If my device works well, covers all my needs, and does all reasonable tasks, where is the reason to get some risk with a decision to update it? Until the update process goes, I can do something wrong. The update itself can have something wrong. The possibility to lose some hidden feature, which is incidentally removed/resolved in the last update, and so on.
Any of these tells me to avoid doing anything.
Hi there,
you are totally right and I actually agree with your point of view. But in the end it is a question of whether to comply or not to aviation law standards.
Here are the few things that the "new" EU 2019/945 has to say about the manufacturer's side obligations concerning firmware and software updates:
EU 2019/945, SECTION 1, Product requirements, Article 4, Requirements
(...) 3. Any updates of software of the products that have already been made available on the market may be made only if such updates do not affect the compliance of the product.
EU 2019/945, PART 10, Contents of the technical documentation
(...) The technical documentation shall, wherever applicable, contain at least the following elements,: (...)
(b) the versions of any software or firmware involved in compliance with the requirements set by this Regulation;
So the obligation to update firmware and software of the UAS actually is not part of the EU 2019/945 (UAS manufacturer side) or even EU 2019/947 (UAS operator or remote pilot side).
The only objectives that are referred to as mandatory updates in EU 2019/947 are "(...) active and updated direct remote identification and geo-awareness systems (...)".
Manufacturers "force" the operators or pilots to read and comply with the manual instructions. So this normally includes updating firmware and software of the "UAV" and the "GCS" (in all the "UAS"). They force to do so in order to be "on the safe side" when it comes to mandatory changes or new features due to (new) laws or (meanwhile) known malfunctions.
EU 2019/947 (UAS operator or remote pilot side) says:
ANNEX, UAS OPERATIONS IN THE ‘OPEN’ AND ‘SPECIFIC’ CATEGORIES, PART A:
(...) UAS operations in subcategory A1 shall comply with all of the following conditions: (...)
(4) be performed by a remote pilot: (a) familiarised with the user's manual provided by the manufacturer of the UAS;
(...)
(...) UAS operations in subcategory A2 shall comply with all of the following conditions: (...)
(2) be performed by a remote pilot who is familiar with the user's manual provided by the manufacturer of the UAS (...)
So as far as I understand the laws,
1) operators and pilots should do what is written in the "manual provided by the manufacture".
2) manufacturer's updates may "not affect the compliance of the product".
3) manufacturers must keep their manuals up to date regarding "the versions of any software or firmware involved in compliance with the requirements."