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Have BVLOS opinions? Your feedback on drone flights is actually wanted

If you read the Drone Girl, you probably have BVLOS opinions regarding drone flights far beyond what a pilot or visual observer can see. And while I love that you share them in the comments section with fellow readers (or with me via email), it’s time you send your BVLOS opinions to a source that seriously matters: the FAA.

The Federal Aviation Administration (FAA) is seeking public input on the expansion of beyond visual line-of-sight (BVLOS) drone operations in a public comment period that’s open between now and Wednesday, June 14. Specifically, it wants your thoughts on advances in technology, standards, and operational strategies to safely demonstrate whether UAS BVLOS operations can be applied without adversely affecting safety.

Some factors on the FAA’s mind include:

  • Detect and Avoid (DAA) Systems Performance Standards: Whether a single standard should be created versus multiple definitions, whether a combination approach makes sense, or whether there are circumstances where no standards would provide an acceptable level of safety
  • Declarations of Compliance for Detect and Avoid: Whether operators should be able to declare they are using DAA systems, or whether they should have to submit details of their DAA system for approval and validation prior to operation.
  • DAA between drones: Whether drones should have to have some form of vehicle-to-vehicle communications method
  • Boundaries: Whether their should be boundaries, and what they should actually be (some standards maintain a horizontal distance of 2,000 feet and a vertical distance of 250 feet between drones and crewed aircraft)
  • Third-Parties: Whether operators should be separated from UTM service providers in gaining exemptions

The public comment period could have specific implications for four companies in particular: Phoenix Air Unmanned, uAvionix, Zipline, and UPS Flight Forward. And the FAA says that data collected from these operations will inform the FAA’s ongoing policy and rule-making activities, particularly around BVLOS drone operations at or below 400 feet.

In short, each of the four companies has asked for some sort of exemption or waiver, and the FAA needs your feedback on how to handle them. For example, Zipline, which is considered the largest drone delivery company in the world, wants a revised exemption so it can use DAA systems to deconflict with other aircraft rather than simply using visual observers.

Meanwhile, UPS Flight Forward, which was the first operator approved in the U.S. to operate the Matternet M2 drone for commercial delivery (a certification it earned way back in 2019), is seeking approval to allow a remote pilot in command (RPIC) to conduct flights from a command center in an entirely different location (another Matternet customer, Ameriflight, is also looking to do the same).

In fact, your comments around BVLOS operations such as these are truly critical and timely, as the FAA said it anticipates making a decision on those four companies’ requests this summer.

Have BVLOS opinions? Your feedback on drone flights is actually wanted UPS Flight Forward
A UPS Flight Forward delivery operation using Matternet’s M2 drone system.

How to submit BVLOS opinions to the FAA

So how do you submit your BVLOS opinions?

The easiest way to share your feedback is online, through the U.S. government’s regulations website. Simply visit this link and click “Comment in the top left.”

The FAA is giving you up to 5,000 characters to leave a comment, though you can also attach up to 20 files up to 10 MB each on top of that.

Comments can be submitted via individuals or on behalf of a company, organization or government agency. And yes, comments can be left anonymously.

If Internet isn’t your think, you can also send your comments via snail mail, fax or you can even hand deliver them. Information for those methods is here.

As of this writing, there have been roughly 200 comments received. And in fact, since they’re public, you can read them all here.

What’s the big deal with BVLOS?

BVLOS operations, which involve drone flights beyond what the operator (or other staff) can see, hold immense potential for expanding the capabilities and applications of unmanned aerial systems. However, ensuring the safe integration of drones into the national airspace system remains a top priority for the FAA, and other governments too.

The FAA took a big step ahead when, in March 2022, its designated UAS Beyond Visual Line-of-Sight (BVLOS) Operations Aviation Rulemaking Committee (ARC) issued its final report, which included a comprehensive set of recommendations for implementation to support expanded drone operations.

Ideas in that report included creating a proposed, new 14 CFR Part 108 that would spell out how you can operate drones beyond visual line of sight and would create a new Remote Pilot certificate rating to cover BVLOS operations beyond the scope of the extended Part 107 rating.

We don’t have such a thing as Part 108 yet, but in the meantime, several petitioners since that March 2022 report have proposed various methods to safely operate UAS BVLOS under petitions for exemptions, and the FAA has received several petitions for exemptions to conduct several types of BVLOS operations.

Submit your thoughts on BVLOS soon. The comment period closes next Wednesday, June 14.

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