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Software Briefing

What Certificate-Level Part 108 Software Should Do

Certificate-level software should work as a dispatch gate before it works as a report system.

This briefing discusses proposed rulemaking and operational readiness. It is not legal advice.

Certificate-level Part 108 software has one main job. It must help the operator decide whether a specific flight can be released. A logbook with attached documents can help after the fact, but it is not the center of the problem.

The critical moment is before dispatch. The system must check aircraft configuration, crew currency, operational area, required procedures, risk state, and open blockers. If a required fact fails, the flight should not launch without a recorded human decision.

If software can log a flight that should not have flown, it is not certificate-level software.

The certificate is about system trust

Part 107 puts much of the operational trust close to the remote pilot in command. The proposed certificate path shifts more trust to the operator organization and its system. The FAA needs to believe the operator can repeat authorized work without one-off improvisation.

That means the release decision must be reproducible. The same inputs must produce the same result. Each finding should cite the rule or internal control. Each override should keep a reason. Each correction should supersede older facts instead of erasing them.

Five record families need one spine

The five record families are aircraft and configuration, personnel qualification, operational area, risk and SMS, and the flight record. Many tools store these facts apart from each other. Certificate-level software connects them around the mission.

An auditor should be able to start with one flight and move to the exact aircraft state, assigned people, training, approved area, governing procedure, risk decision, and sealed evidence.

What belongs above the gate

Hazards, incidents, mitigations, and open safety findings should affect readiness. Evidence packs should assemble from source records. Reviewers should inspect scoped, read-only views without changing the record.

The product should not act as autopilot, mapping software, air traffic control, or a general dashboard. It sits above execution as the layer that checks and the layer that proves.

Sources

Build the record while you keep flying.

Ledger runs deterministic checks before release and keeps proposed Part 108 readiness evidence in shadow mode while you operate under today's authority. See BVLOS compliance software for the dispatch gate that those certificate-level checks would sit behind.