Appendix A: List of Recommendations

Appendix A: List of Recommendations

Recommendations for Standards

• Congress should mandate the FAA to create Federal UAS Safety Standards. • The FAA should charter an ARC and authorize it to identify processes whereby industry standards on safety and SMS become incorporated into Federal UAS Safety

Standards. • The FAA should identify and promulgate a body of foundational safety standards and

SMS for UAS through AC and SAFO processes.

Recommendation for Education and Reference Resources

• The FAA should organize the educational materials it is providing to industry according to testing, pilot certification, and Part 107 waiver submission needs.

Recommendation for Commercial Sales of UAS Components

• The FAA should mandate manufacturers of UAS aircraft and radio control transmitting systems inform the purchaser of regulatory requirements for registration, safe operations, and licensure at the time of purchase.

Recommendation for Cost of Education Testing

• To broaden adoption of safety culture and principals by the UAS community, the

FAA should provide low cost or no cost basic testing through the Basic Part 107 RPC license proposed in this paper.

Recommendation for Cost Recovery

• Similar to recommendations in the GAO-20-136 report, the FAA should further review the recovery of UAS-related costs and establish criteria for future fee designs.

Recommendations for Centers of Excellence

• Congress should fund and the FAA should develop a national institute of UAS safety modeled after the National Highway Institute. • FAA should increase funding of ASSURE programs and prioritize expanding the body of foundational knowledge required by pilot and industry applicants to understand the application of safety culture and SMS. • FAA should fund ASSURE programs which develop Means of Compliance (MoC) that UAS operators may use, and the agency will accept for common Part 107 waiver operations.

Recommendations for Unmanned Aircraft Safety Team (UAST)

• The FAA Administrator should issue a Notice of Order which designates information provided to the UAST as protected from public disclosure. • The FAA Administrator should direct the Drone Advisory Committee (DAC) to identify specific data generated during UAS operations that can be aggregated and

used to identify and reduce safety risks. These data fields should be published for use in a subsequent Advisory Circular. • Congress should fund programs similar to ASAP, FOQA, and ATSAP for collection and analysis of UAS data by the UAST. • Congress should program additional FAA resources to support the ongoing operations and expansion of the UAST.

Recommendation for Use of AC, SAFO, and SORA Frameworks for Safety Culture

• The FAA should issue a series of Advisory Circulars and SAFOs establishing best practices on promoting safety culture and SMS. • The FAA should charter an ARC to provide advice on developing a SORA framework and standard scenarios for commonly sought operations in Part 107 Waivers or

Section 44807 Petitions.

Recommendations for Knowledge Testing

• The FAA should revise UAS knowledge testing to require applicants demonstrate understanding and the ability to apply the principals of safety culture and SMS to common situations they might encounter. • The FAA should align UAS knowledge testing to support a professional development path from ab initio UAS user to professional UAS RPC. • The FAA should develop an Advanced RPC testing framework for commercial delivery operations focusing on demonstrating mastery and application of the fundamentals of safety culture and SMS. • The FAA should align UAS knowledge testing with complexity of aircraft systems and operations. A suggested testing framework is: • TRUST • Part 107 Basic RPC • Part 107 Fixed Wing RPC • Part 107 Crewed RPC • Part 107 Advanced RPC

Recommendations for Licensure, Ratings, and Privileges

• The FAA should revise UAS pilot Licensure, Ratings, and Privileges to create a safety culture and professional development path that scales with increasing complexities of aircraft and operations. • The FAA should create a Part 107 Advanced Commercial pilot license with type ratings for specific uncrewed aircraft.

• The FAA should revise the Part 107 RPC pilot license requirements to include understanding of BVLOS and FPV technologies. It shall include ratings and privileges for UAS operations and fixed winged aircraft.

Recommendation for WINGS

• Congress should fund, and the FAA develop WINGS for UAS operators.

Recommendation for Promoting Safety Culture and SMS

• Congress should incorporate the following provision into 49 CFR Part 107.15,

Condition for Safe Operation: • The FAA should align UAS knowledge testing with complexity of aircraft systems and operations. A suggested testing framework is: • “No person may operate or manufacture a civil unmanned aircraft system unless there is in place a safety management system that is consistent with the standards and recommended practices established by ICAO and contained in annex 19 to the Convention on International Civil Aviation and approved by the FAA Administrator.”

Recommendations for SMS Standards

• The FAA should publish a Notice of Proposed Rulemaking containing a notional framework for SMS for the UAS industry based on previous work done for airlines, airports, and D&M. • The FAA should charter an advisory ARC to identify industry segments and specific

SMS standards that may apply to each industry segment. • The FAA may wish to incorporate the SMS framework proposed in this report in future regulations on safety culture and SMS.