Emphasize Need For Safety Guardrails At Low Altitudes

The EAA recently submitted its formal comments on the FAA’s notice of proposed rulemaking, or NPRM concerning Normalizing Unmanned Aircraft Beyond Visual Line of Sight Operations. In its 28-page feedback, EAA affirmed its support for the safe integration of UAS into the National Airspace System (NAS), and while the proposed rule begins to establish a pathway toward that objective, there are significant areas of concern especially for manned operations.

With very few exceptions, the NAS currently operates in a well-established and safe manner, and EAA firmly believes that bringing in UAS should not disrupt existing operations nor should it impose undue risk or burden to current operators. Manned aircraft for decades have operated safely and responsibly in that regulatory system, and the imposition of costs, operational limitations, or a shift of responsibility onto existing NAS users poses a dangerous risk to the culture of safety that pilots have built over the years.

EAA offers three conditions it sees as essential to the successful integration of UAS into the system: First, the safety of manned aircraft must take precedence in any discussion of UAS integration.

Second, no new airspace restrictions should be placed on manned operations to facilitate unmanned operations.

Third, manned aircraft should not be required to install new equipment beyond what FAA regs already require.

EAA believes the BVLOS proposed rule as it is written now, has elements that do not meet those conditions, and if the FAA implements the rules in their current form, safety of both manned and unmanned aircraft could potentially be jeopardized.

FMI:  www.eaa.org/