VAI proposes a clearer, safer vision for drone integration under Part 108 Association urges the FAA to revise its BVLOS rule to protect low-altitude safety. VAI is asking the FAA to reconsider numerous aspects of its proposed new rule, Normalizing Unmanned Aircraft Systems (UAS) Beyond Visual Line of Sight (BVLOS) Operations, also known as Part 108, which aims to expand BVLOS drone operations. The proposed rule introduces significant changes to how aircraft share the low-altitude airspace where vertical flight operations routinely take place. The association fully supports the safe integration of drones and recognizes the importance of advancing BVLOS operations for UAS. At the same time, it is essential that the final rulemaking reflects the realities of manned vertical flight operations and the important missions these aircraft perform. The proposed rule relies on inaccurate assumptions about the low-altitude environment, proposes significant changes to long-standing right-of-way rules, and risks creating unnecessary hazards in the airspace. The comments VAI submitted to the FAA highlight several areas for improvement: • The FAA’s statement that manned aircraft don’t operate within 400 ft. of structures is incorrect and therefore must not form the basis of safety analyses. • Right-of-way rules must continue to protect the least maneuverable aircraft; manned aircraft should retain precedence over UAS within the right-of-way hierarchy. • Detect-and-avoid systems must include redundant, overlapping systems (including onboard broadcast receivers for UAS systems and visual and/or acoustic systems) as part of a phased approach to ensure reliable avoidance maneuvers upon the effective date of Part 108. • Shielded operations must be restricted to ensure that no manned aircraft are operating in the areas where UAS would have shielded protections. • Recreational operations should not be permitted under Part 108 at this time. • The flight area for UAS of 400 ft. above ground level should be maintained unless exceeding that level is required to ensure safety. When such an exceedance is required, it should always be limited to no more than 100 ft. above a structure and should only be permitted as needed for temporary transit. With these targeted revisions, the FAA can strengthen the proposed new rule and ensure that BVLOS integration enhances, rather than compromises, the safety and efficiency of the US National Airspace System. The association mobilized its global membership to provide aligned, consistent feedback highlighting the realities of manned vertical flight operations. Through this coordinated effort, VAI reinforced the importance of protecting right-of-way principles, maintaining low-altitude safety, and ensuring that detect-and-avoid technologies and operational limits reflect the needs of both manned and unmanned aircraft. View VAI’s comments to the FAA proposal Read the proposed FAA rule
