The FAA—which so far has published final airworthiness criteria for two air taxi designs, Archer Aviation’s Midnight and Joby Aviation’s flagship model—issued an advisory circular (AC) that would create the foundation for certification of powered lift vehicles, such as eVTOL aircraft. The AC, which lays out acceptable means for showing compliance with FAA Part 21 requirements for special class aircraft, is open for comment for 60 days.

EASA, meanwhile, updated its special condition for vertical takeoff and landing aircraft (SC-VTOL) rules to incorporate new requirements agreed upon with the FAA, covering safe flight and landing, handling qualities, and single-point failures.

Simultaneously, the regulators together revised Safety Emphasis Items (SEI) lists—which determine an agency’s level of involvement in aircraft validation projects—for parts 23, 27, and 29. According to the FAA, the partners have reduced SEI requirements and placed greater responsibility on the authority actually certifying the aircraft.

“The FAA and EASA have achieved a significant milestone on the path to certifying eVTOL aircraft,” the FAA said in a statement. “This also marks important progress in our effort to more closely align rulemaking and policy initiatives between the United States and the European Union. We’re committed to ensuring the safety of the flying public both at home and abroad.”

Both the FAA and EASA have announced ambitious initiatives designed to cement their respective AAM industries as the world’s biggest and best. But before tackling challenges such as eVTOL infrastructure, which will require a network of vertiports and electric chargers to support the aircraft, the regulators first need to define clear certification pathways for the novel designs.

The FAA’s new criteria, intended for powered lift designs with maximum weights of 12,500 pounds and a maximum capacity of six passengers, were developed using standards in FAA parts 23, 27, 33, and 35. The regulator said it leveraged its work on Archer and Joby’s type certification applications to develop the standards, claiming they will create a more efficient path to developing the certification bases for powered lift projects.

For example, the FAA will no longer need to publish airworthiness criteria in the federal register for public notice and comment, as it was required to do for Archer and Joby’s aircraft, for designs that use the standards in the AC. Applicants can now propose certification bases that draw from previously approved designs, such as Archer’s Midnight, or use equivalent level of safety findings to adopt existing airworthiness criteria for their own projects.

EASA, which had already published an initial set of standards for VTOL projects, made a few key changes in the second issue of its SC-VTOL criteria. Unlike the FAA AC, it will not be subject to public consultation.

The most notable change is an increase of the maximum certified takeoff mass (MCTOM) from 7,000 pounds to about 12,500 pounds, one of many examples of the regulator adjusting standards or wording to better align with the FAA AC.

Another key provision is the introduction of a requirement around electrical wiring interconnection systems (EWIS), which transmit data and signals across aircraft systems. Manufacturers will need to prove these can be operated without risk.

So far, China’s EHang is the only eVTOL manufacturer in the world to achieve type certification, awarded by China’s Civil Aviation Authority (CAAC) for the company’s EH216-S in October. Already, the manufacturer has completed commercial demonstration flights and begun mass production.

Things are moving a bit slower in the West, much to the chagrin of U.S. lawmakers and regulators, who don’t anticipate AAM operations at scale until 2028. It’s no secret that Western officials are wary of Chinese drones and electric vehicles, and the country’s growing AAM industry could be a threat to their dominance in that sphere as well.

Monday’s announcements should help accelerate the technology’s growth in the U.S. and Europe. In the coming months, expect the list of eVTOL companies with type certification bases to grow beyond Archer, Joby, and the handful of companies, among them Lilium and Volocopter, collaborating with EASA.

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The post FAA, EASA Release New Certification Criteria for Air Taxis appeared first on FLYING Magazine.

The European Union Aviation Safety Agency (EASA) on Thursday shared its final opinion on rules and regulations for eVTOL air taxis, drones, and other emerging aircraft with the European Commission. Now, the ball is in the Commission’s court as it determines whether to accept EASA’s policy recommendations.

Opinion No 03/2023 lays out a comprehensive regulatory framework for safe operations of new aircraft types. It introduces requirements for piloted electric air taxi operations, flight crew licensing, air traffic management, and standardized European rules of the air (SERA). The proposal also suggests a criteria and process for the certification and maintenance of remotely piloted drones.

“Such developments, stimulated by a global wave of digitalisation and automation, have reinforced the impetus for the creation of new air mobility concepts in the framework of the ‘smart, green and digital’ cities initiative led by the European Commission under the Sustainable and Smart Mobility Strategy,” the opinion reads.

Safety is at the core of the proposal. But EASA also hopes to promote the acceptance and adoption of emerging aircraft by E.U. citizens, accelerate innovation, harmonize regulatory frameworks across member states, and create an operation-centric, performance-based regulatory framework.

The proposal would complement existing EASA regulations and guidance on unmanned aircraft operations, vertiport design, VTOL certification, and unmanned traffic management in European U-space, protected airspace dedicated to complex operations. It was the last piece of rulemaking from Executive Director Patrick Ky, who was replaced by former Director of Safety and Strategy Management Luke Tytgat Friday.

“This is the last piece of regulation required to enable the launch of VTOL and air taxi services for Innovative Air Mobility,” Ky said. “Once this has passed into law, individual manufacturers and operators will of course need to obtain all the required approvals from various authorities, but the framework rules for these operations will be complete.”

EASA proposes amendments to several existing regulations and the establishment of a few new ones. Specifically, they address the initial airworthiness of unmanned aircraft systems (UAS), the continuing airworthiness of UAS operating in the specific category, and operational requirements applicable to manned VTOL aircraft.

The opinion was informed by about 1,300 comments from industry associations, national aviation authorities, aircraft manufacturers and operators, and service providers following the November 2022 release of a Notice of Proposed Amendment.

So without further adieu, let’s dig in.

New Terminology

EASA isn’t a fan of the term AAM. It argues the FAA terminology does not cover all of the operations that could be performed by these innovative new aircraft and that it limits oversight to operations involving the transport of people and cargo. So, it came up with some new terms.

The first is innovative air mobility, or IAM: the safe, secure, sustainable air mobility of passengers and cargo using emerging designs integrated into a multimodal transportation system.

Within IAM is urban air mobility (UAM), which includes operations conducted in, you guessed it, urban settings. These could be noncommercial, commercial air transport, or VTOL emergency medical services (VEMS) operators.

The other subset of IAM is non-urban air mobility (NAM), covering everything outside the domain of UAM. A UAM operator would be able to fly NAM services, but the reverse would be forbidden. IAM will also include drone operations in the higher-risk certified category.

EASA doesn’t use the term VTOL, either. It instead prefers VTOL-capable aircraft, or VCA, which it defines as “a power-driven, heavier-than-air aircraft, other than aeroplane or rotorcraft, capable of performing vertical take-off and landing by means of lift and thrust units used to provide lift during take-off and landing.”

The new VCA definition means EASA will need to modify its definition of helicopters in order to distinguish between the two aircraft types. It proposes doing so by limiting helicopters to two or fewer lift and thrust units and classifying them in the rotorcraft family.

Certifying New UAS

EASA wants to adopt an operation-centric and performance-based framework, with certification criteria that are proportionate to the type of intended operation and environment. VCA carrying passengers, for example, may be bound to stricter requirements. Manned VCA and complex and critical drone operations, in particular, could require hundreds of flight hours rather than tens.

The agency noted several “peculiarities” of VCA compared to conventional aircraft “that deserve a distinct approach in terms of certification and operational approach.” For example, they rely mainly on electric propulsion, use advanced fly-by-wire flight control systems, have reduced endurance, and require different infrastructure, ground handling, and pilot skills.

The opinion introduces a process for issuing type certification to unmanned aircraft and their control and monitoring units (CMUs). Notably, UAS will not need to be certified in the specific or certified categories.  It also establishes eligibility requirements for CMUs and the guidelines for producing them, including a dedicated CMU type certification.

Continued Airworthiness

In EASA’s opinion (and probably that of many others), UAS need to be routinely assessed to make sure they’re safe to fly. 

To do so, it proposed a delegated act (DA) that would ensure operators adhere to continuing airworthiness (CAW) requirements and an implementing act (IA) laying out provisions for authorities overseeing and enforcing the DA. The requirements cover certified category operations and high-risk operations in the specific category.

The agency also gave CAO.UAS organizations, which are responsible for ensuring CAW, the ability to award Permits to Fly in cases where a UAS airworthiness certification is invalid. This would keep uncertified aircraft that are still capable of safe flight in the air.

UAS operators would be obligated to contract one or more CAO.UAS organizations for CAW management and maintenance purposes. They might be asked to provide certain information, like airworthiness directives. Modifications and repairs of UAS components would need to be approved under Part 21. The document also set CAW requirements for CMUs.

VCA and Drone Operations

A big concern around AAM—excuse me, IAM—operations is the ability to certify an initial group of pilots to fly VCA. EASA addressed this and more in its opinion.

The agency says it is developing comprehensive flight crew licensing requirements for manned VCA and that an initial draft will be published in a future Notice of Proposed Amendment. But some pilots will be able to fly even before that arrives.

EASA proposes a “bridging solution” that would allow airplane or helicopter commercial license holders to add a VCA type rating to their certificate after completing training. The recommendation is similar to the one the General Aviation Manufacturers Association (GAMA) and other industry groups made to the FAA regarding powered-lift pilot certification.

Allowing pilots to skip a VCA category rating and add a type rating directly to their license does a few things. For one, it should lower training costs for operators and allow them to certify pilots more quickly. But it would also ensure only experienced pilots fly VCA—with no VCA category license for new pilots, only those who are battle-hardened would be eligible.

EASA plans to keep this provision in place even after releasing its flight crew licensing requirements. It said in the future VCA may be grouped into different classes, but for now it is only establishing type ratings.

To fly drones and VCA, both commercial and noncommercial operators would need to obtain air operator certifications (AOC), a process that could end up being similar to the one required for helicopters.

“The safety levels of VCA operations (refer to the impact assessment of NPA 2022-06) have been compared to current helicopter operations of CAT operators (AOC holders) over congested areas,” the opinion reads. “The comparative assessment of the potential safety hazards posed by VCA operations clearly points to the need of increased mitigating measures in the area of flight crew training, building of safety culture, as well as safety and security risk management.”

Accordingly, EASA plans to use existing regulations—which lay out the requirements for AOC for commercial air transport operators who fly airplanes and helicopters—as the certification basis for VCA operators. Their responsibilities will include setting procedures for aircraft operational control, ensuring pilots are licensed and properly rated, and making sure team members have the appropriate training or clearance.

But what will those operators be permitted to do? The proposed Annex IV lays out general air operations rules, operating procedures, aircraft performance and operating limitations, and instrument, data, and equipment requirements. Each of these sections (except the first) is split into UAM and NAM rules.

One of the big recommendations EASA made is the use of predefined routes for operations in urban environments as a way to mitigate ground and collision risks. The agency is disillusioned by the concept of “free routing,” where VCA and drones could fly more liberally. But it suggested emerging designs flying outside urban settings be treated as any other aircraft.

“Predefined routes may be specific routes or corridors, or geographical areas, which the competent authority may establish in its territory for use by VCA operators where operations may be conducted within acceptable air and ground risks and under specified conditions,” the document reads.

Another key proposed safety provision concerns flight restrictions. For VFR operations in urban areas, aircraft would need to stay at least 1,000 feet above the highest obstacle, or 500 feet in other areas. IFR operations in high terrain would need to happen 2,000 feet above the highest obstacle, or 1,000 feet elsewhere. EASA added that “competent authorities” could safely permit flights in urban areas below these minimums.

The agency also laid out a few operational rules for preflight preparation and emergency situations. Operators would need to pick two or more possible landing sites before taking off, basing their selections on a list of proposed requirements. They’d also need to commit to a performance or energy level that, should they reach it, would require an emergency landing.

What’s Next?

The ball is now squarely in the court of the European Commission, which holds most of the executive power in the E.U. It likely will have an incentive to codify EASA’s proposal in some form, given its commitments to decarbonizing aviation and pressure stemming from the development of the U.S. market.

At present, there is no timeline for the Commission’s approval or denial. It will spend the coming weeks poring over the 58-page document to ensure not only that the proposed VCA operations will be safe, but that they fit into the frameworks of all 27 member states.

However, there is certainly a bit of time pressure—France is expected to host one of the world’s first public electric air taxi displays at the 2024 Paris Olympic Games, including eVTOLs from German manufacturer Volocopter. Having a framework in place by then would be preferable.

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The post EASA Charts Future of Drone, AAM Industry With Proposed Framework appeared first on FLYING Magazine.

In a level of coordination and political mobilization not that uncommon in the industry, what seems like the entirety of general aviation has rallied against the FAA’s proposed rules for training and certification of powered lift pilots. And it did it the old-fashioned way: by penning the agency a strongly worded letter.

The FAA’s 160-page Special Federal Aviation Regulation (SFAR), published in the Federal Register for comment in June, attempts to create a pathway to establish the initial cohort of pilots who will conduct advanced air mobility (AAM) operations using electric vertical takeoff and landing (eVTOL) and other emerging aircraft designs. Think air taxis, such as Joby Aviation or Volocopter.

But despite the clear amount of effort that went into the document, a collective of industry stakeholders spearheaded by the General Aviation Manufacturers Association (GAMA) fears the proposal falls short.

GAMA’s comments are supported by the Aerospace Industries Association (AIA); Aircraft Owners and Pilots Association (AOPA); Experimental Aircraft Association (EAA); Helicopter Association International (HAI); National Air Transportation Association (NATA); National Business Aviation Association (NBAA); and Vertical Flight Society (VFS).

Let’s start with the good. GAMA praised the “dedication and efforts” of FAA rulemakers, acknowledging the challenge of integrating an entirely new model of aircraft into the national airspace system. An accompanying comment from the NBAA highlighted a few provisions in the SFAR the groups support. These relate largely to the inclusion of powered lift instrument procedures, operations in remote areas, and extended permissions for pilot inspections.

But that’s about it. The bulk of GAMA’s letter criticized four key provisions in the SFAR, which the industry feels will impede AAM entry into service, restrict operations, and place undue burdens on pilots, instructors, and manufacturers.

Representing more than 150 of the world’s largest general aviation manufacturers, operators, service providers, and other stakeholders, GAMA has plenty of political clout on Capitol Hill. And with the added support of the NBAA, NATA, and others, chances are these comments will inform the FAA’s final rule.

So, let’s dive into the implications of the industry’s recommendations.

Where It All Started

Though GAMA highlighted the challenge of certifying an entirely new cohort of aircraft and pilots, many of the obstacles the FAA faces are of its own making.

Last year, the agency unexpectedly reversed course on eVTOL certification, opting to certify the aircraft as “special class” powered lift aircraft under FAR 21.17(b) rather than as normal category airplanes with special conditions under 21.17(a). This followed four years of communication that 21.17(a) would be the standard.

While some supported the reversal, it immediately drew criticism from eVTOL manufacturers and stakeholders, including GAMA, whose members “weren’t happy” with the change. A Department of Transportation audit of the FAA, released in June, alleges the rule change significantly impeded the agency’s progress on fostering the new industry.

Interestingly, the FAA cited pilot certification as the catalyst for its decision: “These regulations did not anticipate the need to train pilots to operate powered lift [aircraft], which take off in helicopter mode, transition into airplane mode for flying, and then transition back to helicopter mode for landing.”

But the new certification path may actually complicate pilot training and certification.

It has been brought up that the skills required to pilot two existing powered lift aircraft, the Bell Boeing V-22 Osprey and the F-35B, are very different, though the FAA currently issues former military pilots of these aircraft powered lift pilot certificates with no distinction for these differences. The argument has been made that placing all powered lift aircraft in the same category in a similar fashion creates issues with the uneven distribution of privileges, which GAMA says can only be resolved by requiring additional type-specific training for all aircraft models.

Recommendation 1: Training Should Credit Existing Certificates

According to GAMA, the SFAR proposal “reflects the same path for new powered lift pilots as existing requirements for airplane and rotorcraft.” In other words, it’s largely hours based.

To operate powered lift aircraft, the FAA proposes that airplane and helicopter category pilot certificate holders first obtain a powered lift category rating by completing a certificate at the commercial level followed by a type rating. The add-on would require 50 hours of flight time in the category. This echoes the updated airline transport pilot (ATP) rule, which has been criticized by pilots and airlines for its arbitrarily high time requirement.

All applicants (including Flight Standardization Board pilots, who will likely be the first to fly these aircraft) must log at least 50 flight hours in the category.

This is “not a practical nor appropriate” pathway to certify initial pilots, GAMA says. It argues that airplane and rotorcraft category certificate holders are experienced pilots ready for type-specific training. In short, there is no added value or safety benefit from requiring them to train on generic powered lift aircraft—a category it contends does not yet even exist—before pursuing a type rating.

The agency itself acknowledged the lack of a generic powered lift category in the SFAR: “…The FAA has determined that, unlike airplanes and rotorcraft, it is not feasible to establish classes within the powered lift category at this time.”

In lieu of the two-step process, GAMA recommends the FAA allow a powered lift type rating to be added directly to an airplane or helicopter category pilot certificate, which would remove a big chunk of the hours requirement. This, the group says, aligns with International Civil Aviation Organization (ICAO) standards for certifying pilots for powered lift operations.

GAMA suggests that because the proposal seeks to qualify already-certificated pilots with plenty of experience, the curriculum should be based on training rather than hours. It points to the FAA’s removal of the requirement for military pilots to build time in unrelated training aircraft, which the agency says provides no added safety benefit.

“This requirement is not a training requirement but a time-building requirement,” GAMA wrote. “The economic realities of operating a large powered-lift will incentivize an applicant to build this time in a lower-cost aircraft that might not be relevant to the aircraft they intend to operate commercially.”

Instead of the time required for a powered lift category certificate, GAMA argues that minimums should align more closely with those for an instrument powered lift rating in 61.65(f) and the powered lift rating flight hour requirements in 61.129(e)(3) and 61.129(e)(4). Specifically, GAMA stated, “Industry questions the net safety benefit of § 61.129(e)(1), requirement for 50 hours in a powered-lift for which the SFAR proposes no alternate requirements. This requirement is not a training requirement, but a time-building requirement. The economic realities of operating a large powered-lift will incentivize an applicant to build this time in a lower-cost aircraft that might not be relevant to the aircraft they intend to operate commercially.” 

“GAMA and its members propose instead that the time required in a powered-lift should be linked to meeting the minimums specified in §§ 61.65(f), 61.129(e)(3), and 61.129 (e)(4), which are training-oriented requirements rather than mere time-building metrics.”

Stakeholders were particularly critical of the 50 powered lift flight hour requirement. Few, if any, FSB pilots hold powered lift category ratings at the commercial level and therefore cannot complete flight hours in a powered lift aircraft requiring a type rating. This, the industry argues, would place the burden on the aircraft manufacturer to provide FSB pilot flight hours.

By GAMA’s estimate, requiring a full 50 hours per pilot could extend the FSB process by as many as nine months. And with a growing number of manufacturers looking to enter the FSB process at the same time, that issue is not likely to go away.

The groups contend that the SFAR’s proposed requirement of an airplane or helicopter category rating and the similarities between maneuvering those aircraft and powered lift designs justifies credit toward the 50-hour requirement. It also recommended the FAA consider takeoff and landing operations as equivalent to a flight hour, similar to the way 61.159(b) allows certain night takeoffs and landings to count toward night flight hours. 

Further, the group suggests that after applicants complete an approved training course, the FAA should accept simulator flight training or supervised line flying (more on that later) as sufficient to approve newly rated powered lift pilots for commercial operations.

Recommendation 2: Ax the Dual-Control Aircraft Requirement

One unexpected piece of the FAA’s proposal would require AAM manufacturers to maintain a separate, dual-control variant of their design—or find a different model altogether—specifically for pilot training. The agency contends that before operating a model with single controls, pilots must show they can safely fly a dual-control design with an instructor.

Industry stakeholders have several qualms with this. For one, many powered lift models will not have dual-control alternatives in the near term, since most manufacturers have developed their designs with a single set of flight controls. The rule would also penalize manufacturers who have integrated advanced flight controls by proposing a single pathway for training. 

“These barriers are a direct consequence of FAA reversals on this rulemaking and the content of the proposed SFAR,” GAMA says.

The groups further contend that this “one-size-fits-all approach” could compromise safety, considering the dual-control training aircraft may have very different controls and performance compared to the real deal.

The proposal also fails to consider the safety benefits of simulator-based training, which is at the core of GAMA’s recommendation. It asserts that simulator tech has come far enough to offer realistic scenarios minus the risk, proposing the FAA allow applicants to complete training in flight simulation training devices (FSTDs) under approved training courses.

These courses should cover all maneuver training in certified FSTDs qualified for training, testing and checking the airman certification standards maneuvers outlined in recent FAA rulemaking. They should also conduct part of the practical test in an aircraft, GAMA says, which would eliminate pilot-in-command (PIC) and supervised operating experience (SOE) requirements on the applicant’s new certificate.

After qualification, the groups recommend a post-qualification program under Part 135 that would require supervised line flying in the NAS in order to codify flight experience within the training course.

Currently, the Department of Defense uses simulators, augmented flight controls, and endorsed solo flight experience to allow airplane pilots to operate powered-lift aircraft. GAMA suggests these procedures could serve as a reference point for powered lift training programs.

Taking things a step further, the industry asks the FAA to leverage existing precedent and acknowledge the experience gained in one category of aircraft (i.e. airplanes or helicopters) as “creditably similar” to the requirements for powered-lift qualifications.

Accordingly, it argues the agency does not need to require SOE for all single control aircraft, like the current SFAR proposes. Rather, it should allow for exemptions and open a pathway to awarding letters of authorization to manufacturers that can demonstrate their FSTDs meet the same standard.

As things stand, SOE is not required if a single control aircraft is capable of assessing the five maneuvers laid out in 61.64(f)(1). By creating an alternate pathway, the FAA could lower the number of requests for exemption from this provision, allow SOE to be done virtually or in a simulator, or exempt trainees from SOE altogether if the aircraft requires reduced skill or knowledge to operate.

Recommendation 3: Remove the Red Tape Around Flight Simulators

In the current SFAR, the FAA mandates that manufacturers publish powered lift FSTD qualification performance standards (QPS)—essentially, the agency’s curriculum for simulators—in the Federal Register for public notice and comment. But GAMA argues this requirement could delay entry into service beyond the initial cohort of powered lift aircraft.

Instead, it recommends the FAA allow manufacturers to pick and choose portions of the QPS as appropriate for each type of powered lift design. This, it says, aligns with the National Simulator Program’s approach, which recognizes exceptions for certain FSTDs.

As GAMA points out, many powered lift manufacturers and training partners have already proposed QPSs and had deviations approved. Under the current proposal, these firms risk having to go through the QPS process all over again.

The group adds that because the SFAR would amend FAR 60.1—effectively incorporating powered-lift aircraft into Part 60—the proposed requirement for public notice and comment is unnecessary. Since it would overlap with powered lift FSTD qualifications already outlined in FAA rules, all it would do is strain time and resources.

Stakeholders further ask the FAA to expand the types of simulators that can be used for training, which the SFAR limits to Level C or higher. They argue that new, lower-level technology can meet or even surpass safety requirements, as well as lower costs for the operator—which would make the Level C provision moot.

Recommendation 4: Treat Powered Lift Aircraft the Way They Want To Be Treated

While GAMA’s first three points of contention focus on pilot training and certification, its final criticism turns the spotlight on operations.

As written, the SFAR primarily applies airplane rules to powered lift operations, with few exceptions. That inherently limits the acceptability of rotorcraft rules, which in GAMA’s view fails to consider that many powered lift designs fly just like helicopters.

The core issue here is that the proposed operating rules are prescriptive: They place all powered lift aircraft under the same regulatory umbrella, despite the wide spectrum of capabilities and use cases they possess. Accordingly, the industry is clamoring for performance-based rules.

GAMA suggests the FAA apply operating rules for both airplanes and rotorcraft as appropriate, based on the performance characteristics of each powered-lift aircraft type demonstrated during type certification. Basically, it asks the agency to treat powered-lift as airplanes when they fly like airplanes and as helicopters when they fly like helicopters.

The FAA could do this by approving individualized operating rules based on each operator’s safety management system, training requirements or other factors, achieved through an operations specification for Part 135 air carriers or a letter of authorization for Part 91 operators. This would allow them to collect and share data about the suitability of rotorcraft operational rules for powered-lift and adjust current standards.

It would help the FAA accommodate the range of vehicle types and performance capabilities in the new category. The industry recommends the agency revisit its proposal and take inventory of operational data every two years in order to make necessary refinements.

There are a few specific operational requirements GAMA highlighted. Under proposed 91.155, powered lift aircraft would be subject to the same visibility requirements as airplanes. But since they can maneuver like helicopters, possess VTOL capabilities, and can operate safely at low airspeeds and altitudes, the group contends helicopter rules should apply.

It argues the same for minimum safe altitudes, asserting that powered lift designs have similar emergency maneuverability to helicopters and therefore should be allowed to fly below the safe minimum for airplanes. In the SFAR, the FAA counters that some powered lift aircraft lack the autorotation capabilities of helicopters and could lose altitude when transitioning from forward to vertical flight.

Overwater operations are one of the few areas the FAA proposed permitting helicopter rules for powered lift. But again, GAMA disagreed. This time, it argues that some eVTOLs glide on fixed wings like airplanes when carrying passengers over water. As such, the agency should apply airplane rules to these designs.

The industry’s final point of contention concerns fuel reserve requirements, which the FAA proposes should be time-based. But because powered lift aircraft can land vertically like helicopters to find runways when fuel is low and can operate in reduced visibility, stakeholders counter with a performance-based system.

That framework would instead account for mission- and aircraft-specific conditions. Through a mission-specific range and endurance hazard assessment that covers weather, air traffic, and airport conditions, mission planning, and other factors, the industry argues manufacturers could determine how much reserve fuel is needed.

Ball Now in the FAA’s Court

GAMA and the other groups have a few peripheral concerns. The biggest is the SFAR’s Regulatory Impact Analysis, which they say excludes key costs and resources and paints a misleading picture of the FAA’s ability to implement the new rules.

But really, the industry’s recommendations boil down to four key points:

1. Allow a powered lift type rating to be added to airplane and helicopter category pilot certificates.
2. Add language to create an alternative pathway to powered lift training beyond dual-control aircraft.
3. Grant deviation authority in the FSTD QPS process.
4. Add language like “unless otherwise specified” to operational provisions applying airplane and helicopter rules to powered lift operations.

These four changes alone won’t achieve the industry’s vision. But they would help shift powered lift pilot training and certification away from hours-based standards and toward a more practical, accessible, and cost-effective pathway. They would also allow early powered-lift aircraft to operate the way they were built to be operated.

After two months, the proposed SFAR this week officially closed for comments. Now, the ball is in the FAA’s court—and the pressure is on from all corners of the industry.

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The post GAMA and Other Industry Groups Cast Shade on FAA Powered Lift Pilot Proposal appeared first on FLYING Magazine.

When a federal agency, such as the FAA, seeks public input on a proposed policy, providing a substantive comment is an essential way to voice concerns, offer suggestions, and contribute to the policymaking process. With Modernization of Special Airworthiness Certificates (MOSAIC) on the horizon, you may be looking to add your thoughts to the process but aren’t sure how to create a comment that will have the effect you want.

A well-structured and thoughtful comment can significantly impact an agency’s final decision. In this guide, we will explore the key components of making a substantive comment to the FAA, highlighting examples and offering do’s and don’ts for effective commenting.

Do’s for Making a Substantive Comment

Take Time to Understand the Proposal

Thoroughly read and comprehend the FAA’s proposal to grasp its objectives, implications, and intended outcomes. You can read the MOSAIC proposal and take notes on how it may impact your personal or professional role in aviation. 

Analyze the potential effects on safety, the environment, and industry. You may want to think about composing a comment that addresses a specific impact. Make notes that reflect your observations. Your note may not be your final comment, but you can use it to help construct the one you send to the FAA.

• READ MORE: Light-Sport Category Could Expand Under Proposed FAA Rule Changes

Example of a reflective note: “In the FAA’s proposal for implementing new air traffic control procedures, there is a potential impact on small airports and general aviation pilots, as they might face increased congestion and altered flight paths.”

Provide Specific Evidence and Data

When you’re ready to craft your comment, support it with factual data, research, and evidence to strengthen your argument. If you can, use statistics, studies, and case examples to back up your assertions and bolster your position. 

Example: “I recommend that the FAA review the recent study by XYZ research group, which highlights the safety benefits of the proposed runway extension at ABC airport.”

Offer Constructive Suggestions

If you are opposed to a potential rule or aspect of one, try to present viable alternatives or solutions to address concerns and improve the proposed policy.

Consider the feasibility and practicality of your suggestions.

Example: “Instead of imposing a blanket curfew on all flights, the FAA should consider implementing noise reduction measures for late-night operations at major airports.”

Be Clear and Concise:

Articulate your points in a well-organized and coherent manner. Avoid jargon or technical language that may confuse readers. Keep your comment short so that it can be quickly read and digested.

• READ MORE: More Training Aircraft in Reach With FAA’s Proposed MOSAIC Rule

Example: “I strongly advocate for the FAA to prioritize the implementation of bird strike prevention measures at airports with a history of avian-related incidents.”

Don’ts for Making a Substantive Comment

Avoid Emotional Language

Refrain from using emotional or inflammatory language that may undermine the credibility of your comment. Focus on rational arguments and evidence-based reasoning.

Example of an emotional claim: “The FAA’s proposal is a disaster! It will destroy our neighborhoods and ruin our quality of life!”

Steer Clear of Generalizations

Be specific and avoid making broad, unsubstantiated claims that lack evidence.

Example of an overgeneralized claim: “This proposal will lead to disastrous consequences for the aviation industry.”

Don’t Rely on Form Letters or Boilerplate Phrases

While form letters can show collective concern, personalized comments carry more weight. If many commenters send the same text, those responses may be lumped together rather than considered individually. 

Customize your comment to include personal experiences or perspectives.

Example: “Although I support the general premise of the proposed air traffic control reform, I believe it should incorporate more considerations for rural airports like the one I operate.”

Avoid Confrontation

If you want to ensure your comment will be read and make an impact, it’s important to maintain a respectful tone, even if you disagree with the proposal or other comments. Promote a constructive and collaborative discussion.

Example: “While I understand the concerns raised by other commenters, I believe that we can find common ground by enhancing safety protocols and ensuring continued airspace access for all stakeholders.”

Engaging in the rulemaking process with substantive comments is a great way to actively participate in shaping federal policies like those proposed by the FAA. By adhering to the do’s and don’ts outlined in this guide, you can create impactful and persuasive comments that contribute to the agency’s decision-making process and help achieve better policies for aviation safety, efficiency, and fairness. Remember, your voice matters, so use the opportunity to make a difference through thoughtful and well-informed commenting.

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