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uAvionix Submits Comments on FAA Part 108/146 NPRM

With just under a week to go, uAvionix has officially submitted our comments to the FAA’s Beyond Visual Line of Sight (BVLOS) NPRM – also known as Part 108/146. At more than 700 pages, the rule is broad, but we focused our input on the areas where uAvionix brings unique expertise and experience.
Here are the highlights of our comments:
- ADS-B In Requirement – We support ADS-B In as the baseline for BVLOS operations and recommend clarification on acceptable means of compliance.
- Portable EC Devices – We endorse portable Electronic Conspicuity devices as alternatives to permanent ADS-B Out installations for crewed aircraft, and propose a fast-track approval path.
- Selective ADS-B Out/EC for UAS – We encourage a risk-based approach that allows ADS-B Out or EC on certain low-volume, high-consequence UAS operations.
- Non-Cooperative Detection – We challenge proposed requirements that are not economically scalable and could create spectrum challenges.
- C2 Frequencies – We support licensed spectrum for higher-risk operations and advocate harmonization of FAA Part 108 with FCC Part 88 in the 5030–5091 MHz band.
- Automated Data Service Providers – We support the concept of Part 146 ADSPs and propose a cooperative surveillance standard to complement ADS-B In.
Our full public comments can be found here https://www.regulations.gov/comment/FAA-2025-1908-1386
If you align with any of these positions, feel free to reference our comments or reach out to engage further.