A broad cross-section of aviation and drone industry organizations submitted comments following the FAA’s reopening of the comment period on its proposal to normalize beyond visual line of sight (BVLOS) unmanned aircraft operations. Responses to the proposed Part 108 rulemaking focused largely on electronic conspicuity, right-of-way and detect-and-avoid responsibilities, with commenters generally supporting drone integration while outlining different approaches to implementation.
Many stakeholders pointed to portable electronic conspicuity devices as a potential near-term tool for improving air-to-air awareness, frequently referencing existing and emerging products and concepts. Several filings emphasized that these devices should remain distinct from certified ADS-B Out equipment used for air traffic surveillance. Commenters also said timelines for bringing such systems to the U.S. market would depend on FAA technical standards, with some estimating availability within months after a framework is finalized.
Manned aviation groups emphasize layered safety
General aviation and crewed-aircraft organizations generally supported integration, but stressed compatibility with existing operations and layered safety measures. AOPA said in its comments that BVLOS integration “must be done in a manner that is safe and that accommodates manned aircraft operations,” adding that drones must be able to detect and avoid “ALL manned aircraft, including those not equipped with EC devices.”
EAA wrote that “the safety of manned aircraft must take precedence,” while other groups, including the National Agricultural Aviation Association (NAAA), Vertical Aviation International (VAI) and the NBAA described electronic conspicuity as a supplemental awareness tool rather than a replacement for ADS-B Out.
Several filings also supported performance-based standards to support BVLOS operations and referenced RTCA DO-282C as a possible interoperability baseline. RTCA DO-282C referrs to a technical standard that defines how aircraft broadcast position data over the 978 MHz Universal Access Transceiver system used for ADS-B traffic awareness.
Uncrewed and commercial operators highlight scalability
Drone industry groups and commercial operators also supported electronic conspicuity as part of a broader safety framework, often focusing on interoperability and scalability.
The Association for Uncrewed Vehicle Systems International described ADS-B-derived conspicuity as “the most mature, interoperable, and immediately deployable baseline,” while the Commercial Drone Alliance said expanded use of EC could help enable BVLOS operations.
Amazon Prime Air cited operational experience in which its systems detected and maneuvered to avoid crewed aircraft, stating that layered safety measures are needed because “equipment failure and human error will cause EC systems to fail even when properly installed.”
Wing Aviation, however, cautioned against broad mandates for noncooperative detect-and-avoid-systems that allow BVLOS drones to sense and avoid aircraft that are not electronically broadcasting their position, such as those without ADS-B or electronic conspicuity equipment. In its filing, the company said requirements to deploy those systems in Class B, Class C and certain high-density operating areas “are not supported by evidence,” and argued they could add weight, cost and technical complexity for small unmanned aircraft while limiting BVLOS operations in urban environments.
Across submissions, many organizations agreed electronic conspicuity devices should enhance situational awareness rather than replace ADS-B Out, and several supported performance-based standards grounded in existing infrastructure.
Crewed-aviation groups often emphasized protections for current operations and layered safeguards, while uncrewed stakeholders tended to focus on interoperability, adoption speed and scalable compliance paths.
The FAA will review the comments as it continues development of the Part 108 rule.