AURA Provides Input on FAA Regulatory Framework for BVLOS Operations

By Brian Regan, AURA Chief Legal & Regulatory Officer 

In comments filed this week, AURA urged the Federal Aviation Administration (FAA) to create a separate approval process for third-party service providers that is distinct from approvals sought by UAS operators.

While the focus of the agency’s current effort is extremely important, we are encouraging the FAA to propose and create a more comprehensive framework allowing early advanced air mobility (AAM) operations such as remotely piloted air cargo to thrive in the next generation of aviation.

Third-party services, including for safety critical command-and-control (C2) communications links, are essential to enable BVLOS operations, and providers like AURA are developing innovative technologies and services from the ground up to support this new evolution in aviation safety. Having a separate, well-defined process for approval will provide us – and our customers – the certainty needed to plan our operations.

Our comments outline why it’s important to distinguish between third-party services and UAS Traffic Management (UTM). Although UTM may include such services, some exist outside of UTM. In addition, UTM may only be necessary for certain concepts of operations (CONOPs), while robust and reliable C2 communications (and other services) will be required for all BVLOS operations.

“While the experience of small UAS (sUAS) operators is instructive and an important early use CONOPs, it will not reflect the full range of expected UAS use cases. As such, the data gathered through the accompanying exemptions, while valuable, will not be a sufficient basis on which to create a comprehensive rule framework for BVLOS operations. AURA urges the FAA to consider holistic regulatory structures that, to the greatest extent possible, apply to all CONOPs, as necessary.”

We believe our suggested approach helps accomplish the FAA’s objective to gather technical industry input as it considers the expansion of BVLOS operations in particular operating environments. We look forward to continuing to engage with both government and industry stakeholders, and we are particularly appreciative of the FAA’s continued efforts to advance U.S. leadership in aviation.

You can read the complete filing here.