Unlocking Routine BVLOS Operations: Turning Policy Promise into Practical Progress 

October 7, 2025

When the FAA released its long-awaited proposal to enable routine Beyond Visual Line of Sight (BVLOS) drone operations, AUVSI welcomed it as a long-overdue milestone and we quickly published our initial analysis outlining the opportunities and open questions we saw in the draft rule. 

Since then, we’ve worked closely with our member companies, partner associations, standards bodies, and public-safety stakeholders to develop comprehensive final comments, reflecting the operational experience, data, and priorities of an industry ready to scale safely. Those discussions shaped the detailed recommendations AUVSI submitted to the FAA on October 6, 2025. 

The message from across the ecosystem is clear: the BVLOS rule must move from potential to practical. It must protect safety and unlock economic opportunity by providing clear, scalable, and performance-based pathways for commercial, public-safety, and civic-interest missions alike. 

What the NPRM Gets Right 

The FAA’s proposal introduces several long-awaited advances that AUVSI and our members strongly support: 

• A performance-based, scalable framework. The proposed Part 108 and companion Part 146 (Automated Data Service Providers) finally recognize that different aircraft and different operations carry different levels of risk; this is a necessary evolution from the one-size-fits-all waiver system. 

• Two operational pathways: Permit and Certificate. This structure mirrors crewed aviation, combining flexibility for innovation with predictable oversight for routine, higher-volume operations. 

• Integration of consensus standards. By accepting performance-based “Means of Compliance,” the FAA can keep safety standards current without stifling innovation. 

• Recognition of real-world data. The agency’s acknowledgment of thousands of successful BVLOS operations under existing waivers shows that the U.S. already has the evidence base to expand safely. 

These strengths form a solid foundation. But without targeted refinements, the final rule risks introducing new uncertainty and administrative friction just as the industry is ready to scale. 

Where the Rule Needs Refinement 

1. Ensure a Predictable Transition for Existing Operators
   Public-safety agencies, infrastructure inspectors, and delivery providers have collectively logged tens of thousands of safe BVLOS flights. The final rule must credit that experience and operational data toward Part 108 authorization and establish a clear transition timeline so ongoing missions aren’t grounded while new processes are stood up.
2. Clarify the Boundaries Between Permits, Certificates, and Fleet Thresholds
   As we noted in our initial analysis, the NPRM lacks clarity on how operators move from a permit to a certificate, or what metrics trigger the shift. The FAA should define objective thresholds for fleet size, frequency, and operational complexity to give operators the predictability needed for business planning and investment. 
3. Codify Shielded Operations as Operate-by-Rule
   AUVSI’s comments urge the FAA to formally recognize shielded BVLOS operations (those conducted near structures or terrain) as operate-by-rule under standardized mitigations like geofencing and altitude limits. These flights have proven exceptionally efficient across powerline, rail, and infrastructure inspection missions, and codifying them would immediately reduce regulatory bottlenecks. 
4. Streamline Approvals for Emergency and Civic Payloads
   Drones are delivering AEDs, naloxone, and blood products today, but current rules make it hard for public-safety and civic operators to act quickly in emergencies. In parallel, the FAA and PHMSA should update outdated hazardous-materials rules to allow routine carriage of low-risk consumer goods using standardized Means of Compliance suited to small UAS operations. 
5. Keep Security Proportionate and Practical
   The TSA’s proposed airport-style vetting and “Limited Security Program” requirements are disproportionate to risk and inconsistent with the agency’s own layered, risk-based approach. AUVSI calls for these provisions to be removed from the final rule and replaced with a coordinated security framework that builds on existing FAA oversight, company security protocols, and TSA’s established General Aviation model. 
6. Recognize Global Equivalencies to Maintain U.S. Competitiveness
   The FAA should recognize foreign approvals and Means of Compliance that demonstrate equivalent safety such as those under the EU’s JARUS SORA or Transport Canada’s SFOC framework. This would streamline certification for global manufacturers, reduce duplication, and align U.S. policy with international best practices. 
7. Clarify the Scope and Role of Automated Data Service Providers (Part 146)
   Automated Data Service Providers are essential to enabling UTM and deconfliction services. The final rule should ensure that certification is risk-scaled, optional for low-risk missions, and does not inadvertently regulate upstream infrastructure providers that aren’t delivering flight-safety services. Interoperability and change-management standards must be transparent and consistent across all ADSPs. 
8. Modernize Right-of-Way and Enable Shared Visibility
   AUVSI urges the FAA to modernize right-of-way rules to reflect how aircraft actually share low-altitude airspace. Crewed aircraft that broadcast cooperative signals should retain priority, while uncrewed aircraft operating safely BVLOS should have right-of-way below 500 feet when crewed aircraft are unequipped. This approach encourages shared visibility, improves safety, and avoids the complexity of population-based right-of-way changes, which are impractical and unsupported by data. Modernizing right-of-way in this way will make low-altitude airspace safer, more predictable, and ready for scaled BVLOS operations. 

A Path Forward 

Routine BVLOS operations are essential to unlocking the next wave of innovation across logistics, energy, agriculture, and public safety. From reducing power-line inspection costs by half to accelerating emergency response times by minutes, the benefits are clear and so is the competitive urgency. 

Other areas of the world already allow routine BVLOS in defined corridors. The longer the U.S. delays finalizing Part 108, the greater the risk that investment, jobs, and leadership migrate elsewhere.  

The U.S. has spent nearly a decade proving that uncrewed flight can be safe, reliable, and transformative. Now it’s time to codify that progress. 

With clear rules, risk-based oversight, and collaboration between government and industry, the FAA’s BVLOS rule can unlock the full potential of uncrewed systems; advancing safety, competitiveness, and public benefit across every sector of the economy.