There is a bit of confusion between the roles of Manufacturer vs Flight Module Provider as per NPNT.
On Page 32 of RPAS Guidance Manual, Section 1.3:
In this document, the term “Flight Module Provider” is used to refer to a RPAS manufacturer or any agency who has partnership with the manufacturer to manage certification and related software/security aspects of registered flight modules
This implies that Flight Module Provider can be a different entity from Manufacturer. In such a case, the Flight Module Provider will be primarily responsible for key management. In Digital Sky, the Manufacturer is required to upload a Trusted Certificate Chain. This implies that the Manufacturer and the Flight Module Provider are considered as one.
One way to fix this could be to have Flight Module Provider as a separate entity and have separate roles for Flight Module Provider and Manufacturer.
- Manufacturer: Responsible for submitting RPAS list application with all the required documents
- Flight Module Provider: Responsible for uploading the Trusted Certificate Chain and key management