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App. A (39)UASAll, except for R&D and showing compliance

FAA Order 8130.34D — UAS Operating Limitation A-39

Appendix A · p. A-9

Minor configuration changes to the UAS are those that have no appreciable effect on the weight, balance, structural strength, reliability, operational characteristics, or other characteristics affecting the condition for safe operation of the UAS. Changes that do not meet the definition of a minor change are classified as “major changes.” For UAS Risk Index Group I UAS, the owner or operator must provide major configuration change documentation to the geographically responsible Flight Standards District Office (FSDO). For UAS Risk Index Group II and III UAS, major configuration changes require the owner or operator to update the safety checklist and provide it to the geographically responsible FSDO. A written response must be received from the FSDO indicating FAA concurrence before flying this aircraft after incorporation of a major configuration change, whether the aircraft is operating under a special airworthiness certificate, public aircraft COA, or other authorization.

Order notes

Notify the applicant which UAS Risk Index Group (I, II, or III) is applicable. This operating limitation may be modified to only include the applicable Group.

🧭 Guidance & sample wording

What makes a change “minor” vs “major”

A minor change has no appreciable effect on weight, balance, structural strength, reliability, operational characteristics, or anything else affecting the condition for safe operation of the UAS. Anything beyond that is a major change.

What a major change triggers — by UAS Risk Index Group

Group I: provide major-change documentation to the geographically responsible FSDO. Groups II & III: update the safety checklist and provide it to the FSDO. In every case you must receive a written response from the FSDO indicating FAA concurrence before flying after the major change — under a special airworthiness certificate, a public aircraft COA, or any other authorization.
Related CFR
Preparation support, not an FAA determination. The determination and record entry are made by the operator or authorized person; the FAA prescribes the final limitations on the FAA Form 8130-7.

Verify it yourself: the eyeball above opens the exact page of Order 8130.34D with this limitation highlighted.

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AWCReady decides limitation A-39 for you — from the aircraft, the operation, and the 8130.34D risk index.

Not every sample limitation goes on every UAS or OPA. AWCReady scores the risk, gates each limitation to the operation and certification basis, asks only the questions that matter in plain language, and assembles a review-ready package.

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This is a free reference reproducing public-domain text from FAA Order 8130.34D. AWCReady is not affiliated with or endorsed by the FAA. This is one of the order’s sample limitations; the limitations an aircraft actually receives are prescribed by the FAA on FAA Form 8130-7 — AWCReady prepares and organizes; the FAA determines every outcome.