View of a UAS in flight from above

Feb. 13, 2026

NBAA is asking the FAA to stand up a group of experts to explore electronic conspicuity (EC), following the agency’s reopening of the comment docket on the proposed rule, “Normalizing Unmanned Aircraft Systems Beyond Visual Line of Sight Operations (BVLOS),” with a series of questions for industry.

The proposed rule, published in September 2025, would allow certain low altitude BVLOS missions by unmanned aircraft systems (UAS) without waivers or exemptions; would create operating rules for UAS package delivery, agriculture, surveying, public safety and flight testing for compensation or hire; and described airworthiness for aircraft to be flown under proposed Part 108.

In its comments to the initial Notice of Proposed Rulemaking (NPRM), NBAA strongly urged the FAA to require EC, or sharing of position, of all aircraft in the National Airspace System (NAS). This concept may have some traction in the agency, as it reopened the proposed rule’s comment period to inquire of industry the availability of EC devices, performance capabilities of such devices and what industry consensus standards might apply to the devices.

“The overarching goal is to have every aircraft in the NAS sharing its position,” said Heidi Williams, NBAA vice president of air traffic services and infrastructure. “The situational awareness provided by universal position sharing is the game changer for improving safety.”

NBAA, in its most recent feedback to the FAA, described the uAvionix SkyEcho, which may meet the safety intent of EC for aircraft-to-aircraft deconfliction, and indicated some other technologies are deployed in Europe, but said without a clear definition of ‘EC’, there’s no way to determine if a device might be applicable.

The association encouraged the agency to stand up an Aviation Rulemaking Committee (ARC) to explore EC more comprehensively. The ARC’s tasks would include defining EC; identifying existing and emerging technologies capable of broadcasting or sharing aircraft position information; and developing a dedicated, performance-based standard for portable devices that are economically viable and commercial feasible.

“The FAA asked pointed questions about the availability of EC devices without defining ‘EC’ or establishing performance standards,” Williams explained. “There could be a range of solutions that meet the safety intent of not only this proposed rule but other airspace where air to air deconfliction would enhance overall safety.

“The next logical step is to get experts around the table to collaborate on a clear definition of EC and its performance standards, explore existing technologies that might comply with those standards and identify a forward-thinking pathway for EC for all aircraft in the NAS,” Williams added. “This is how we will have the greatest impact on aviation safety in the U.S.”

View NBAA’s latest comments to the FAA on Docket FAA-2025-1908