Special Airworthiness Certificates for UAS: Choosing the Right Experimental Category Purpose

A special airworthiness certificate in the experimental category authorizes a UAS to operate outside 14 CFR Part 107 when the aircraft does not have a type certificate. Issued under 14 CFR §21.191, it must specify one of six eligible purposes: research and development, showing compliance with regulations, crew training, exhibition, market surveys, or operating amateur-built or kit-built aircraft. The certificate is governed for UAS by FAA Order 8130.34D and applied for using FAA Form 8130-7. Each purpose carries distinct operating limitations.

For UAS operators whose missions exceed the bounds of 14 CFR Part 107 and for manufacturers who have not yet completed type certification the special airworthiness certificate in the experimental category is one of the most flexible regulatory tools available. It allows a UAS that does not yet have a type certificate to operate lawfully in the National Airspace System for a defined purpose, under operating limitations established by the FAA on a case-by-case basis.

This article walks through the experimental category framework as it applies to UAS, the six eligible purposes available to applicants, the documents that drive the application, and the operating limitations applicants should expect.

The regulatory framework

Special airworthiness certificates are established in 14 CFR Part 21, Subpart H specifically §21.171 through §21.197. The experimental category sits in §21.191 and lists the eligible purposes for which an experimental certificate may be issued. For UAS specifically, FAA Order 8130.34D establishes the procedures aircraft certification staff use when evaluating applications and issuing certificates.

The order is important. Unlike type certification, where the certification basis is established formally through Project Specific Certification Plans and ACO coordination, the experimental airworthiness certificate process is more procedural. The applicant submits Form 8130-7 along with supporting documents; the FAA evaluates the submission; operating limitations are negotiated; and the certificate is issued for a defined duration.

For background on how the experimental certificate path fits within the broader UAS certification landscape including the §21.17(b) special class type certification route see our post on Part 21.17(b) special class certification.

The six eligible purposes

Under §21.191, an experimental airworthiness certificate may be issued for the following purposes. Each carries distinct operational scope, and applicants must select the purpose that aligns with their actual planned operations.

1. Research and development

This is the most commonly used purpose for UAS operators developing new platforms, sensors, payloads, or operating concepts. It authorizes operations conducted to investigate new technology, test new equipment installations, evaluate new operating techniques, or determine whether a concept warrants further development.

Typical R&D operations include flight testing of new airframe configurations, payload integration testing, autonomy and detect-and-avoid algorithm validation, and durability testing in support of a subsequent §21.17(b) type certification application.

2. Showing compliance with regulations

When an applicant has revised the type certificate design data, applied for a supplemental type certificate, or is supporting a §21.17(b) certification campaign, an experimental certificate may be issued specifically to conduct the flight testing required to demonstrate compliance.

This purpose is procedurally narrow. The operations conducted must directly support the certification finding being pursued. Applicants should expect operating limitations to be tightly drawn around the specific compliance objectives.

3. Crew training

This purpose authorizes training of the applicant’s flight crews for UAS, the remote pilots, payload operators, and visual observers in the experimental aircraft. It is most often used by manufacturers training their internal personnel ahead of type certification flight testing, or by operators training crews in a specific aircraft configuration that will subsequently be flown for other authorized purposes.

The certificate does not authorize training of third-party customers. For that, a market survey purpose may be more appropriate.

4. Exhibition

Exhibition authorizes operation of the UAS to demonstrate flight capabilities, performance, or unusual characteristics at air shows, for motion pictures or television, and for maintenance of exhibition flight proficiency. For UAS, exhibition is occasionally used by manufacturers and operators participating in industry events and trade shows.

5. Market surveys

This is one of the more useful purposes for UAS manufacturers. It authorizes operations to conduct market surveys, sales demonstrations, and customer crew training for U.S. manufacturers of aircraft or engines. A manufacturer can use this purpose to fly the aircraft for prospective customers, train customer personnel, and gather market feedback before pursuing full type certification.

The eligibility is constrained to U.S. manufacturers of aircraft or engines, and the supporting documentation must establish that the applicant qualifies.

6. Operating amateur-built or kit-built aircraft

This purpose is generally inapplicable to commercial UAS development. It exists primarily for the manned amateur-built and kit-built aircraft community.

For an overview of how the experimental airworthiness certificate process applies specifically to large UAS and advanced operations, see our post on certification paths for large drones and advanced operations.

The application package

A complete application under FAA Order 8130.34D typically includes:

• FAA Form 8130-7, Application for U.S. Airworthiness Certificate, specifying the purpose sought

• A program letter describing the proposed program, objectives, and operational concept

• A flight test plan or operations description, depending on the purpose

• System description documents covering the airframe, propulsion, command and control link, ground control station, and any associated infrastructure

• A risk assessment identifying hazards, mitigations, and the proposed operating area

• Operating limitations drafted by the applicant for FAA review

The FAA treats the UAS as a system the aircraft, ground control station, datalink, and supporting infrastructure are evaluated together. Multiple aircraft controlled from a single ground station may be certificated under one application, depending on the specific configuration.

What to expect during the evaluation

After application submission, the applicant participates in a safety evaluation with FAA representatives. This may include Aviation Safety Inspectors, the responsible Manufacturing Inspection District Office or Manufacturing Inspection Satellite Office, specialists from the UAS Integration Office, and, in many cases, a Designated Airworthiness Representative authorized to issue the certificate. The evaluation may be conducted in person or by teleconference.

Applicants typically receive action items following the evaluation clarifications to documentation, refinements to operating limitations, additional supporting analysis. Once these are resolved and the operating limitations are accepted by all reviewing offices, the certificate is issued.

The operating limitations are the operational heart of the certificate. They define the geographic boundaries within which the aircraft may operate, the altitudes permitted, the personnel requirements, the conditions under which the aircraft may be flown, and any additional constraints the FAA considers necessary for safe operation. Applicants should expect these limitations to be specific and to require ongoing compliance throughout the certificate’s duration.

How Martin Solutions supports applicants

Martin Solutions prepares experimental airworthiness certificate applications for UAS programs across the research, certification, and commercial spectrum. Our work includes drafting the program letter and operations description, preparing the system documentation, conducting the supporting risk assessment, drafting operating limitations for FAA review, and coordinating with the responsible FAA offices throughout the evaluation.

For full details on this work, see our airworthiness certificate services page. For applicants pursuing experimental certificates as part of a longer-term type certification campaign, our FAA airworthiness certification services page describes the broader certification workflow.

Frequently Asked Questions

How long does an experimental airworthiness certificate take to obtain?

Timelines vary significantly based on the complexity of the operation, the completeness of the application, and the workload of the reviewing FAA offices. Well-prepared applications for straightforward operations may be processed in two to three months. Complex applications involving novel operations, large aircraft, or unusual operating environments can take six months or longer.

How long is the certificate valid?

Experimental airworthiness certificates for UAS are typically issued for a one-year duration, though shorter or longer durations may apply depending on the purpose and operational scope. Renewals are available through a re-application process before expiration.

Can I conduct commercial operations under an experimental certificate?

Generally, no. Experimental certificates do not authorize carrying persons or property for compensation or hire. Commercial operations conducted for compensation typically require either Part 107 authorization, a §44807 exemption with appropriate operational authorization, or operation of a type-certificated aircraft under a standard airworthiness certificate.

What is FAA Order 8130.34D?

FAA Order 8130.34D is the FAA’s procedural guidance for special airworthiness certification of UAS and optionally piloted aircraft. It describes the application process, the documentation required, the evaluation procedures used by FAA staff, and the standard operating limitations applied to UAS experimental certificates.

Who can issue an experimental airworthiness certificate?

FAA Aviation Safety Inspectors, Manufacturing Inspection District Office or Manufacturing Inspection Satellite Office staff, and Designated Airworthiness Representatives authorized for the experimental category may issue these certificates, depending on the specific aircraft and the issuing office’s procedures.

Can the experimental certificate cover multiple aircraft?

Yes, when the application is structured to address multiple aircraft as a single system for example, multiple aircraft of identical configuration controlled by the same ground control station. The FAA evaluates this on a case-by-case basis depending on the configuration and the proposed operations.

Does an experimental certificate allow BVLOS operations?

The certificate itself does not directly authorize BVLOS. Operations beyond visual line of sight typically require either a waiver under Part 107, a §44807 exemption with specific BVLOS authorization, or once the rule is final operations under Part 108. The experimental certificate authorizes the aircraft to operate; the operational authority for BVLOS comes from a separate regulatory mechanism that the applicant typically pursues in parallel.

How does the experimental certificate relate to type certification?

For UAS pursuing type certification under §21.17(b), an experimental certificate is often used during the development and flight testing phases — particularly under the “showing compliance with regulations” purpose. The experimental certificate authorizes the aircraft to fly while the certification program proceeds, with the eventual goal of transitioning to a standard airworthiness certificate once the type certificate is issued.

Bottom line

The experimental airworthiness certificate is one of the most operationally flexible authorizations available to UAS operators who need to fly outside Part 107. Selecting the right purpose under §21.191 and supporting that selection with documentation that matches the actual planned operations determines whether the certificate is issued promptly and whether the resulting operating limitations match the program’s needs.