Comment from Anonymous

This application from Amazon demonstrates a complete disregard for the concept of airworthiness. Specifically, they expect to be exempted from both the requirements of, and the lessons learned from which were derived, DO-178 and DO-254. The number of HIL and SIL events described come nowhere near close enough to validate a TLOS adequate to achieve safe flight in close proximity to people. When considering this petition, I encourage the administrator to contrast the ad-hoc engineering approach that Amazon has described to the airworthiness approach used by Northrop Grumman and the USAF in designing the RQ-4 series of aircraft. The RQ-4 series aircraft were designed specifically using military airworthiness requirements, and have since over 20 years of flying experience. However, with quad-redundant data links and dual-string flight control computers, the RQ-4 series aircraft continue to have loss of control accidents. Amazon's filling attests that they do not have anywhere near enough flight or simulator experience to validate routine flight in the NAS, much less an exemption to multiple FARs. At a minimum, Amazon must demonstrate compliance with industry standard hardware and flight control software engineering standards in order to achieve routine flight in the NAS.