Editor’s Update on FAA Part 108: Beyond Visual Line of Sight Rule

As many of you know, the draft FAA BVLOS Rule has been published and open for comments until October 6, 2025.

DRONERESPONDERS is working with other agencies, industry and public safety stakeholders to capture and prepare comments. This information and method for submitting comments will be provided with a goal no later than one week before the deadline.

There are a couple observations with the current draft rule:

1. Focuses on for profit drone delivery.

2. Focuses on large drone fleets.

3. Assumes operations are totally autonomous (which public safety are not and not likely to be so in the near future because of the need to follow activity).

4. Focuses on preplanned and scheduled flights from a specific path from to launch to location and return.

5. The requirements of permits, personnel requirements, population densities, training, limited operational periods (and more) are onerous, overburdensome and cost prohibitive.

6. Assumes public safety operations are emergency life saving missions only, are not routine, not daily operations and are more likely to be during disasters or to access difficult terrain.

Here are some of the objectives for these comments to address to date:

1. Preserve what public safety has gained by recent DFR and BVLOS waivers by utilizing the COW templates and process that have simplified and accelerated the current waiver process and insert into Part 108.

2. Public Safety be exempt from the other sections of Part 108.

3. Ensure that Part 108 BVLOS is inclusive to all public safety regardless of PAO eligibility to ensure that volunteer fire companies, NGO SAR, etc.

4. To preserve Part 107 BVLOS waivers as is OR integrate this process into Part 108 to ensure that public safety tactical operations and other small operators that will not be autonomous are able to continue operations.

5. Ensure that public safety has prioritization in the national airspace by developing a strategy and path forward that ensure emergency response priority and will harmonize operations between all drones operating in the National Air Space.

6. Plan how public safety will integrate with Strategic Deconfliction with the Automated Data Service Providers (ADSP) to enable public safety identification and priority status and do so in an effective and cost effective way.

While there is more and this is not in its final form, this gives you a sense of the direction to date. If you have more thoughts, please send to [email protected]

THESE COMMENTS ARE ABSOLUTELY CRITICAL TO SHAPE THIS NEW RULE TO MAXIMIZE PUBLIC SAFETY DRONE OPERATIONS INTO THE FUTURE!!!