NBAA Weighs in on Milestone Efforts for Advanced Air Mobility Integration
The National Business Aviation Association (NBAA) weighs in on two initiatives critical to the safe, timely and successful integration of advanced air mobility (AAM) into the U.S. National Airspace System (NAS). The association’s comments — informed by NBAA’s AAM Roundtable and Emerging Technology Committee — provide direction to government agencies on proposals with potential impact for pilots, manufacturers, infrastructure developers and other stakeholders.
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). This effort aims to provide transition regulations, or Special Federal Aviation Regulations (SFAR), for pilot certification and operating rules, allowing entry into service. The association, along with the Aircraft Owners and Pilots Association, the General Aviation Manufacturers Association, the Helicopter Association International, the National Air Transportation Association, and the Vertical Flight Society, describe several concerns regarding the proposal and outline practical recommendations to ensure safe pilot qualification and operations.
The stakeholders explain the proposal is not aligned with International Civil Aviation Organization (ICAO) standards for airman certification, creating an unnecessary burden for many powered-lift manufacturers and operators and establishing impossible mandates for powered-lift with a single set of controls. The proposed rule also does not align with ICAO guidance regarding operational rules, inhibiting operators from utilizing the full capabilities of these new aircraft.
“Unfortunately, this NPRM does not empower the development of powered-lift aircraft with the potential described by the Government Accountability Office (GAO),” the associations state in their comments. “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.
“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,” they conclude.
NBAA’s full comments on the NPRM can be found at https://nbaa.org/wp-content/uploads/aircraft-operations/emerging-technologies/advanced-air-mobility-aam/20230814-Industry-Comments-FAA%E2%80%932023-1275-Powered-Lift-SFAR.pdf.
The NBAA also provided both short- and long-term recommendations on future AAM operations to the Department of Transportation’s AAM Interagency Working Group (IWG), which was created as a result of the Advanced Air Mobility Coordination and Leadership Act, signed into law by President Biden in October 2022.
“As the IWG knows, the U.S. has been at the forefront of aviation leadership and innovation for decades,” the RFI states. “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.”
NBAA emphasizes the importance of safety, while also encouraging entry into service in a timely and thoughtful manner. Looking to the long term, NBAA urges the agency to work closely with stakeholders to facilitate scaled operations. The association also highlights the need to nurture community acceptance and address apprehensions that may arise from the new, on-demand air-mobility entrants into the aviation system.
“The path to realizing the goals of advanced air mobility is a complex and multifaceted endeavor,” the RFI states. “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, sums up the significance of the unified industry direction for federal AAM planning, noting that, “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.”