Iris Automation, uAvionix Partner for Low Altitude, Wide Area BVLOS: Integrating C2 and DAA

BVLOS, Iris Automation, uAvionix, detect and avoid, command and controlIris Automation and uAvionix Partner for Low Altitude Wide Area BVLOS: Integrating Detect and Avoid (DAA) with Command and Control (C2)

For BVLOS flights to scale, regulators must see a reliable solution for ensuring that drones don’t run into drones or manned aircraft.  Integrating ground-based detect and avoid technology with command and control could provide an easily accessible solution, providing a comprehensive view of the air traffic and potential obstacles in low altitude airspace.

by DRONELIFE Staff Writer Ian M. Crosby

Iris Automation and uAvionix have announced a strategic partnership that will integrate Iris’ Casia G ground-based collision avoidance data into uAvionix’s SkyLine services, resulting in combined Command and Control (C2) and Detect and Avoid (DAA) services. This new integration will provide drone operators with advanced low altitude airspace awareness and leading command and control connectivity at an affordable price.

“Integration of the Iris’ Casia G data is another step toward enabling scalable and achievable Beyond Visual Line of Sight (BVLOS) flights for UAS operators,” said uAvionix Managing Director Christian Ramsey. “With better range than the human eye and artificial intelligence (AI) to analyze the optical image, the system can rapidly detect and classify other aircraft or objects in the air. That data is then ingested and combined with other sensor data, including ADS-B, and displayed for UAS operators in the SkyLine system. It’s the type of novel integration and approach that we feel is important for a Command and Control Communications Service Provider (C2CSP) to provide and one that we have seen successfully meets the safety, efficiency and reliably needs of rapidly evolving UAS operations.”

uAvionix is the leader in cooperative aircraft detection with its ADS-B IN solutions for UAS such as pingRX Pro and pingStation3. Meanwhile, its SkyLine software services enable the visualization of air traffic (ADS-B) data through the first cloud-based C2 network management platform. Together, these solutions grant total optimization of the aircraft’s C2 communications links and enhanced situational awareness for remote UAS operators. The uAvionix SkyLine system inclusive of airborne radios, ground stations, and DAA sensor data is central to two FAA BVLOS waivers as well as the company’s recent FAA BVLOS exemption.

“We couldn’t be more excited for this partnership,” said Iris Automation CEO Jon Damush. “uAvionix has long been an industry leader in our space, and their ability to combine multiple technologies to address long standing gaps in our market is unmatched. Combining reliable and protected C2 communications with comprehensive situational awareness just makes sense. With the addition of our non-cooperative aircraft detection data, operators will now have a turn-key solution for their BVLOS operations.”

Iris Automation’ Casia system relies on computer vision and artificial intelligence to detect non-cooperative intruder aircraft that pose the risk of a ‘near mid-air collision’ (NMAC), giving a drone time to adjust its flight path and grant right-of-way to crewed aircraft. The Casia G system is a ground-based variant offering a large area of coverage that can be expanded infinitely with the deployment of additional ground-based nodes.

The Casia G system’s data will complement the ADS-B data from uAvionix, enabling cooperative aircraft positions to be validated through two independent sensors and rapid identification of non-cooperative aircraft. The combined systems grant a level of comprehensive situational awareness greater than that of existing single-sensor-based systems. Integrating the Casia G data into the uAvionix SkyLine system will allow for multiple and diverse air traffic data points from both cooperative and non-cooperative aircraft to be displayed and used by UAS operators for DAA functions. Both companies are actively collaborating on this integration, which is expected to be available later this year.

Read moe:

Ian attended Dominican University of California, where he received a BA in English in 2019. With a lifelong passion for writing and storytelling and a keen interest in technology, he is now contributing to DroneLife as a staff writer.

Red Cat’s Teal 2 Gets Remote ID Certification as US Defense Logistics Doubles Order

 Red Cat Holdings, Inc. (Nasdaq: RCAT), a drone technology company integrating robotic hardware and software for military, government and commercial operations, announced August 22 that the military-grade  Teal 2 had received Remote ID certification from the Federal Aviation Administration (FAA).  The news was closely followed on August 23 by an announcement that the U.S. Defense Logistics Agency (DLA) had doubled its order for Teal 2, ordering an additional 172 units plus spare parts and training.  The DLA order now totals over $5 million.

The Teal 2 is a US-manufactured, short range reconnaissance (SRR) drone.  With the motto “Dominate the Night™” they are specially designed for tactical work even in darkness: ideal for military, law enforcement, firefighter, and wildlife management applications.

Teal 2 and Remote ID

All operators in the US must comply with the Remote ID rule as of September 16, 2023.  Remote ID allows UAS in flight to provide identification and location information that other parties – such as law enforcement – can receive via a broadcast signal. This helps security agencies identify the operators of rogue drones – and understand which drones are operating legitimately in the space.  For a tactical drone like Teal 2, which may be deployed in emergency situations, Remote ID is a critical tool for integration into first responder missions.

Red Cat’s integrated Remote ID system goes above and beyond the technology being used in competing drones. It sits inside the Teal 2 vehicle, broadcasting data from the flight control system about once per second to ensure a high level of accuracy. The use of Bluetooth 5 allows the signal to be transmitted over a longer distance — as far as a mile — significantly outpacing the range of other systems on the market.

“I think this really speaks to who we are at Red Cat and what our values are,” said Brendan Stewart, vice president of regulatory affairs at Red Cat. “We view ourselves as an aircraft manufacturer, as opposed to a consumer electronics manufacturer building something that flies. What sets us apart is our ability to look into the future, figure out what the FAA’s goals are in implementing a particular regulation, and then build technology that allows us to not only meet the regulation today, but sets our customers up for long-term success in a changing regulatory environment.”

Red Cat recently tested its Remote ID integration in New York with NUAIR acting as the independent third-party validator, using ASTM International standard F3586-22 for the means of compliance testing. Working alongside individuals from the standardization committee who helped write the regulations for Remote ID, NUAIR personnel also provided mission commander, visual observers, airworthiness check and test card formulation.

“Remote ID is another great step forward to safely integrate drones into the national airspace and move the commercial drone industry forward,” said NUAIR CEO Ken Stewart. “NUAIR has conducted multiple validations for other ASTM Standards including sUAS parachute recovery systems and we are happy to see Red Cat receive their certification following our successful validation of their Remote ID solution.”

All Teal 2 systems sold for operation within the U.S. will be manufactured with Remote ID included. Red Cat is also creating a pathway for owners of previously manufactured Teal 2s to have Remote ID modules installed on their units to comply with FAA regulations.

“We’ve put a lot of effort, a lot of resources and a lot of capital into this to make sure that our customers won’t have a service interruption,” said Brendan Stewart. “For us at Red Cat, standing behind the quality of our products means ensuring that they’ll remain operational and compliant with regulations long into the future.”

New Order of Teal 2 Drones

Teal will deliver an additional 172 units of the Teal 2 drone plus spare parts and training to the DLA. Earlier this month, Red Cat announced an initial order from the DLA for 172 units, also totaling $2.6 million. Combined, the two orders now total $5.2 million.

Both orders were requested by U.S. Air Force Security Forces, whose role is to defend Air Force bases and installations.

“The Air Force needs to secure its airfields and bases 24/7, and the Teal 2 offers the highest-resolution night vision in its class,” said Red Cat CEO Jeff Thompson. “We’re honored that the Air Force has now doubled its order, to more than $5 million.”

The procurements were sourced by global operations support company Noble Supply & Logistics, LLC (NOBLE) as part of the DLA’s Special Operational Equipment Tailored Logistics Support (SOE TLS) Program.

NOBLE is a DLA-designated provider for the SOE TLS Program. This 10-year program, capped at $33 billion, covers the delivery of logistics support to federal agencies, military bases and other DLA customers worldwide, helping them meet their SOE requirements.

Read more:

FAA Releases Air Taxi Implementation Plan: Operations by 2028

FAA Air Taxi Implementation Plan

image: FAA

The FAA has issued an implementation plan for integrating air taxis and advanced air mobility (AAM) into the National Airspace (NAS) by 2028.

The  implementation plan is directed towards the “Innovate28” AAM project, in reference to the agency’s goal of allowing AAM operations at limited locations by 2028.  The plan  “includes various components and the sequence they will occur in for operations to be at scale at one or more sites by 2028,” says the FAA announcement.

“This plan shows how all the pieces will come together allowing the industry to scale with safety as the north star,” said Deputy FAA Administrator Katie Thomson.

The plan will serve as a foundation for making entry into service routine and predictable by maximizing the use of existing procedures and infrastructure. It addresses how the agency and partners will certify aircraft and pilots, manage airspace access, ensure pilot training, develop infrastructure, maintain security, and engage communities.

The plan also includes a planning guide that can be applied to any site, laying out key integration objectives and sequences.

The Innovate28 (I28) project continues the FAA and Department of Transportation (DOT) focus on AAM.  The U.S. DOT formed the  Advanced Air Mobility Interagency Working Group in 2022.  The FAA released the airspace blueprint for air taxis in May of 2023, and proposed a comprehensive rule for training and certifying AAM pilots in June of 2023.  Shortly after announcing the publication of the blueprint for AAM at the AUVSI Xponential show in spring of 2023, former FAA Acting Administrator Billy Nolen announced that he would leave the agency: Nolen now works for AAM manufacturers Archer Aviation.

What’s Innovate28?

The report emphasizes that AAM operations will happen in a “crawl, walk, run” approach: beginning with entry into service (EIS) and culminating in AAM operations at scale.  Innovate 28 will be one step between EIS and operations at scale.

Innovate28 is a project that will bring public and private stakeholders together to move beyond EIS and deliver regular AAM operations at specific key locations.  The project will result in significant data to inform future rulemaking and documented, repeatable processes for certification, operations, infrastructure, and more.

What’s Will I28 Operations Look Like?

Initially, the plan for I28 says that pilots will fly crewed AAM along predetermined flight schedules from existing heliports and airports, modified as appropriate (with charging for electric vehicles, for example.)  AAM will be supported by Air Traffic Control.  AAM may operate up to 4,000 feet in urban areas “using existing or modified low altitude visual flight rules (VFR) routes where possible within controlled Class B and C airspace around major airports,” says the FAA.  (Much more detail can be found in the report.)

The report also states that stakeholders will need to consider many issues related to AAM operations, requiring communication and cooperation between government agencies.  Among the working issues are potential required upgrades to the electrical power grid; border and homeland security; noise considerations; and the environmental impacts of AAM.

Read more:

Red Cat to Supply 200 Long-Range, High-Speed Drones to Ukraine

Red Cat Holdings, Inc. , a military technology company integrating robotic hardware and software to protect and support the warfighter, announced that it will fulfill a purchase order to provide 200 long-range, high-speed FPV (first-person view) drones to Ukrainian drone pilots engaged in conflict with Russia.
The FPV drones will be delivered to Ukraine in June. The drones to be shipped have the highest power-to-weight ratio in the drone industry, offering increased maneuverability, especially when combined with the FPV functionality of the drones. These FPV drones can also fly in GPS-denied and GPS-jammed battlefield conditions.
“Fortunately, Red Cat has the U.S. manufacturing capacity required to quickly deliver on such orders,” said Red Cat CEO Jeff Thompson. “We are pleased to provide our product to Ukrainian drone pilots, and we look forward to continuing to engage with them, including by providing our new nighttime drone, the Teal 2. Much of drone activity is performed at night, and the Teal 2 is at the forefront of nighttime drone capabilities.”
Teal Drones partners with Doodle Labs for U.S. Army’s SRR program

Red Cat Holdings, Inc. (Nasdaq: RCAT) (“Red Cat” or the “Company”), a military technology company integrating robotic hardware and software to protect and support the warfighter, today announces that subsidiary Teal Drones will partner with Doodle Labs on Teal’s sUAS prototype for the U.S. Army’s Short Range Reconnaissance (SRR) program.   

Teal is one of only three vendors competing in SRR Tranche 2, which the Army has advised will now be the final tranche of the SRR program. The winning vendor(s) will produce a rucksack-portable sUAS to provide platoons with rapidly deployable reconnaissance capability.  

Doodle Labs produces industrial-grade wireless networking solutions. By integrating Doodle Labs’ Helix Mesh Rider Radio, Teal’s SRR prototype will be capable of reliably transmitting thermal imagery, AES-256 encrypted video and other high-bandwidth data back to a ground station 3+ miles away. Mesh Rider Radio uses FIPS 140-3 certified encryption, protecting this data and flight control functionality even in contested environments. 

“Teal is confident of building an sUAS prototype that will meet and exceed the Army’s requirements for the SRR program,” said Teal Founder and CEO George Matus. “Our strategy includes leveraging the best technology partners available, and Doodle Labs is an industry leader in wireless networking solutions.” 

Teal’s previously announced technology partners for its SRR effort include Teledyne FLIR and Immervision

Teal and Doodle Labs are both certified as “Blue UAS,” which designates manufacturers authorized to provide equipment to the U.S. military. Doodle Labs developed its Helix Mesh Rider Radio with sponsorship from the U.S. Department of Defense’s Defense Innovation Unit (DIU).  

“We’re excited for our technology to be integrated into Teal’s SRR prototype and, potentially, other Teal platforms,” said Doodle Labs Vice President of Business Development Ashish Parikh. “The SRR program is a great opportunity to showcase how Doodle Labs’ wireless networking solutions can deliver and protect warfighters’ data.” 

Helix Mesh Rider Radio uses Doodle Labs’ proprietary multi-band technology to cover – in a single radio for bands M1 to M6 (1.6 GHz to 2.5 GHz) – a range of licensed radio frequencies often used by the U.S. military. The radio’s mini-OEM form factor is extremely low-SWaP (size, weight, and power). 

Teal and Doodle Labs are exhibiting their technologies at two industry events this week, both running from May 8 to 11. Those events are XPONENTIAL in Denver, Colorado (Booth 4416), and SOF Week, in Tampa, Florida (Booth 1016). At XPONENTIAL, Teal’s George Matus will join a Doodle Labs panel discussion (on May 10 at 3 p.m. MDT), “How Collaboration Sparks Innovation in DIU’s Blue UAS Program.” 

About Red Cat Holdings, Inc.    

Red Cat (Nasdaq: RCAT) is a military technology company that integrates robotic hardware and software to provide critical situational awareness and actionable intelligence to on-the-ground warfighters and battlefield commanders. Its mission is to enhance the effectiveness and safety of military operations domestically and globally – and to “Dominate the Night™.” Red Cat’s suite of solutions includes Teal Drones, developer of the Teal 2, a small unmanned system with the highest resolution imaging for nighttime operations, and Skypersonic, a leading provider of unmanned aircraft for interior spaces and other dangerous environments. Learn more at    

About Doodle Labs LLC  

Doodle Labs designs and produces industrial-grade wireless networking solutions. The company focuses on mesh networking for robotic systems, providing high throughput, long-range Mesh Rider solutions for UAVs, UGVs, AMRs, connected teams, government/defense, private wireless and other applications. The company’s Helix Mesh Rider Radio was developed with sponsorship from DIU and is the Blue UAS program’s datalink of choice.  

Doodle Labs was founded in 1999 and has offices in the United States and Singapore. For more information, visit

Red Cat officially launches world leading sUAS for nighttime operations, the Teal 2

Red Cat Holdings, Inc. (Nasdaq: RCAT) (“Red Cat” or the “Company”), a military technology company integrating robotic hardware and software to protect and support the warfighter, today officially launches its new military-grade sUAS, the Teal 2.

Attendees at the 2023 AAAA Army Aviation Mission Solutions Summit in Nashville, Tennessee, will see the Teal 2 on public display for the first time. 

Previously available only to early-adopter customers, the Teal 2 is now available to order for military, government and commercial purposes. The U.S.-made system is manufactured at Red Cat’s purpose-built factory in Salt Lake City, Utah.

“Most military operations take place at night, and the Teal 2 is exactly the sUAS that warfighters have been asking for,” said Red Cat CEO Jeff Thompson. “Teal 2 is designed to ‘Dominate the Night™’ and arrives as the world’s leading small unmanned aircraft system for nighttime operations. The system also offers the latest intelligence, surveillance and reconnaissance (ISR) technology, delivering time-critical information and enabling operators to make faster, smarter decisions.”    

The Teal 2 is the first sUAS to be equipped with Teledyne FLIR‘s new Hadron 640R sensor. This provides end users with the highest resolution thermal imaging in a small (Group 1) form factor, optimized for nighttimeoperations. Red Cat’s other technology partners for the Teal 2 include Athena AIReveal Technology and Tomahawk Robotics.

The system’s compact size and rugged design enable it to be rucksack portable and deployed in the most challenging environments. Multi-vehicle command and control allows for a 360-degree view of a target, or for ISR on multiple targets.

Early-adopter customers have included U.S. Customs and Border Protection, which ordered 54 units of the Teal 2. These systems are being used to provide supplemental airborne reconnaissance, surveillance and tracking capability, enhancing situational awareness for U.S. field commanders and agents. 

Red Cat subsidiary Teal Drones is certified as “Blue UAS,” which designates manufacturers authorized to provide equipment to the U.S. military. Teal is also one of only three drone manufacturers invited to participate in the U.S. Army’s Short Range Reconnaissance Tranche 2 (SRR T2). The SRR T2 program seeks to deliver a portable sUAS that army platoons can use for surveillance and reconnaissance duties, as well as to improve situational awareness.  

“The advanced technology and innovative design of the Teal 2 will help redefine the future of defense,” said Thompson. “The AAAA summit this week is your first opportunity to see the system up close and in person.”

The 2023 AAAA Army Aviation Mission Solutions Summit runs from April 26-28 at Nashville’s Gaylord Opryland Resort & Convention Center. Red Cat is exhibiting at Booth No. 2138.

Red Cat Holdings Invests in Firestorm Modular Unmanned Aerial Systems Company

Red Cat Holdings, Inc. (Nasdaq: RCAT) (“Red Cat” or the “Company”), a military technology company integrating robotic hardware and software to protect and support the warfighter, has made a materially significant financial investment in Firestorm, an American company developing the first completely Modular Unmanned Aerial System (MUAS) that is 3D printed and payload agnostic. 

Firestorm is building a new category of fixed-wing UAS with 30-day product iterations, a commitment to open-system architectures, and an additive manufacturing approach that allows them to scale production in an elastic manner.  

“Firestorm is changing how UAV’s can be designed, manufactured, and delivered quickly, and the Firestorm system solves a lot of problems for many critical situations. Their  long-range and long-duration loitering capabilities are a cost-effective approach to winning in the air.   We believe that our Teal 2 drone and the Firestorm UAV could be a great combination for the warfighter,”  said Red Cat CEO Jeff Thompson. 

Firestorm’s founding team has deep industry expertise in additive manufacturing, aerospace, and defense and understands how to build and quickly scale dual-use technology companies.  

“We are honored to have Red Cat join us on our journey. Red Cat’s Blue UAS products, their American manufacturing facilities, and their industry knowledge have made them a great partner as we work to scale our business,” said Firestorm CEO Daniel Magy. 

“We want to help Firestorm succeed, and this investment may be just the beginning. For example, our large manufacturing facility in Salt Lake City could accelerate the production of Firestorm’s products to meet increased demand,” Thompson added. 

About Red Cat Holdings, Inc.  

Red Cat (Nasdaq: RCAT) is a military technology company that integrates robotic hardware and software to provide critical situational awareness and actionable intelligence to on-the-ground warfighters and battlefield commanders. Its mission is to enhance the effectiveness and safety of military operations domestically and globally – and to “Dominate the Night.” Red Cat’s suite of solutions includes Teal Drones, developer of the Golden Eagle, a small unmanned system with the highest resolution imaging for nighttime operations, and Skypersonic, a leading provider of unmanned aircraft for interior spaces and other dangerous environments. Learn more at  

About Firestorm 

Firestorm is building the future of modular, open-architecture unmanned aerial systems, supporting global requirements to create radically affordable hardware. Firestorm is dedicated to redefining commercial and military expectations for modularity with in-field reconfiguration that supports the widest array of mission needs. Learn more at https://www.launchfires


SmartSkies safely integrating unmanned aircraft systems into the National Airspace

ANRA Technologies was selected by Raytheon Intelligence & Space (RI&S) to provide its SmartSkies suite of technology solutions to support simulation and live drone flight operations at Mid-Atlantic Aviation Partnership UAS test site at Virginia Tech. The testing is part of a larger project to safely integrate Unmanned Aircraft Systems into the National Airspace System and advance Beyond Visual Line of Sight (BVLOS) operations.

Under the contract, RI&S will establish a ground-based surveillance supplemental data service provider (SDSP) test program consisting of local radar services using the company’s Skyler active electronically scanned array, AESA, UAS weather product services and UAS service suppliers.

ANRA Technologies will partner with RI&S and other program participants, including Virginia Tech, SkyGrid and, to test technologies that will support scalable, safe and compliant BVLOS drone operations at low altitudes.

ANRA will implement its SmartSkies airspace management and data services platform to gather detailed and comprehensive SDSP data to provide a holistic operating approach as the nation moves forward to create a safe and reliable environment for UAS and Urban Air Mobility.

For this project, ANRA SmartSkies FUSION will consume data feeds from the Skyler AESA and data transmitted from cooperative aircraft flying within the USS network to develop a well-defined and known airspace environment.

“ANRA is excited to work with our partners to implement our SmartSkies platform for this project,” said Amit Ganjoo, CEO of ANRA Technologies. “Our technology will enable testing and evaluation of systems that will pave the way for commercial BVLOS drone operations at scale,” said Ganjoo.

SmartSkies FUSION leverages artificial intelligence and machine learning to generate a path-prediction capability to forecast into the future where aircraft will be positioned. SmartSkies CTR, in turn, enables the ability to aggregate and integrate networked and non-networked surveillance data with UTM, creating a complete airspace picture that can be distributed to authorized users. SmartSkies AWARE will integrate the weather intelligence platform into the system for flight planning and route optimization and other supplementary datasets already available in the system.

A Risk-Based Approach: The UAS BLVOS Arc Final Report
A Risk-Based Approach: The UAS BLVOS Arc Final Report

The flight path toward normalizing and integrating UAS into the National Airspace System begins to clear.

The long-awaited Unmanned Aircraft Systems (UAS) Beyond Visual Line of Sight (BVLOS) Aviation Rulemaking Committee (ARC) final report dropped on March 20. The almost- 400-page document comes nine months after the FAA chartered the ARC, and three months beyond its originally projected deadline. Here we break down the report into key elements, with analysis and predictions for the way ahead.


The FAA chartered the ARC last June, “to make recommendations to the FAA for performance-based regulatory requirements to normalize safe, scalable, economically viable and environmentally advantageous UAS BVLOS operations that are not under positive air traffic control.” Emphasized items specifically included UAS BVLOS support to long-line linear infrastructure inspections, industrial aerial data gathering, small package delivery and precision agriculture operations, including crop spraying.

A diverse team of experts gathered to tackle this effort. Representatives came from academia and standards bodies; critical infrastructure owners and operators; infrastructure security; privacy groups; state, local, tribal, territorial interests—including environment and equity considerations; technology and network infrastructure interests; traditional aviation associations; and UAS associations.

These teams spent thousands of hours in meetings, divided into various groups and subgroups and working in two phases. Phase 1 focused on understanding the landscape and developing a pathway forward. It explored topics such as “Safety,” “Environment and Community,” “Market Drivers” and “Regulatory Challenges.”

Phase 2 focused on establishing a risk framework, building on Phase 1 inputs. During this Phase, the ARC made recommendations for UA with a resultant kinetic energy of up to no more than 800,000 foot-pounds (representative of a Light Sport Aircraft, or LSA) to conduct “fly to rule” BVLOS operations…without waivers.


The ARC focused on safety and societal benefits as its guiding principles. While safety may be an obvious focal point for a potential aviation rule, societal benefit got a lot of play. Why? To justify a risk-based approach that deviates from the typical “regulate to prevent the worst case scenario” mindset of crewed aviation.

As Jon Damush, CEO of Iris Automation and ARC member, explained: “This is probably the first time in aviation where risk has become two-dimensional in terms of probability and consequence. With crewed aviation, the consequence of an accident is dire because souls are on board. With UAS, this is not the case. Until now, we’ve never been able to consider the question: ‘What is an acceptable level of risk?’”

The ARC answered this question by recommending a consistent acceptable level of risk (ALR) across all types of UAS operations, encapsulated in a regulatory framework supported by an Operation Risk Matrix and an Automation Matrix. These both use qualitative and quantitative approaches to assess air and ground risks to enhance compliance and reduce risks to an acceptable level.

The Operation Risk Matrix defines risk levels based on a number of factors, including strategic and technical mitigation and the UAS’ kinetic energy, as applied to an operation. The Risk Levels are 1, 2A/2B and 3 (the highest level). Strategic mitigations reduce risk prior to flight. Technical mitigations reduce risk in flight.

The Automation Risk Matrix describes the acceptable ranges of autonomous UAS operations and prescribes the operator qualifications necessary to conduct them:

AFR Level 1A manual system (“human in the loop”), where direct monitoring and human interface are necessary and intended for the vast majority of flight.

AFR Level 2A system with increased automation (“human on the loop”), in which human remote pilots are responsible for the flight of assigned aircraft, and are expected to directly monitor and maintain situational awareness for the flight(s) under their control.

AFR Level 3Extensive automation, similar to existing on-demand delivery operations (“human over the loop”); may not require human intervention to operate successfully, but may accommodate human supervision and intervention; used to support substantially one-to-many operations.

AFR Level 4A state of ultimate automation (“human out of the loop”), handled completely by the automation, with no human intervention.

An Automation/Automated Flight Rules Risk Matrix (page 43-44 of the report) describes the various requirements for human roles and qualifications, and any limits to operations. Equipage requirements are listed as TBD.

This approach provides operator flexibility to meet those ALRs through qualitative or quantitative methods, or a hybrid approach. It footstomps rules based on the risks of operations, based on UA capability, size, weight, performance and characteristics of the operating environment, not the purpose of the operation.

“It is good to see the move toward a risk-based approach and the aspiration to scale to routine BVLOS flights, rather than Proof of Concept,” said Julie Garland, CEO of Ireland-based Avtrain. “We have proven the concept over and over again. Now it is time for scale.” Garland was pivotal to the creation of the Future Mobility Campus Ireland (FMCI), Skyports and Shannon Group consortium, called FMCI Air. FMCI established Ireland’s first drone air taxi service and routine BVLOS drone operations.


The need for BVLOS operational flexibility led to recommended modifications to the right of way rules and conspicuity requirements for UAS. According to the report, conspicuity—technology that can help pilots, UA users and air traffic services be more aware of what is operating in surrounding airspace—could include strobe or other lighting features. These requirements could be established by Means of Compliance (MOC), through a standards development organization (SDO).

The biggest change would be in the Right of Way rules. The ARC suggested modifying the See and Avoid & Well Clear requirements in Part 91.113 (b) to allow a range of sensing methodologies and to clarify adequate separation.

FAR § 91.113(b) would be amended as follows:

General. When weather conditions permit, regardless of whether an operation is conducted under instrument flight rules, visual flight rules, or automated flight rules, vigilance shall be maintained by each person operating an aircraft so as to detect and avoid other aircraft. When a rule of this section gives another aircraft the right-of-way, the pilot shall give way to that aircraft and may not pass over, under, or ahead of it unless able to maintain adequate separation.

In the suggested language above, the word “detect” has been substituted for the word “see’ “to allow the use of other sensing methods beyond human visual capabilities. “Well clear” has been removed and replaced with “adequate separation” to allow for different levels of separation for different situations, consistent with performance-based approaches. This also constitutes a paradigm shift from determining collision risk based on a volume of airspace to an approach based on acceptable level of collision risk appropriate for the airspace.

Perhaps even more controversially, the ARC recommended that in Low Altitude Shielded Areas (within 100 feet of a structure or critical infrastructure as defined in 42 U.S.C. § 5195c) and Low Altitude Non-Shielded Areas (below 400 feet, over crewed aircraft are not equipped with an ADS-B Out), the UA would have the right of way over crewed aircraft.

This topic consumed many hours of discussion, Darmush said. In his opinion, “Evert user of the airspace shares a collision avoidance responsibility. The means of achieving that are less clear at this point, but promising technologies continue emerging. The report recommends a change to right of way rules in lieu of pursuing technical solutions. This would be a good thing for UAS, but I have concerns about the impact to existing airspace users and crewed aircraft, specifically revolving around a human pilot’s ability to see and avoid a drone.” The U.S. still experiences on average four mid-air collisions a year, under the current rules, in cooperative airspace between cooperative aircraft using ADS-B, transponders, ATC contact and certified pilots with eyes-on.

On the other hand, Richard Podolski, director of UAV flight operations for Canadian-based Volatus Aerospace, believes this type of equitable access to airspace constitutes positive progress for the industry. “The BVLOS ARC is recommending amending 91.113 to allow UA right of way within 100 feet of a structure. Canadian regulations have been utilizing this approach and already have regulations from 2019 allowing (901.25) operation 100 feet above/200 feet beside a building or structure. Examples like this have opened up a significant amount of growth in Canadian industry and poses little or no risk to uncrewed aircraft…Flying 50 feet AGL [above ground level],” he continued, “clearly, the ground is far more dangerous to a crewed aircraft than a drone is at this height. The regulations need to reflect this.”

The thinking here is that UA-General Aviation (GA) encounters remain unlikely in shielded airspace because crewed aircraft typically do not work near obstacles. For the non-shielded change, existing regulations prohibit a significant portion of helicopters and non-agricultural GA aircraft from operating at low altitudes except for takeoff or landing.

Even so, the UA would still need to yield way in Non-Shielded Low Altitude Areas (i.e., below 400 feet AGL) to crewed aircraft equipped with ADS-B or Traffic Awareness Beacon Systems (TABS) broadcasting their position.

The ARC also recommended amending visual line of sight aircraft operations to include Extended Visual Line of Sight (EVLOS). This would allow operations where a remote pilot in charge (RPIC) does not see the UAS, but a trained crewmember has situational awareness of the airspace around the UAS. In Australia, Hover UAV already has this in place (see previous coverage at

The ARC made several other related regulatory amendment suggestions to support the proposed Operating and Right of Way Rules ranging from training crewed pilots on uncrewed flight operations to increase situational awareness, to preflight actions and amending minimum safe altitudes.


The key takeaway here is the ARC recommendation for a new BVLOS rule that would include a process for qualification of uncrewed aircraft and systems up to 800,000 foot-pounds of kinetic energy in accordance with the Operating Environment Relative Risk Matrix (see chart opposite page). The report suggests a complete overhaul of the qualification process based on risk and not a one-size-fits-all approach. “Qualification of UA should follow a risk continuum, aligned with the Risk Framework,” according to the report, “with the goal of meeting the acceptable level of risk [ALR]. Outside of traditional certification, the FAA should accept a statement or declaration of compliance to an FAA-accepted means of compliance.”

For small UAS, the report suggests, no airworthiness certificate should be necessary. A production certificate would not be required either, similar to the process used for LSA. Under this construct, the FAA could choose to review and accept certain applicant’s quality systems. However, applicants would not be required to gain acceptance or approval of the UA system or changes to the UA system.

Relatedly, the ARC recommends a slew of other UA updates around UA maintenance; software qualifications, noise certification, who must declare compliance and Repairperson Certification. It also calls for a new Special Airworthiness Certification for the UAS category, under Part 21 in higher relative-risk operating environments with UA from 25,000-800,000 foot-pounds. It also allows third-party test organizations to audit compliance similar to Europe.


The ARC recommended a rule under the 14 CFR to govern UAS BVLOS Pilot and Operator certification requirements and operating rules. The overarching concept is that the FAA should align BVLOS qualification and certification requirements to the categories described in the Automation Matrix AFR Levels noted earlier in this piece. For AFR Level 1, a modified Part 107 could allow for limited BVLOS operations to be conducted under a Remote Pilot certificate with Small UAS rating (e.g. during EVLOS or “shielded” operations). For AFR Levels 2 through 4, BVLOS operations could be conducted under a Remote Pilot certificate with BVLOS rating per two new Operating Certificates for common carriage of property and other commercial operations.

The ARC also wants the FAA to create a new Designated Position of Remote Flight Operations Supervisor under the Remote Air Carrier certificate and the Remote Operating certificate for 1-to-many UAS BVLOS flights. This person would exercise operational control and ultimate responsibility for 1-to-many BVLOS flights conducted under their supervision, based on the AFR level.

Other topics covered included:

Developing tailored medical qualifications for UAS pilots and other crew positions that consider greater accessibility and redundancy options available to UAS. tailored medical qualifications for UAS pilots and other crew members that reflect the reduced physical requirements for flying UA.

Expressly authorizing RPICs of a UA to operate for compensation or hire.

Allowing only appropriately vetted UAS operators approved by the relevant authority to conduct operations deemed to be a higher security risk per Section 2209 of the FAA Extension, Safety, and Security Act of 2016.

Providing an exception to the restrictions and requirements for carriage of specified quantities of hazardous materials for delivery by holders of a Remote Air Carrier or Remote Operating Certificate, to allow carriage of limited quantities.

Additional requirements for agricultural ops would be brought forward from Part 137.

The ARC also recommended that the FAA adopt a non-mandatory regulatory scheme for third party service providers (3PSP) to be used in support of UAS BVLOS operations. The ARC says the FAA and NASA should conduct a study to determine what level of aircraft operations in a defined volume of the airspace might trigger the need for mandatory participation in federated or third party services.


The massive, single-spaced report covers everything from environmental recommendations to spectrum, cybersecurity, counter-UAS and network Remote ID.

While the global industry and the FAA mull over the report’s consequences, the ARC hopes for an interim pathway. Such a runway could allow small-scale operations without significant environmental impact while the FAA continues its waiver and exemption process pending finalization of any future BVLOS Rule.

The walk continues in the “crawl, walk, run” that sums up the UAS regulatory process. But the ARC report situates BVLOS at a pivotal moment. “This ARC report represents a watershed moment for the future of American aviation—whether we embrace the future of aviation and allow society to reap the benefit of drone services, or whether we get left behind relative to our global peers,” said Lisa Ellman, partner at Hogan Lovells and executive director of the Commercial Drone Alliance. “The many social benefits of UAS cannot be fully realized without a regulatory structure that enables safe, expanded, efficient and scalable BVLOS operations.”