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:

  1. ADS-B In Requirement – We support ADS-B In as the baseline for BVLOS operations and recommend clarification on acceptable means of compliance.
  2. 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.
  3. 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.
  4. Non-Cooperative Detection – We challenge proposed requirements that are not economically scalable and could create spectrum challenges.
  5. 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.
  6. 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.