NAAA Comments on UAS BVLOS Petition from Zipline
This week NAAA submitted comments to the FAA regarding a petition by Zipline to amend some of the conditions and limitations (C&Ls) specified in its current exemption to conduct beyond visual line of sight (BVLOS) package delivery operations with its uncrewed aircraft system (UAS). There were three key points on which NAAA expressed opposition:
- Allowing the PIC to hold a US Driver’s License in lieu of a third-class medical certificate
- Relaxing, rephrasing and removal of some monthly collision avoidance reporting
- Approval to conduct operations with a known inoperative anti-collision lighting system
The petition also seeks to “provide the FAA with flexibility” to amend their authorized operations in the future without rulemaking by inserting “unless otherwise authorized” in certain key C&Ls. NAAA’s commented against this practice, as it serves to obfuscate and, in some cases, purposefully sidestep the C&Ls as stated.
You can view NAAA’s comments here.

