GPS steer-able parachute

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If I was planning to develop a device like this (though I'm not), I would:

1) read the regulations that apply to model rockets (and only model rockets)
2) assume what is not specifically disallowed is okay
3) avoid misinterpretation by naming it thoughtfully (something like Drift Limiter, which also sets customer expectations)

Given the limitations (glide speed may not keep up with wind speed at various altitudes, and some trajectories are just super difficult to return from), I would just say to customers that the Drift Limiter would do the best it could to shorten the walk—though sometimes it might actually get back to the pad vicinity and then descend super close to the pad.

That all has a very different feel than touting GPS steering and intelligent guidance, and is much closer to the reality of the solution.
 
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What about letting it fall with a drogue parachute, then at 400 feet, the guidance/steering capability kicks in? Almost like a Jolly Logic Chute Release or dual deploy, but instead of releasing the main parachute at the programmed altitude, it deploys or activates the steerable parachute.

Or, the parachute and its guidance/control system are deployed at apogee. At that point, the parachute is set to simply descend in a giant circle. Then at 400 feet, the guidance or steering system activates. Depending on how far away it is from the launch site at activation, 400 feet may be enough height to get it back close to where it launched...or maybe not.

I'm not familiar with the relevant regulation(s), not does it matter if I was. In the end, all that matters is what an Article III federal judge says the regulation means.
If this is allowed... You would not be able to return to the launch site since L/D for a gliding parachute is much lower than for an RG. You would have to have on board sensors and an AI to just steer it away from trees, roads, water and other hazards.
 
I recommend sending an email to FAA UAS Support Center.

Something close to: "I would like to know if a steerable parachute system that autonomously steers a payload without any direct human control to a predefined landing point is considered as a UAS or not"

You might be surprised by the answer you get.

An unmanned aircraft system is an unmanned aircraft and the equipment necessary for the safe and efficient operation of that aircraft. An unmanned aircraft is a component of a UAS. It is defined by statute as an aircraft that is operated without the possibility of direct human intervention from within or on the aircraft (Public Law 112-95, Section 331(8)).

Aircraft means a device that is used or intended to be used for flight in the air. 14 CFR § 1.1 - General definitions.

Since a parachute is a drag-producing device meant to slow the fall of an object, such an object-parachute combination would generally not be said to fly. Therefore, it is not an aircraft. Furthermore, the FAA has historically regarded only radio controlled aircraft as drones/UAS.
 
I recommend sending an email to FAA UAS Support Center.

Something close to: "I would like to know if a steerable parachute system that autonomously steers a payload without any direct human control to a predefined landing point is considered as a UAS or not"

You might be surprised by the answer you get.

An unmanned aircraft system is an unmanned aircraft and the equipment necessary for the safe and efficient operation of that aircraft. An unmanned aircraft is a component of a UAS. It is defined by statute as an aircraft that is operated without the possibility of direct human intervention from within or on the aircraft (Public Law 112-95, Section 331(8)).

Aircraft means a device that is used or intended to be used for flight in the air. 14 CFR § 1.1 - General definitions.

Since a parachute is a drag-producing device meant to slow the fall of an object, such an object-parachute combination would generally not be said to fly. Therefore, it is not an aircraft. Furthermore, the FAA has historically regarded only radio controlled aircraft as drones/UAS.
Was the the response you got back from the FAA?

As you stated, it's public law, not FAA regulations. There may be other government agencies interested in it's enforcement with a whole different idea of what it means. Rather than accept the FAA's analysis with their focus on aircraft safety, you might want to also contact Homeland Security to get their take on it. It could be significantly different and their enforcement of the "public law" might be different. Only a court can work out the differences and define the boundaries and then, only after a case is tried and judgement rendered.
 
Was the the response you got back from the FAA?

As you stated, it's public law, not FAA regulations. There may be other government agencies interested in it's enforcement with a whole different idea of what it means. Rather than accept the FAA's analysis with their focus on aircraft safety, you might want to also contact Homeland Security to get their take on it. It could be significantly different and their enforcement of the "public law" might be different. Only a court can work out the differences and define the boundaries and then, only after a case is tried and judgement rendered.
Yup, an agency's opinion is fairly persuasive, but even if no other agency disagrees, it's really up to a federal judge to make the final decision as to whether a law/statute/regulation/rule/standard has, from a practical perspective, "the force of law."
 
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