UAS Beyond Visual Line-Of-Sight Operations


On the evening of June 13, 2023, the BFA made its final comments (see attached) in response to the recommendation made to FAA by the UAS community in their attempt to secure special airspace within which the UAS would have the right of way over all other air traffic. The BFA remains steadfast in its earlier comments to the ARC, that any modification of FAR 91.113, or right of way rules, would result in an unacceptable risk to balloons flying in the same airspace if the UA is given the right of way.


The BFA, along with other organizations such as AOPA, EAA, NATA, and HAI, have all commented with the same purpose: to stop the land grab tactics of some UAS operators to favor their commercial delivery enterprises. This process began with BFA’s discovery of the UAS industry’s first 400-page recommendation to the FAA, to give UAS the right of way, with little or no concern for the safety of other aircraft occupying the same airspace. We were successful in bringing the unacceptable safety issues to light and publicly commenting on our disagreement with their recommendations. With the ARC’s new comment period, we are now seeing the FAA working toward a requirement for UAS to be equipped with detect and avoid equipment. If it becomes a requirement, it will help to ensure that UAS and balloons may coexist in the National Airspace System with an eye toward the mutual safety of both.


This BVLOS comment package is somewhat more complicated than the first and as you read through, you will see that it covers many aspects of regulatory requirements raised by the FAA to the ARC. The comment period was a short 20 days and the BFA, along with numerous other organizations, issued a letter to FAA requesting an extension to the comment period. This was not granted but each of our organizations was afforded the opportunity to discuss this matter, by phone, directly with AFS-800 and the person in charge of the ARC. You may still submit your comments today, June 14, until 11:58 P.M. EDT. A simple comment is all that is necessary stating your position or concern regarding the requirement for all UAS to have detect-and-avoid equipment on board. Please upload your comments to and find the docket provided in the list on the right side of the page (Docket No. FAA-2023-1256). Find the BVLOS comment area and upload your comments. We will continue to fight the proposals from UAS operators to gain the right of way over balloons and we are stronger now, with excellent partners from the many other aviation organizations who support us.


BFA Final Comments -  Beyond Visual Line-Of-Sight Operations



Cannon Pat






Pat Cannon, BFA President

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Balloon Federation of America
PO Box 400
Indianola, Iowa