Hot Air Rises

The National Business Aviation Association (NBAA) has addressed two initiatives broadly believed critical to the safe, timely, and successful integration of Advanced Air Mobility (AAM) into the U.S. National Airspace System (NAS).

Advanced Air Mobility (AAM) is defined, generally, as an air-transport system concept comprising new, transformational aircraft designs and flight technologies into existing and modified airspace operations.

The NBAA’s comments—as informed by the Association’s AAM Roundtable and Emerging Technology Committee—provide direction to government agencies vis-à-vis proposals potentially impacting pilots, manufacturers, infrastructure developers, and other aerospace stakeholders.

Initially, the NBAA provided feedback to the Federal Aviation Administration (FAA) on its Integration of Powered-Lift: Pilot Certification and Operations; Miscellaneous Amendments Related to Rotorcraft and Airplanes Notice of Proposed Rulemaking (NPRM)—a legislative effort to provide transition regulations, or Special Federal Aviation Regulations (SFAR), for pilot certification and operating rules, facilitating entry into service. 

The NBAA, along with the General Aviation Manufacturers Association (GAMA), the Helicopter Association International (HAI), the National Air Transportation Association (NATA) and the Vertical Flight Society (VFS), described numerous concerns germane to the proposal, and outlined practical recommendations to ensure safe pilot qualification and operations.

Stakeholders explained the proposal is misaligned with International Civil Aviation Organization (ICAO) standards for airman certification, creates an unnecessary burden for powered-lift manufacturers and operators, and establishes impossible mandates for powered-lift with a single set of controls. The proposed rule misaligns, also, with ICAO guidance pertaining to operational rules, thereby inhibiting operators’ utilization of new aircrafts’ full capabilities.

The NBAA set forth in its comments: “Unfortunately, this NPRM does not empower the development of powered-lift aircraft with the potential described by the Government Accountability Office (GAO). The proposal for airman qualification creates a barrier for most AAM aircraft manufacturers to enter the U.S. market and the proposed operations rules create an uneven playing field for powered-lift aircraft, failing to take advantage of the many benefits provided by vertical takeoff and landing capabilities.

The comments concluded: “Close alignment with ICAO standards and guidance will allow U.S.-based manufacturers and operators to achieve anticipated operations launch dates in 2025, and ensure a lively AAM industry in the U.S. far into the future.”

Additionally, the NBAA provided the U.S. Department of Transportation’s AAM Interagency Working Group (IWG) recommendations, both short- and long-term, pertaining to future AAM operations. The DOT AAM IWG’s creation derived of the October 2022 passage of the Advanced Air Mobility Coordination and Leadership Act.

The Request For Information (RFI) states: “As the IWG knows, the U.S. has been at the forefront of aviation leadership and innovation for decades. We have the potential to continue to lead the next phase in the evolution of aviation with AAM, but competition with other nations is fierce and rapidly advancing. Among other considerations, this means the FAA will need to keep pace with its promised regulatory schedule, so that the first AAM commercial operations can occur as soon as 2025.”

The NBAA emphasized the importance of safety, while encouraging entry into service in a timely and thoughtful manner. Looking to the long-term, the Association urged the agency to work closely with stakeholders to facilitate scaled operations. The Association highlighted, also, the need to nurture community acceptance and address apprehensions arising from the emergence of new, on-demand air mobility entrants into the aviation system.

The RFI continues: “The path to realizing the goals of advanced air mobility is a complex and multifaceted endeavor. However, by upholding a steadfast commitment to security, adhering to regulatory timelines, harnessing existing infrastructure and fostering community acceptance, we can pave the way for a future where the skies are not just a symbol of boundless potential but a tangible and integrated component of our modern transportation landscape.”

NBAA Chief Operating Officer Chris Rocheleau summed up the significance of the unified industry direction for federal AAM planning, asserting: “Taken together, the industry’s input on these two key initiatives will inform the work needed to ensure that the U.S. remains the world’s leader in fostering the development, integration, and utilization of promising advanced air mobility technologies.”

FMI: www.nbaa.org