AuthorTimothy M. Ravich
C 7
Before conducting any operations in the National Airspace System (NAS), an
unmanned aircraft system (UAS) operator— public, civil, or hobby/recreational—
must demonstrate that the aircra ft is in a condition for safe operation without undue risk
to other operations in the NAS or to persons and/or property on the ground.1 is is
achieved by obtaining an airworthiness certificate, an FAA document that grants autho-
rization to operate an aircraft in flight.
Notably, under 14 C.F.R. Part 107effective August 29, 2016 (see Chapter 9,
infra)— no airworthiness certification is required for operation of civil unmanned aerial
vehicles (UAVs) weighing under 55 pounds. Air worthiness requirements continue for other
aircraft, including public UAV operations and flight of UAVs weighing over 55 pounds.
is chapter details the various airworthiness regulations that govern such unmanned
I. Airworthiness Certicates: Standard and Special
ere are two different cla ssifications of FAA airwort hiness certificates: sta ndard airworthi-
ness certificates a nd special airworthiness cert ificates. A standard airworthi ness certificate
is the FAA’s official authorization allowing for the operation of type certificated aircraft
in the following categories: normal, utility, acrobatic, commuter, transport, manned free
balloons, and special classes. A standard airworthiness certificate remains valid as long
as the aircraft meets its approved type design; is in a condition for safe operation; and
maintenance, preventative maintenance, a nd alterations are performed in accordance with
14 C.F.R. Parts 21, 43, and 91.2
1 F. A A ., F S  I  M   S, Vol. 16, Unmanne d Aircraft Sys tems,
Chapter 2, § 1, ¶ 16-2-1-3.
2 F. A A ., Standard Airw orthiness Certificate ,
std_awce rt/. (FAA form 8100-2 Displayed in t he Aircraft).
A special airworthiness certificate in the experimental category (SAC-EC) is issued to
operate an aircraft that does not have a type certificate or does not conform to its type
certificate and is in a condition for safe operation.3 Additionally, a special airworthiness
certificate may be issued to operate a prima ry category kit- built ai rcraft that was assembled
without the supervision and quality control of the production certificate holder.4
Special airworthiness certificatesparticularly those in the experimental category—
are of limited utility to civilian UAS operators because they are rarely granted, among
other reasons, due to being issued with accompany ing operational limitations under Title
14 C .F.R . § 91. 319.5 at said, funda mentally, the FA A authorizes the operation of aircraft
in the NAS by way of a special airworthiness certificate (SAC) to eight discrete types of
aircraft: primary, restricted, multiple, limited, light- sport aircraft, special flight permit,
provisional, and experimental.
A. Primary6
Aircraft i n the primary category are of a simple design and intended exclusively for pleasure
and personal use.7 Although these aircraft may be available for rental and flight instruction
under certain conditions, t he carrying of persons or property for hire is prohibited.8 Aircraft
certificated in this category must be manufactured under a production certificate.9 is
includes aircraft assembled from a kit under the production certificate holder’s supervision
and quality control system; however, kit- built aircraft bui lt without the production certificate
holder’s supervision are only eligible for certification in the experimental category.10
B. Restricted11
Operation of restricted category aircraft is limited to special purposes identified in the
applicable type design, including agricu ltur al (spraying, dust ing, seeding, and livestock and
predatory animal control); forest and wildlife conservation; aerial surveying (photography,
mapping, and oil and mineral exploration); patrolling (pipe lines, power lines, and canals);
weather control (cloud seeding); aerial advertising (skywriting, banner towing, airborne
signs, and public address systems); and any other operation specified by the admi nistrator.12
3 F. A  A., Sp ecial Airworth iness Certifica tes, Regulat ions & Policies,
4 F. A  A., Experimental Category,
5 Title 14 C.F.R. § 91.319, “Airc raft having exp erimental certi ficates: Operating L imitations.”
6 F. A  A., Special Airworthiness Certificate—Primar y,
7 Id.
9 Id.
10 Id.
11 F. A  A., Special Airworthiness Certificate—Restricted,
12 See 14 C.F.R. §§ 21.24 and 21.185.
Chapter 7: Airworthiness
C. Multiple13
Under certain circumstances, an aircraft owner may be entitled to multiple airworthiness
certificates.14 Operators may obtain an airworthiness certificate in the restricted category
and in one or more other categories except primary category, upon a showing of compli-
ance with the requirements for each c ategory, when the ai rcraft is configured for that cate-
gory, and when the aircraft can be c onverted f rom one categor y to another by removi ng or
adding equipment by simple mechanical means.15 Once the airworthiness certificates are
issued, the operator of the aircraft is obligated to have the aircraft inspected by the FAA
or a certificated mechanic to determine airworthiness each time the aircraft is converted
from restricted to standard categories.16
D. Limited17
A limited category SAC is issued to operate surplus military aircraft that have been
converted to civilian use under the following conditions: the aircraft has a limited
type certificate; the aircraft conforms to its type certificate; the FAA has determined
that the aircraft is safe to operate; or operations may not include carrying passengers
or cargo for hire.18 e FAA may prescribe additional limitations as necessary for safe
E. Light-Sport Aircraft20
A light- sport aircraft (LSA) category SAC is issued to operate an aircraft that has not
bee n prev ious ly iss ued a n air wort hine ss cer tific ate o r an eq uiva lent a irwo rthi ness cert if-
icate by the United States or a foreign civil aviation authority; is in a condition for safe
operation; was built and tested to the applicable consensus standards by the aircraft’s
manufacturer; and possesses the manufacturer’s statement of compliance.21 Aircraft
classes that are eligible for LSA category SACs include airplanes, gliders, powered
parachutes, weight- shift- control aircraft (commonly called trikes), and lighter- than- air
aircraft (balloons and airships).22
13 F. A  A., Special Airworthiness Certificate—Multiple Airworthiness Certificates,
air_cert/air worthiness_certificat ion/sp_awcert/multiple/.
14 Id.
15 Id.
17 F. A  A., Special Airworthiness Certificate—Limited Category, raft/air_cert/ai rworthiness_
18 Id.
20 F. A A ., Special Airwor thiness Certificat e—Light Sport A ircraft Catego ry,
21 Id.

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