GAMA and the NBAA, backed by AOPA, HAI, NATA and VFS, have formally submitted comments to the FAA's proposed Special Federal Aviation Regulation (SFAR) for Integration of Powered-Lift: Pilot Certification and Operations; Miscellaneous Amendments Related to Rotorcraft and Airplanes.

GAMA methodically worked with its membership to review the proposal and put forward comments that reflect the SFAR's critical role in enabling initial powered-lift operations. The SFAR will also provide the regulatory environment required to collect necessary operational data that will inform future permanent rule-making.

“The world's leading AAM manufacturers have collaborated on targeted comments that if accepted, will improve aviation safety and alleviate regulatory uncertainty forced on the industry by FAA reversals of key decisions. With the FAA's publicly stated target date for enabling initial eVTOL and other powered lift aircraft entry into service of early 2025, there is an urgent need for a performance-based regulatory framework that permits the industry to complete the aircraft certification, pilot licensing and operational approval processes necessary to meet this timeline. Just last month, the FAA doubled down on its commitment to its early 2025 initial operational timeline with the publishing its first AAM implementation plan dubbed 'Innovate28'. This document calls for integrated 'at scale' AAM operations in key cities by 2028 as a showcase in time for the 2028 Olympic Games in Los Angeles. To achieve this 'at scale' objective, near term initial operations must be enabled,” says GAMA president and CEO Pete Bunce.

“We acknowledge the significant work and challenges created for both industry and government by the decision to type certificate eVTOL aircraft as powered-lift and urge the FAA to take full consideration of the expertise behind the safety-based comments provided by a very broad group of AAM manufacturers, operators and industry trade groups. We must ensure that the final SFAR establishes a practical pathway to initial pilot certification as well as an appropriate operational framework consistent with the US led initiative at ICAO. Doing so would provide a clear regulatory framework to ensure safety and facilitate industry growth in the US and worldwide. Failure to provide timely and practical regulatory certainty will jeopardise the US industry's global leadership position in advanced air mobility,” he continues.

In its comments, GAMA focuses on four critical areas of interest to be addressed within the SFAR: pilot certification, dual controls, flight simulation training devices and operational rules. GAMA and the entire AAM community urge the FAA to enable the initial pilot cadre to be certificated by adding a powered-lift type rating to an existing aircraft or helicopter category type certificate and to apply the appropriate operating rules for powered-lift operations based on the performance characteristics of each aircraft type. More specifically, the legacy fuel-based energy reserves and the antiquated requirement to design and certificate a dual control variant of each aircraft platform needs to be addressed. There is also significant concern that there are not adequate FAA resources to support the SFAR's framework as proposed in a timely manner, especially as it relates to pilot certification and training.

The NBAA weighed in on two initiatives, its comments, informed by its AAM Roundtable and Emerging Technology Committee. First, it described several concerns regarding the proposal and outlined practical recommendations to ensure safe pilot qualification and operations.

The stakeholders explained the proposal is not aligned with 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 utilising 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,” says the associations. “The proposal for airman qualification creates a barrier for most AAM aircraft manufacturers to enter the US 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 VTOL capabilities.

“Close alignment with ICAO standards and guidance will allow US-based manufacturers and operators to achieve anticipated operations launch dates in 2025 and ensure a lively AAM industry in the US far into the future,” they conclude.

Second, NBAA 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 US 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 emphasised the importance of safety, while also encouraging entry into service in a timely and thoughtful manner. Looking to the long term, it urged the agency to work closely with stakeholders to facilitate scaled operations. The association also highlighted 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 realising the goals of advanced air mobility is a complex and multifaceted endeavour,” 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: “Taken together, the industry's input on these two key initiatives will inform the work needed to ensure that the US remains the world leader in fostering the development, integration and utilisation of promising advanced air mobility technologies.”