Intelligent Infrastructure - AAM Backbone

INTELLIGENT INFRASTRUCTURE is the foundation for Advanced Air Mobility (AAM), drawing from the FAA's Part 108 BVLOS NPRM.

Intelligent Infrastructure: The Unseen Backbone of Advanced Air Mobility

The Federal Aviation Administration 's proposed Part 108 rule is not merely about allowing drones to fly beyond the pilot's sight; it is the foundational regulatory step toward a future of Advanced Air Mobility (AAM). This future envisions a dense, integrated ecosystem where small package delivery drones, large passenger-grade air taxis, and everything in between operate simultaneously at low altitudes. Managing this complexity—where systems of all sizes share the sky in closer quarters and higher volumes—is impossible with today's infrastructure. The Federal Aviation Administration 's NPRM makes it clear that Intelligent Infrastructure is not a supporting actor; it is the most vital enabling platform for this new era of flight.

U.S. Department of Transportation Secretary Sean Duffy and the administration that understands the critical need for INTELLIGENT INFRASTRUCTURE , Intelligent Infrastructure Economic Zones , ASOCC 's, the U.S. Department of Autonomy , and the evolution to the National Urbanautics and Autonomy Administration (NUAA) .

Intelligent Infrastructure for Scaled Operations

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The proposed rule implicitly and explicitly mandates a network of resilient, interconnected Public Infrastructure Network Nodes (PINNs) to provide the necessary "central nervous system" for AAM. This infrastructure is critical for three core reasons:

1. It is the Prerequisite for Scalable Traffic Management

The NPRM introduces requirements for strategic deconfliction and conformance monitoring (primarily through proposed Part 146 service providers). This is a digital, automated form of air traffic control for low-altitude operations.

Without Intelligent Infrastructure: These services are limited to isolated, proprietary networks. They cannot achieve the universal, real-time data exchange required to prevent collisions between drones from different operators in a crowded sky.

With Intelligent Infrastructure: PINNs provide the ubiquitous communications backbone (e.g., 5G, satellite-terrestrial hybrid networks) and distributed edge computing required to run these services at scale. They form the physical layer that allows the digital UTM (UAS Traffic Management) and future xTM (extensible Traffic Management) ecosystem to function, making it possible to know "what drone is in the sky" at any given moment.

2. It Enables the AI and Automation Required for Safety

The rule's reliance on Detect-and-Avoid (DAA) systems and automated pre-flight checks means that vehicles must be intelligent and connected.

Without Intelligent Infrastructure: DAA is limited to what's on the vehicle itself ("onboard sensing"). This is insufficient for detecting non-cooperative objects (e.g., a bird, a mast) or managing complex, high-density airspace where threats emerge faster than any single vehicle can process.

With Intelligent Infrastructure: A network of ground-based sensors (e.g., radar, acoustic arrays, optical sensors) on PINNs can create a common situational awareness picture. This data can be fused and processed using AI at the edge and then broadcast to all vehicles in the area, creating a cooperative, networked safety system far superior to any standalone solution. This is how you safely operate large numbers of vehicles in "closer quarters."

3. It Provides the Resilience and Security for Critical Operations

The NPRM includes cybersecurity requirements and emphasizes operational reliability.

Without Intelligent Infrastructure: Networks are fragile, relying on commercial cellular or private RF links with gaps in coverage and significant vulnerability to intrusion, jamming, or spoofing.

With Intelligent Infrastructure: A purpose-built, hardened network of PINNs provides redundant, secure, and resilient communications pathways. This ensures that command-and-control (C2) links remain stable, cybersecurity protocols are enforced at the network level, and operations can continue even if one node fails. This is non-negotiable for scaling operations and eventually carrying passengers.

Conclusion: The Infrastructure Must Precede the Scale

The FAA's Part 108 NPRM correctly focuses on performance-based outcomes rather than prescribing specific technologies. However, it creates a regulatory framework whose very goals cannot be met without the widespread deployment of Intelligent Infrastructure.

You cannot have advanced air mobility without advanced infrastructure.

PINNs provide the indispensable highways of data, sensing, and computation that will allow AI-driven systems to navigate the physical world safely and efficiently. They are the critical public utility that will unlock the economic and societal potential of autonomous flight, transforming our airspace from a void to be crossed into an intelligently managed network for transportation.

Summary of Comments on the FAA-2025-1908-0023

The FAA Notice for Part 108 BVLOS Proposed Rulemaking (FAA-2025-1908-0023). The comments have been categorized, and the key issues are highlighted.

Overall Summary

The comments reveal significant concerns from a diverse group of stakeholders, including individual remote pilots, manned aircraft operators (especially balloonists), small business owners, public safety agencies, and industry associations. While there is support for the concept of normalizing BVLOS operations, the proposed rule is perceived by many as flawed, potentially unsafe for manned aviation, and economically prohibitive for small operators.

Category 1: Safety Concerns & Risk to Manned Aviation

This was the most prominent and passionately argued category, particularly from pilots of manned aircraft.

Key Issue: Collision Risk with Non-Cooperative Aircraft: The most frequent and critical safety concern focuses on the risk to manned aircraft, especially hot air balloons and gliders.

Lack of Electronic Conspicuity: Balloons often have no electrical systems and are not equipped with ADS-B Out or transponders. The NPRM's reliance on strategic deconfliction and electronic surveillance (§ 108.190, § 108.825) is seen as completely ineffective for detecting these aircraft.

Maneuverability Limitations: Balloons cannot take evasive action. A collision with a UAS would likely be catastrophic.

Inadequate Hazard Finding: Commenters (e.g., Dan Gerbus, David Fuller) argue the FAA's finding that BVLOS operations "would not create a hazard" is invalid for this class of aircraft and demand explicit recognition of this risk in the final rule.

Key Issue: Inadequate Detect-and-Avoid (DAA) Requirements: Many commenters state that the rule's performance-based approach to DAA is insufficient.

There are strong calls for mandatory, redundant, onboard DAA technology that can detect and avoid aircraft without electronic signals, placing the entire burden of avoidance on the UAS.

Key Issue: Right-of-Way Inversion: Commenters are alarmed that the proposed framework effectively inverts established right-of-way rules (§ 91.113), putting the onus on manned aircraft (which have the right-of-way) to be seen electronically rather than on the UAS (which must yield) to see and avoid.

Category 2: Operational & Technical Concerns

Comments addressed the practical implementation of the proposed rules.

Key Issue: Certification and Training Standards: Several comments criticize the lack of rigorous, standardized personnel certification.

Some argue that key personnel like Operations Supervisors should be required to hold a specific BVLOS or Large UAS endorsement on their Remote Pilot Certificate, similar to other FAA safety-critical roles.

Others note the absence of a defined knowledge test, like the Part 107 exam, which they believe is essential for ensuring competency.

Key Issue: Hardware Restrictions and Sourcing: Concerns were raised about potential restrictions on using foreign-made technology, particularly reliable docking systems from companies like DJI.

Commenters (e.g., Porche Aerial) warn that limiting operators to U.S.-only or FAA-preapproved manufacturers would stifle innovation, delay adoption, and distort the market, unfairly harming small businesses that rely on cost-effective, proven technology.

Category 3: Economic & Accessibility Concerns

A major theme was the fear that the rule would create an uneven playing field.

Key Issue: Barriers for Small Businesses: Numerous small business owners and individual Part 107 pilots expressed concern that the cost of compliance (advanced DAA tech, certification processes, SMS) would be prohibitively expensive.

They argue the rule is tailored for large corporations (e.g., Amazon, Zipline) and could lead to industry consolidation, crushing the small innovators and entrepreneurs who built the drone industry.

Key Issue: Need for a Tiered or Scalable System: The common recommendation is for the FAA to implement a risk-based, tiered compliance model. A small operator flying a light UAS in a rural area should not face the same financial and technical burdens as a large company conducting urban package delivery with heavy UAS.

Key Issue: Impact on Public Safety: Volunteer fire departments and other small public safety agencies (e.g., Capon Springs Volunteer Fire & Rescue) highlighted their critical need for BVLOS capabilities in rural/search and rescue operations. They urge the FAA to ensure the final rule includes "reasonable and practical safety requirements" that are attainable for resource-constrained public organizations.

Category 4: Regulatory Structure and Transition

Comments focused on the rule's relationship with existing regulations and its implementation.

Key Issue: Unclear Transition Path from Part 107: Current Part 107 waiver holders are concerned about the lack of a defined grandfathering or streamlined transition process to Part 108, fearing their previous investments and efforts will be wasted.

Key Issue: Protection for Recreational Flyers: While recreational operations are excluded from Part 108, commenters request explicit reaffirmation that their flying under 49 U.S.C. 44809 will remain unaffected and that voluntary pathways for hobbyist innovation be considered.

Key Issue: Performance-Based vs. Prescriptive Rules: While some support the performance-based approach for flexibility, others see it as too vague and lenient, preferring more prescriptive "rules of the road" for clarity and enforcement.

Category 5: Supportive Comments with Caveats

Some comments expressed general support for the FAA's effort to advance BVLOS operations, acknowledging it as a necessary step for industry growth. However, this support was almost always conditional, paired with recommendations to address the safety and equity concerns listed above.

Intelligent Infrastructure is Critical

The collective feedback on NPRM FAA-2025-1908-0023 indicates that while the industry desires a path forward for BVLOS, the proposal in its current form is viewed as potentially unsafe for manned aviation and economically threatening to small businesses. The key to a successful final rule will be addressing the critical safety gap regarding non-cooperative aircraft and ensuring the regulatory framework is scalable and accessible to operators of all sizes.