Regulatory Alert: AAAE Responds to Draft FAA Guidance on Vertiport Design
AAAE submitted its response to the Federal Aviation Administration's (FAA) draft Engineering Brief (EB) No. 105, “Vertiport Design,“ which provides interim guidance to airport operators for the design of vertiports to support electric vertical takeoff and landing (VTOL) operations. In our comments, AAAE emphasized the need for additional research and guidance in key areas of vertiport infrastructure development, including facility design and structural capacity requirements; electrical power requirements; charging infrastructure design (e.g., charging plugs); and appropriate ARFF tools and techniques to support these operations. In addition, AAAE highlighted the need for FAA to require off-airport vertiport developers to closely coordinate with airports before development and provide airports with more guidance on criteria that airports can use when selecting a site for a vertiport. 
You can read AAAE's comments in response to the draft FAA EB here. 
Background. The EB specifies interim design guidance for vertiports and vertistops, including modification of existing helicopter and airplane landing facilities and the establishment of new sites. The AAM industry and airport community have both sought interim guidance to help provide greater clarity on the development of vertiport infrastructure for VTOL operations. FAA has repeatedly indicated the long-term goal is to develop a performance-based Advisory Circular (AC) on vertiport design that will detail categories of vertiport facilities requiring different design criteria depending on the characteristics of the aircraft they plan to support and activity levels at the facility. You can read additional information in our February 28 Regulatory Alert. 
Summary of AAAE's Response. AAAE was generally appreciative of FAA's efforts to develop design guidance for the airport community to help them support eVTOL aircraft operations at their facilities. However, there were several overarching recommendations that AAAE made to FAA to improve the guidance and make it easier to integrate AAM operations into the airport environment: 
• FAA needs to better highlight and emphasize that eVTOL aircraft can operate at existing airport facilities, including runways, taxiways, and heliports. AAAE wants airports to understand that while the design guidance is helpful for new vertiport facilities (or the modification of current facilities), existing infrastructure can support operations in the short term.
• FAA needs to conduct additional research and provide more guidance in key areas of vertiport design, including (a) facility design and structural capacity requirements; (b) electrical power requirements; (c) charging infrastructure design (e.g., charging plugs) to ensure consistency across the system; (d) appropriate firefighting extinguishing agents and techniques for lithium battery cells; and (e) the applicability of Part 139 ARFF requirements to these operations; among other things.
• FAA needs to take a stronger position on the need for proponents of off-airport vertiports to coordinate with any nearby airports and aviation stakeholders. Close coordination and collaboration is necessary to avoid potential airspace, air traffic, safety, financial, or operational impacts from occurring at existing airports due to the development of nearby vertiports.
• FAA needs to provide guidance on criteria that airports can use when selecting a site or location for the vertiport. While the design of a vertiport, including safety and touchdown areas, is important, siting considerations and criteria are equally important for airports that are beginning to plan for these operations.
• FAA needs to allow airports to develop vertiports that are smaller in size (compared to what is included in the guidance) in order to improve flexibility and expand the potential locations for these facilities. Several members commented that the proposed standards for the safety area and other approach and takeoff areas of the vertiport are too large and would restrict the ability for airports to deploy these facilities and support VTOL aircraft operations.
What's Next? FAA will compile all the comments submitted by the deadline today and begin adjudicating them over the next few months. During the March 29 Industry Day, FAA indicated that its goal is to release a final EB on vertiport design by the end of summer this year. FAA will then continue to update the EB as necessary until the agency finalizes its broader performance-based AC on vertiport design in the late 2024/early 2025 timeframe. 
Resources
• FAA Draft Engineering Brief 105, “Vertiport Design“ 
• FAA 3/29 Industry Day Presentation on Draft EB 105 
• FAA 3/29 Industry Day Recording (Accessible on YouTube) 
• AAAE 4/18 Response to FAA's Draft EB 105