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UA.I.E.K12

Per AC 107-2A § 8.4.1, who qualifies as an "applicant" responsible for declaring compliance with subpart D's over-people requirements?

Why: AC 107-2A § 8.4/8.4.1, p. 8-10, defines an applicant as any person who produces, designs, or modifies a small unmanned aircraft eligible to operate over people, and specifically extends this to a kit seller whose kit contains all components needed to build an operable aircraft.

  • AC § 8.4.1 specifically extends applicant status to a kit seller, and §§ 8.4.3–8.4.4 extend it to later modifiers as well — responsibility is not limited to the original manufacturer.
  • A part 21 production certificate relates to Category 4 airworthiness certification under § 107.140(b)(1), not the subpart D "applicant" definition, which covers ordinary producers, designers, and modifiers without requiring part 21 status.

UA.I.E.K12Source: AC_107-2A.pdf, § 8.4.1, p. 8-10Reviewed 2026-10-22

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