While the FAA develops regulatory language intended to govern beyond visual line of sight (BVLOS) operations for unmanned aircraft systems (UAS), AOPA has been working with industry partners to ensure these new rules allow for safe integration and do not have a negative impact on general aviation.
Specifically, AOPA has been adamant that there not be any equipage mandates or loss of right-of-way privileges placed upon GA—two things that have been suggested by some in the UAS community. The wider aviation community aggressively pushed back on several recommendations that came out of the 2022 UAS BVLOS Aviation Rulemaking Committee Final Report that, if adopted, would have a significantly negative impact on the GA community.
One of AOPA’s primary objectives has been to push back on efforts to require ADS-B Out equipage for GA aircraft that are currently not required to have it—an effort by some to allow the UAS community to use the technology for collision avoidance. Such a requirement would be problematic for a variety of reasons, and AOPA continues to stress that this is not a sensible course of action. Another primary concern is a proposal to change the right-of-way rules to be based upon ADS-B Out equipage instead of the traditional basis of aircraft maneuverability. This proposal would require those not equipped with ADS-B Out to cede right of way in certain areas to UAS. Again, this is a non-starter for AOPA and most others in the wider aviation community.
The letter to the FAA addressed these concerns, along with several others, including airspace considerations and what constitutes “shielded operations”—that is, UAS operations that occur below a specified altitude which may or may not be the height of surrounding obstacles (such as trees or buildings). Additionally, the letter addressed detect-and-avoid (DAA) equipage on UAS—AOPA recommends the FAA work to certify DAA technologies for UAS that can detect both ADS-B-equipped and non-ADS-B-equipped aircraft.
AOPA has been heavily involved in efforts to usher BVLOS operations into the national airspace system for several years and is excited to see the adoption of this revolutionary new technology and eager to work alongside the UAS community to bring its benefits to the United States. However, AOPA remains strongly committed to ensuring that BVLOS be implemented safely, efficiently, and equitably and without negative impacts to general aviation.
The FAA has been anticipating publication of a proposed BVLOS regulation in mid to late 2024.