A Truly Monumental Feat – The FAA BVLOS ARC Report
By Jim Williams, FAA Regulatory Affairs Director for AURA Network Systems
Well, I have to say that the U.S. aviation community certainly took note last week as the FAA's Uncrewed Aircraft Systems (UAS) Beyond Visual Line of Sight (BVLOS) Aviation Rulemaking Committee (ARC) released a final report. I strongly recommend you review the entire 200+ page document because it represents a tremendous amount of work by the 87 members of the ARC. I just want to say how very proud I was to serve on the ARC with some of the most talented and knowledgeable professionals in aviation – both traditional and uncrewed.
First, let's note that it was a massive undertaking over only nine months. The report represents tens of thousands of hours of research and writing. This entire effort is about historical changes in a very important industry that has a time-honored suspicion of changes. When you convene 87 members from all across an industry, you can certainly expect to discover the conflicts inherent to making history. I’m proud to have witnessed the many times people worked past differences and looked at the data to accomplish this landmark report.
To be sure, this is monumental. The recommendations, if implemented, truly enable all aspects of UAS BVLOS operations. They identify and generally address specific inconsistencies of current regulations. I believe they also honor the FAA's safety-first approach to UAS integration. An example is that the recommendations would open an approval path for third-party services that is not available under current regulations.
As someone who has been involved with these issues for decades and once was executive lead for the FAA's UAS Integration Office, this work was grueling yet very satisfying. This day has been coming for a long time, and I felt the process ensured that all voices were heard and considered. One theme across the hundreds of pages is risk assessment and the data support our recommendations at every level.
If I could add one more thing to the larger community discussion (not that 200+ pages aren't enough) it would be that everyone recognizes regulation can be daunting. The ARC was thankfully not tasked with solving all the conflicts and challenges, but with identifying them and we sure accomplished that. So, I might offer the FAA's Part 107 as a possible example of how the future could unfold for these recommendations. Passed as innovation in 2016, the rule required specific waivers to fly at night. That is, until such waivers became commonplace and in December 2020, the FAA updated the regulation to permit smaller aircraft to fly without a waiver, although, of course still within the operator's line of sight. This approach can be used again to enable many of the ARC’s recommendations to be implemented prior to the rules becoming final.
Time and again, the ARC recommendations urge the FAA to find ways to enable BVLOS operations as soon as possible. I'll end by thanking all my AURA colleagues and industry friends who showed such patience as the ARC consumed my time and attention. I believe it was worth every single minute.