements for an approved quality system.
The expectation of the general public and even those that enforce the FARs in the interest of safety for that of UAS commercial operation in the NAS, is that the FAA will publish rules and regulations similar to those of manned commercial aviation. Certain limitations or exemptions to the current rules will have to be taken into account due to the nature of the unmanned systems. While the expanded use of UAS presents great opportunities, it also presents significant challenges as unmanned aircraft systems are inherently different from manned aircraft (JPDO, 2013, pg.6). The FAA recently published their UAS Comprehensive Plan and UAS Roadmap 2013. The UAS Comprehensive Plan sets the overarching, interagency goals, objectives, and approach to integrating UAS into the NAS (JPDO, 2013, pg. 3). What the Comprehensive Plan does not do is supersede current government rules and regulations. All Government agencies in coordination with developing UAS policy will comply with their own processes, policies, and standards regarding airworthiness, pilot, aircrew and maintenance personnel certification and recurrent training (JPDO, 2013, pg. 9). This particular statement requires additional clarification, wherein it references standards regarding airworthiness, this is specific to certification requirements or what has been discussed, approved quality systems.
Although aviation regulations have been developed generically for all aircraft, until recently these efforts were not done with UAS specifically in mind. This presents certain challenges because the underlying assumptions that existed during the previous efforts may not now fully accommodate UAS operations. As an example, current regulations address security requirements for cockpit doors. However, these same regulations lack a legal definition for what a “cockpit” is or where it is located. This presents a challenge for UAS considering that the cockpit or “control station” may be located in an office building, in a vehicle, or outside with no physical boundaries. Applying current cockpit door security regulations to UAS may require new rulemaking, guidance, or a combination of both (First, 2013, pg.16).
While the FAA develops special permits to allow operations in the NAS, current airworthiness standards can be considered for type certification. In the long-term, UAS that are designed to a standard and built to conform to the design may be integrated into the NAS as fully certificated aircraft (First, 2013, pg. 22). Provided the long term still requires an approved quality system.
Detailed consideration of UAS in the certification process will be limited in number until such time as a broad and significant consideration is given to existing standards, regulations, and policy. This will be facilitated by UAS manufacturers making application for type design approval to the FAA. For type design approval, UAS designers must show they meet acceptable safety levels for the basic UAS design, and operators must employ certified systems that enable compliance with standardized air traffic operations and contingency/emergency procedures for UAS. Because the UAS community is well established under its current operational assumptions, it is unlikely the FAA or UAS industry will establish an entire set of design standards from scratch. As additional UAS airworthiness options are considered and UAS airworthiness design and operational standards are developed, type certification may be more efficiently and effectively achieved (First, 2013, pg. 26).

Alternative Actions
There will be incremental increases in NAS access based on rigorous safety mitigations of current UAS that were previously developed and built without approved industry or governmental standards (First, 2013). The FAA has initiated the development of a Special Federal Aviation Regulation (SFAR) to govern operation of low-flying sUAS within visual line-of-sight that are used for commercial purposes. The SFAR will provide a process for sUAS to operate in the NAS under low-risk conditions without undergoing the case-by-case approval process that is currently required. Such guidance could enable sUAS users to initiate or continue operations that do not present a safety threat to the public or to other aircraft prior to the finalization of complete certification regulations for all classes of UAS (Chesebro, 2011). Experimental certificates and COAs will always be viable methods for accessing the NAS, but typically come with constraints and limitations and do not allow for commercial operation (First, 2013).
Having presented some of the basic quality standards for which current UAS are developed both for the military and public operations and having presented the current regulatory requirements for manned aircraft to be considered airworthy, Type-Certified and issued an Airworthiness Certificate. It should be apparent that before any sUAS makes application for civil operations in the NAS, they must have been manufactured and subsequently certified under an FAA approved Quality System. Certification of UAS will evolve as future technologies evolve and will be consistent with other aircraft airworthiness and operational approval processes, adding platform capabilities to the UAS through data analyses and trending, which will identify areas for change and improvement in operations, human factors, communication links, and maintenance (First, 2013).

Recommendation
“Because the UAS community is well established under its current operational assumptions, it is unlikely the FAA or UAS industry will establish an entire set of design standards from scratch. As additional UAS airworthiness options are considered and UAS airworthiness design and operational standards are developed, type certification may be more efficiently and effectively achieved” (First, 2013, p. 26). In meeting the anticipated growth for commercial UAS operation in the NAS within the next five years, the FAA might consider it beneficial to fast track those sUAS applicants that hold dual accreditation in ISO 9000 / AS9100. By virtue of their accreditation alone, those facilities would have data to substantiate the viability of their systems and might possibly bypass the regulatory requirement of establishing an approved quality system before any and all products produced are presented to the FAA and deemed airworthy. Unfortunately, this recommendation can only be viewed as just that, by a student of MAS/UAS studies that knows that the regulatory bureaucracy takes forever and is made by decisions that go well beyond the scope of what can be analyzed here. In closing, The FAA expects to gain experience in applying the existing airworthiness regulations during the type certification process with early UAS adopters and by taking into account industry and Aviation Rulemaking Committee (ARC) inputs, and future experience with UAS type certification projects, the FAA will review and revise as necessary the existing airworthiness regulations to ensure UAS safety (First, 2013).

References
ANSI (2013) About ANSI Overview Retrieved from http://www.ansi.org/about_ansi/overview/overview.aspx?menuid=1
Austin, R. (2010). Unmanned Aircraft Systems: UAVS Design, Development, and Deployment. Chichester, West Sussex, U.K: Wiley.
Barker E. M. (2012) Aerospace’s AS9100 QMS Standard Retrieved from http://www.qualitydigest.com/magazine/2002/may/article/aerospaces-as9100-qms-standard.html#
Chesebro, J (2011) Unmanned Aircraft Systems (UAS) Retrieved from http://www.trade.gov/mas/manufacturing/oaai/build/groups/public/@tg_oaai/documents/webcontent/tg_oaai_003781.pdf
Code of Federal Regulations (Amdt. 3-1, Eff. 10/17/2005) Part 3 General Requirements Sec. 3.5 Statements about products, parts, appliances and materials Retrieved from http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgFAR.nsf/0/9C6DBA5E134BF637862575BB006D1CBD?OpenDocument
Code of Federal Regulations (n.d.) Part 91 General Operating and Flight Rules Sec. 91.7 Civil aircraft airworthiness Retrieved from http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgFAR.nsf/0/27865155C48434A6852566CF00612316?OpenDocument
DARC (2013) Drones & Aerial Robotics Conference Law & Policy Guidebook Retrieved From https://droneconference.org/darc2013_guidebook.pdf
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Final (2012) Expanding Use of Small Unmanned Aircraft Systems in the Arctic Implementation Plan FAA Modernization and Reform Act of 2012 Retrieved from http://www.faa.gov/about/initiatives/uas/media/sUAS_Arctic_Plan.pdf
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JPDO (2013) Unmanned Aircraft Systems (UAS) Comprehensive Plan a Report on the Nation’s UAS Path Forward Retrieved from http://www.faa.gov/about/office_org/headquarters_offices/agi/reports/media/UAS_Comprehensive_Plan.pdf
JSC Group (2013) Commercial off the Shelf Retrieved from http://www.jscgroup.com/commercial-off-the-shelf.html
MAC (2013) The Infamous MIL-SPEC Standard Retrieved from http://www.thebangswitch.com/the-infamous-mil-spec-standard/
Sec. 21.1 (Apr 16, 2011) Part 21 Certification Procedures for Products, Articles, and Parts Retrieved from http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgFAR.nsf/0/D503D14EB7344D10862576E4004C7642?OpenDocument
Thornton, R.K., (2001), DOT/FAA/AR-01/41 Review of Pending Guidance and Industry Findings on Commercial off-the-Shelf (COTS) Electronics in Airborne System, Retrieved from http://www.faa.gov/aircraft/air_cert/design_approvals/air_software/media/01-41_COTS.pdf
Webb W.D., (2001) Creating and Maintaining Safety-Agency Reports Retrieved from http://www.ce-mag.com/archive/01/09/webb.html
Wikipedia (2013) American National Standards Institute Retrieved from http://en.wikipedia.org/wiki/ANSI