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function and thereby achieving an “equivalent level of safety” (ELOS), comparable to an
aircraft with a pilot onboard. In addition, ROA must be equipped to meet the same airspacespecific
operating requirements as manned aircraft. ROA that do not possess this equipment
may be restricted to certain routes, confined to specified airspace, and restricted to altitudes that
do not provide maximum operational flexibility. Furthermore, the Air Force must develop
standards and procedures for ROA to assure both airworthiness and reliable operating
capabilities.
The following topics are mentioned for informative purposes and provide insight into the
interaction of the military (DoD) ROA community with the Air Force Flight Standards Agency
(AFFSA) and the FAA:
FAA Order 7610.4, Special Military Operations
In the late 1970s, the FAA and Department of Defense (DoD) reached agreement on the
operation of unmanned aircraft in the NAS, outside of restricted and warning areas. At
that time, these systems were labeled remotely piloted vehicles (RPV). The criteria for
the operation of DoD RPV in the NAS were written into FAA Order 7610.4, Special
Military Operations. Subsequently, some military organizations began using the term
“unmanned aerial vehicle (UAV)” for these systems, and that term became more
prevalent over time. Yet, this terminology was never included in FAA Order 7610.4.
The advent of the MQ-1 and the RQ-4 extended the operational capabilities of unmanned
aircraft significantly. As a result, the FAA and DoD determined additional guidelines
were needed to ensure safety could be maintained when ROA were operated in the NAS
outside restricted and warning areas. Therefore, in May 1999, the FAA, with DoD
concurrence, issued an FAA Notice that changed the criteria in FAA Order 7610.4 for
DoD RPV operations. This Notice implemented the COA process and changed the
designation of unmanned flight systems from RPV to ROA. Subsequently, the contents
of this Notice were incorporated into the next revision to FAA Order 7610.4. Since a
single document was developed jointly between the DoD and FAA, DoD publications
like AFI 11-202V3 refer to the FAA Order as an approved source.
Equivalent Level of Safety
In accordance with FAA Order 7610.4, Special Military Operations, Chapter 12,
Section 9: a ROA must achieve an “equivalent level of safety” (ELOS), comparable to a
manned aircraft. ELOS refers to a combination of systems and a concept of operations
that reduces the chance of a midair collision to an acceptable level. At this point in the
development process of a SAA system, we do not yet have all the information necessary
to establish a defensible and tangible value for ELOS (e.g., 10 -6 ). Historical midair
collision rates for manned aircraft will provide some indication of what this value should
be. However, further simulation, testing, and analyses will be required before we will be
able to define the requirement for “ELOS.”
ROA vs. RPV and UAV Terminology
During the coordination process leading to the creation of the FAA Notice that changed
the previous RPV criteria, the FAA and DoD reached agreement that these unmanned
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