(Source: uasvision.com)
The FAA UAS Integration Office issued an email to the industry outlining the requirement for all commercial UAS to bear an aircraft registration number when applying for a COA:
UAS, other than those owned by the Armed Forces, intended to operate under a new COA must be registered and marked prior to COA application. The aircraft registration number (N-number) must be entered into the “Aircraft Registration” field, of the System Description section in COA on-line.
Additionally, UAS, other than those owned by the Armed Forces, currently operating under an existing COA must be registered and marked within 90 days of the date of this email. COA holders will confirm their aircraft have been registered by entering the registration number, (N-number) in the Monthly Operational Report, in the block labeled, “Describe any other Operational / Coordination Issued”. Failure to comply with the registration requirements within the prescribed timeframe may result in a suspension of the COA.
UAS must be marked with their U.S. nationality and registration marks (N-Number) in accordance with 14 CFR Part 45. The marks must be painted on the aircraft or affixed by any other means ensuring a similar degree of permanence (§45.21(c) (1), General).
Most full scale UAS are able to comply with the marking requirements, including size and location of the N-Number on the aircraft. Sub-scale or small UAS, or UAS of an un-conventional shape such as a multi-rotor (quad-copter, octo-copter, etc.) or ducted fan may not be able to comply with Part 45 or the guidance in AC 45-2D because of size or space limitations on the aircraft. In these cases, 14 CFR, §45.22(d) allows the UAS owner or operator to propose an alternative marking procedure to the FAA. Alternate marking approvals may be issued to public aircraft by FAA UAS Integration Office (AFS-80). If alternative markings were required, a copy of the Alternative Marking approval letter should be attached to application in the “Aircraft Registration” field.
Complete details for registering your UAS and reserving an N-number are provided online at www.faa.gov.
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Alan is serial entrepreneur, active angel investor, and a drone enthusiast. He co-founded DRONELIFE.com to address the emerging commercial market for drones and drone technology. Prior to DRONELIFE.com, Alan co-founded Where.com, ThinkingScreen Media, and Nurse.com. Recently, Alan has co-founded Crowditz.com, a leader in Equity Crowdfunding Data, Analytics, and Insights. Alan can be reached at alan(at)dronelife.com
The FAA has officially “suggested” that UAV operators keep a log of flight times and maintenance so it’s not too hard to read into that message that logs will be required. The rules will need to adjusted to fit UAS, but the rules will remain. It is also clear that the requirements will include passing the PAR written test, 25 hours of flight time verified by flight log, 5 hours in the aircraft intended for use (similar to “ratings” for GA pilots), and registered aircraft. Unlike auto licensing, there is no mention of liability insurance at this point, but it should not be overlooked. AOPA, TransportRisk and others have already started gearing up for UAS insurance. http://www.DronersGuide.com Part of this process satisfies requirements of Homeland Security, for reasons which are becoming more logical all the time.
The drones automatically log flights on website ofr DJI Drones.
There are no obstacles to reserving an N number. However, it appears that is where the road appears to end. Have any of the FAA test sites performed tests on the most common UAS aircraft? Nobody seems to know .
Where did you find that FAA notice? I’m not finding it at FAA.gov, searching for 14 CFR, §45.22(d)
There may be a catch-22 here – In order to request an N number there may be a requirement to list a “certified” aircraft, and as far as I know, none of the common small UAVs have been accepted for certification. What do you have on that?
This is interesting, because it may seem logical that the N-registration will lead to other FAA reporting requirements. The list is extensive for aircraft reporting requirements, and this may be the “barrier of entry” that the FAA and other governmental agencies use when issuing new guidance. Typically, N-registered aircraft are required to keep flight logs, maintenance records and report incidents, such as damage history.