Advanced Air Mobility takes shape through US regulatory initiatives - Part 2

President Donald J. Trump's executive order, "Unleashing American Drone Dominance," issued June 6, 2025, mandated issuance of an eVTOL Integration Pilot Program (eIPP) Request for Proposals (RFP) by Sept. 4, 2025. It was actually issued Sept. 12 as a Screening Information Request (SIR). The SIR invited proposals from state, local, tribal and territorial (SLTT) governments, which were required to "include a private sector partner with demonstrated experience in eVTOL aircraft development, manufacturing, and operations." 

According to the SIR, proposals were due on Dec. 11. Per the executive order, at least five pilot projects are to be selected within 180 days of the SIR, or by March 11, 2026. Selection criteria shall include "eVTOL aircraft and technologies developed or offered by a United States-based entity; overall representation of economic and geographic operations and proposed models of public-private partnership; and overall representation of the operations to be conducted, including advanced air mobility, medical response, cargo transport, and rural access."

The DOT and FAA will execute Other Transaction Agreements (OTAs) with selected applicants outlining project goals, regulatory needs, timelines, information-sharing and data-exchange mechanisms, and responsibilities. The pilot projects should "plan to begin eVTOL operations within 90 days after the date on which any agreement for a pilot project is established."  So, assuming any such agreement is promptly established, eVTOL pilot programs could begin as early as this summer.

Will this ambitious timeline be met? Aviation program timelines, including FAA initiatives, often slide. The Trump administration's programs sometimes turn out other than initially promised. Moreover, cuts to FAA funding and personnel and competing FAA priorities do not bode well for the proposed eIPP ramp-up.

The current timeline seems optimistic. For example, note that no eVTOL or powered-lift had achieved FAA-type certification as of the SIR issue date on Sept. 12. Although the SIR program overview contemplates pre-certification operations, the SIR also requires that aircraft be in the Type Certification Process, which is ongoing.

That being said, pretty much anyone who has worked in government contracting or private procurement can tell you that RFPs are sometimes written to favor known suppliers or bidders. This is not to say that "the fix is in," but some of the U.S. OEMs, routes and markets discussed in Part 1 seem to be very well positioned for an eIPP OTA award.

All things considered, the federal regulatory framework is well in progress. The FAA has been working on type certification of several OEM airframes. Lessons learned from AAM certification type-by-type resulted in the issuance of Advisory Circular (AC) 21.17-4, Type Certification of Powered-lift, July 18, 2025. It provides a fairly coherent and concise roadmap to powered-lift (AAM) certification, and it may accelerate the process.

The FAA previously issued Special Federal Aviation Regulation (SFAR) No. 120 (Oct. 24, 2024), establishing a new Part 194 authorizing eVTOL "Powered-Lift Pilot Certification and Operations."  Before that, the FAA had previously issued an overarching UAM (Urban Air Mobility) Concept of Operations (v. 2.0, April 26, 2023). FAA has also issued guidance on "vertiport" design standards (last version: Dec. 27, 2024) to further enable AAM operations, particularly within cities. Local authorities (i.e., Los Angeles, the Florida Dept. of Transportation) have also issued guidance in the form of policy briefs and AAM concepts of operation.

In summary, essential regulatory pieces are falling into place. We have an increasingly good view of how AAM airframes will be certified and operated. At least some of the legal infrastructure necessary to support AAM operations is ready for a beta test. However, there also seem to be some missing pieces, particularly at the state and local level.

The current U.S. regulatory structure can be briefly summarized as follows:

SFAR 120/Part 194, Powered-Lift Pilot Certification and Operations: This piece runs roughly 227 pages in the Federal Register, including commentary. A full summary is beyond the scope of this review. We will excerpt and discuss a few highlights, as follows:

SFAR 120/Part 194 adopts new rules to facilitate "powered-lift" AAM operations. Powered-lift refers to aircraft using engine thrust for lift during VTOL or low-speed flight, and nonrotating airfoil(s) during horizontal flight. Note that some AAM designs may not fit this definition and may instead be considered rotorcraft, short takeoff and landing (STOL), or CTOL platforms.

SFAR 120/Part 194 makes applicability revisions to federal aviation regulations Parts 43, 60, 61, 91, 97, 111, 135, 136, 141 and 142 in order to clearly communicate that current FAA regulations are intended to operate in tandem with Part 194 and vice versa. In short, Part 194 aims to bring powered-lift aircraft into the existing aviation regulation framework, not re-invent it.

For example, powered-lift flights may be conducted under Part 91 (private operations), Part 135 (air taxi services) or Part 91K (fractional ownership) programs. These structures will be discussed further in Part 3 of this series.

Part 194 also facilitates the training and certification of the "initial cadre" of powered-lift instructors and pilots. OEM pilots may form this initial cadre of flight instructors who will then train further instructors at Part 141 pilot schools, Part 142 training centers and Part 135 operators.

Alternative requirements for powered-lift pilot certification would be available to pilots who already hold a commercial pilot certificate and an instrument rating for another category of aircraft. Essentially, current fixed wing and rotorcraft commercial (and eligible ex-military) pilots should be able to transition to AAM types.

Part 194 also offers significant flexibility in the use of simulators for training, as very few AAM airframes will be available for live training, at least in the near term.

Note the FAA did not propose any new requirements for the noise certification of powered-lift aircraft. Noise standards are expected to develop during certification of powered-lift airframes. Note also that this will be a sensitive subject in state and local airport and other land-use planning, which will be critical to establishing new sites for AAM operations. This will be discussed further below.

Note also that the FAA did not propose any new air traffic control (ATC) procedures, despite prompting from industry to consider emerging technologies. The FAA also deferred rulemaking on autonomous flight systems.

In summary, Part 194 aims to integrate powered-lift aircraft into existing aviation infrastructure. For example, SFAR 120 changes the definition of "heliport" to include powered-lift operations. By contrast, the emerging class of "vertiports" to be built for UAM operations is not explicitly included in Part 194/SFAR 120, although FAA has already issued guidance on vertiport design standards and will continue to refine those standards as powered-lift aircraft are certified.

The FAA's explicit goal is "to integrate powered-lift into the National Airspace System (NAS)," not re-invent it. Everything the FAA is doing is consistent with its prior regulations and AAM guidance--particularly, its prior UAM Concept of Operations v. 2.0 (April 26, 2023).

UAM [Urban Air Mobility] Concept of Operations v. 2.0: Sometimes the past is prologue, particularly in matters of government policy. This 2023 Concept of Operations relating to Urban Air Mobility Operations was intended to be "a target description of the evolution of integration from the near-term Innovate 28 environment to a future of high-density [AAM] urban operations."  Innovate 28 (or "I28") refers to "Advanced Air Mobility (AAM) Implementation Plan Near-term (Innovate 28); Focus with an Eye on the Future of AAM," Version 1.0 (July 2023), which defined the steps FAA and others would need to take for AAM operations to be at scale at one or more sites by 2028.

Note that the I28 timeline--i.e., operations at scale by 2028--is congruent with the timing of Trump's executive order, as well as the issuance of Part 194/SFAR 120. The eIPP/OTA framework can be seen as a series of trial runs towards more substantial operations by 2028. The FAA's been working on this plan for years.

I28 refers to itself as a "crawl-walk-run methodology that recognizes early opportunities to support Entry into Service (EIS) operations through existing services and infrastructure with minimal changes."  It says "Initial AAM operations in the 2025-2028 timeframe are expected to primarily use existing airports and heliports (with modification where required to meet FAA's interim guidance for vertiport design)."  As with Part 194, the objective is to integrate powered-lift aircraft into the existing NAS.

Concept of Operations v. 2.0 also forecasts further AAM development, such as establishing AAM Corridors or Cooperative Areas where "Cooperative Operations" (e.g., automated flight) can occur in accordance with "Cooperative Operating Practices" (basically, privatized and automated ATC) to be developed by industry and approved by FAA. Possible "UAM Corridor" operations are described. These would basically be "highways in the sky": flightpaths where less ATC oversight would be required for aircraft that are networked to maintain horizontal and vertical separation and avoid each other.

Concept of Operations v. 2.0 also refers to the use of "vertistops"--minimally developed vertiports for boarding and discharging passengers and cargo (i.e., no fueling, defueling, recharging, maintenance or parking areas would be required). The Concept of Operations also discusses increasing aircraft automation levels, as well as discussing the role(s) of a "Provider of Services" for [AAM], e.g., data/networking services providers supporting AAM operations in a "federated service network."  Basically, air traffic control would be outsourced to tech providers.

These are not near-term goals. Until a few certified AAM types engage in flight operations at scale, the FAA will likely not make any big bets on their guidance systems, no matter how much industry lobbies for it. In our view, fully automated flight operations involving paying passengers are not likely in the near term.

I28 includes an "Integrated Master Schedule Version 1.0" depicting the various regulatory and operational tasks that may be required to allow an operator to enter into service at any particular location. A table of "AAM Maturity Levels" or evolutionary steps towards high-density autonomous operations is also included, but no timeline is forecast.

Note that on Dec. 17, 2025, the Advanced Air Mobility Interagency Working Group issued "The Advanced Air Mobility National Strategy: A Bold Policy Vision for 2026-2036". While it's worth study, the National Strategy is largely aspirational, and has not yet resulted in any new or different laws or regulations. I28 still describes where we are, and where AAM is going in the near term.

Vertiport guidance: The biggest unknown regulatory factor facing progress in AAM may be the need for new infrastructure to support it. As discussed above, the Concept of Operations v. 2.0/I28/Part 194/SFAR 120 paradigm consists mostly of integrating AAM with existing NAS infrastructure. However, if AAM is to achieve operations at scale, a new network of vertiports may be required.

FAA Engineering Brief (EB) No. 105A, Vertiport Design (Dec. 27, 2024) forecasts the likely minimum scope of acceptable vertiport design from the FAA's perspective. Note EB 105 is a work in progress; FAA "is still collecting validated VTOL aircraft operational data and is transitioning from a prescriptive approach to a performance-based design approach with the recommendations in this EB."  The FAA has also announced that a new "Unified Vertical Lift Infrastructure Advisory Circular" including standards for both heliport and vertiport design will be issued by June 30, 2027.

Until then, EB 105 remarks on changes it makes to existing guidance on heliport design. Although "Heliports provide the most analogous present-day model for vertiports [. . .] there are design differences between traditional helicopters and VTOL aircraft that create specific, unique infrastructure requirements."

In other words, we can't assume that existing heliports will be able to host AAM operations. Although heliports have been written into Part 194/SFAR 120, some of those heliports may be unsuitable for vertiport operations, unless they are modified, or allowed a waiver for limited operations--e.g., as vertistops or vertipads.

That being said, development of vertiports will require prior notice to FAA. Here's some good news: There are already forms for that. For example, you would file Form 7460-1, Notice of Proposed Construction or Alteration, before building out or operating a vertiport on previous federally funded airports or heliports. You would file Form 7480-1, Notice for Construction, Alteration and Deactivation of Airports, for privately funded properties.

That's the easy part when it comes to vertiports. After that, things get a little muddy. The FAA admits that there is a substantial state and local role in licensing and permitting of landing facilities; see EB 105A, section 1.4. The FAA sagely advises "early and continued engagement across all project phases [to] identify and mitigate potential conflicts, ensuring smoother project approvals."  While that is no doubt sage advice, it also risks being a nice way to say, "Hey, good luck with that."

This is not to say that state and local governments are not supporting AAM initiatives. To the contrary, AAM preparatory work is underway in many states and cities.

For example, Florida recently passed Senate Bill 1662, which brings AAM and vertiports into the statewide aviation system plan, streamlines vertiport approvals at the state level, and facilitates the Florida DOT's work and investment in the construction of vertiport facilities. Florida's DOT has issued guidance on AAM development, including a primer on land use compatibility and site approvals.

California is working on AB 431, the Advanced Air Mobility Infrastructure Act, which would require California's DOT to develop or update the statewide aviation plan to include vertiports, electric aviation charging and other AAM infrastructure needs, as well as designate an AAM subject-matter expert within the Department.

Los Angeles, which will host the 2028 Olympics, has long had a fairly well-developed AAM policy. In 2022, the city collaborated with Urban Movement Labs, a public/private nonprofit policy think tank, on Integrating Advanced Air Mobility: A Primer For Cities, which was intended to define and disseminate best practices on urban AAM engagement.

So, the political will is there--state and municipal authorities all over the country seem to be sincerely anticipating the need to implement AAM. However, the actual scutwork has not commenced.

For example, a recent search in the Los Angeles Municipal Code revealed no new regulations on AAM or vertiport permits or procedures. That's an observation, not a criticism. Until particular AAM types are certified for operation, the new FAA vertiport design criteria are issued, or Los Angeles is awarded an OTA under the SIR issuing permits for new vertiports is a moot point. City Hall has enough on its plate already.

The Los Angeles DOT's 2021 Urban Air Mobility Policy Framework Considerations features a table of "UAM Land Use Policy Elements."  It's a nice piece of work; a degree of foresight may serve AAM better than the 20/20 vision that too often comes with hindsight. That being said, these "Policy Elements" comprise 10 broad categories (Zoning Considerations, Safety Regulations, Compatible Land Uses, etc.) and 36 related factors, all of which may bear on the evaluation of a particular AAM land use.

This makes for a very useful map of the territory, but it doesn't really tell us what riding through that landscape will be like. That remains to be experienced.

The single most important open question in the implementation of AAM operations thus may be: "Apart from existing airports and heliports, where are these new flying taxis going to take off and land?"  For the time being, the best answer may be: "Um, wherever you can pull permits."

In summary, the regulation of AAM is developing pretty well from the White House and FAA on down. Much of the federal regulatory scheme is in place. However, bottom-up and middle-market solutions are still relatively unformed. Preparatory work is proceeding on the state and local level, but it still feels a little abstract. Until AAM startup becomes a series of concrete tasks--filling out forms, applying for licenses, pulling permits--we won't really know what this next transportation revolution is going to look like.

Part 3 of this series will attempt to anticipate how AAM operations will be structured under existing federal aviation regulations, as formulated during the boom in American business aviation before the 2008 global financial crisis. Part 4 will assay the types of transactions that implementing AAM operations will likely require.

Thanks for bearing with us. We hope you're enjoying the trip.