NBAA Pushes FAA for Safety-First Approach to Proposed Drone Regulations

Contact: Dan Hubbard, 202-431-5970, [email protected]

Washington, DC, Oct. 6, 2025 - The National Business Aviation Association (NBAA) has provided the Federal Aviation Administration (FAA) and Transportation Security Administration (TSA) with feedback on proposed drone regulations, stating any rule must ensure that safety is the highest priority.

The FAA's portion of the proposed rule would allow certain low altitude, beyond visual line of site (BVLOS) missions by unmanned aircraft systems (UAS) without waivers or exemptions and would also create operating rules for UAS package delivery, agriculture, surveying, public safety and flight testing for compensation or hire. The provisions were outlined in a recently published notice of proposed rulemaking (NPRM).

"NBAA has a unique interest in this NPRM, as many of our members who have operated manned aircraft for decades are now adding UAS to their mission planning," said Heidi Williams, NBAA vice president of air traffic services and infrastructure. "In addition, some NBAA member companies use UAS exclusively in furtherance of their businesses."

Williams added that the association considers the proposed rule as foundational to advancing the integration of UAS and other emerging technologies into the National Airspace System (NAS) and its importance for safety, national security and operational efficiency. "However, NBAA members shared several concerns, including the need for electronic conspicuity, or sharing of position, for all aircraft in the NAS," she said.

"Electronic conspicuity solutions must be interoperable within the NAS and among relevant user groups, and must consider current and future technologies," Williams noted. "ADS-B is one, but not the only means, of achieving effective electronic conspicuity. Industry standards could be used to identify appropriate means of achieving electronic conspicuity. Universal position sharing through electronic conspicuity across all aircraft in the NAS would also negate the need for complex changes to the existing right-of-way regulations, since UAS would simply detect and avoid all other aircraft."

Part 108 also outlines airworthiness requirements for aircraft to be flown under these rules.

In its comments, NBAA advocated for retaining the existing criteria for making decisions (CMD) process as an industry standard for UAS airworthiness, stating, "The current CMD process, a working method for airworthiness, has contributed to a very high level of safety and should not be discarded without justification."

Meanwhile, the TSA proposed changes would impose security measures on these operations, particularly package delivery operations. These proposed measures include security threat assessments for certain persons engaged in BVLOS operations and implementation of a formal, TSA-approved security program by certain types of operations.

NBAA urged the TSA to withdraw its proposed regulations from this larger rulemaking and undertake a separate risk-based rulemaking process.

Read NBAA's full comments.

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Founded in 1947 and based in Washington, DC, the National Business Aviation Association (NBAA) is the leading organization for companies that rely on general aviation aircraft to help make their businesses more efficient, productive and successful. The association represents more than 10,000 company and professional members and provides more than 100 products and services to the business aviation community, including the NBAA Business Aviation Convention & Exhibition (NBAA-BACE), the world's largest civil aviation trade show. Learn more about NBAA at nbaa.org.

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