AAAE Shares Airport Perspectives on AAM Implementation with DOT's Interagency Working Group

AAAE submitted comments in response to the U.S. Department of Transportation's (DOT) request for information (RFI) on the development of a national strategy for advanced air mobility (AAM). A newly formed AAM Interagency Working Group (AAM IWG) within DOT has been tasked with development of the strategy by 2024 pursuant to the Advanced Air Mobility Coordination and Leadership Act that President Biden signed into law last year.

In our comments, which were based on extensive outreach efforts with our members, AAAE emphasized our support for the safe integration of AAM operations into the National Airspace System (NAS) and the preliminary planning that many of our members have undertaken to support these operations. However, we stressed the major obstacles preventing airports from making investments and taking more meaningful steps. These include a limited supply of electrical power to meet future demand from AAM operations; questions surrounding the viability and reliability of future AAM commercial operations; and a lack of guidance from the Federal Aviation Administration (FAA) on how to integrate these operations into their facilities. If AAM-specific infrastructure development is to be prioritized, we highlighted the need for clear guidance and reliable operators to ensure that any investment made in these operations will be returned to the airport and benefit its community and users.

You can read AAAE's comments here. In July, AAAE met with key members of the AAM IWG where we had the opportunity for more in-depth discussions and could share airport specific AAM challenges and opportunities. We appreciate everyone who responded to our survey and provided feedback. It has been extremely helpful as we continue to engage with the administration and lawmakers on Capitol Hill on AAM implementation.

Background. Over the past few years, lawmakers from both sides of the aisle and from both chambers have taken an interest in helping advance the maturation of AAM. In October 2022, Congress passed, and President Biden signed, the Advanced Air Mobility Coordination and Leadership Act. The law directed DOT to establish the AAM IWG, consisting of representatives from across the federal government. The goal of the working group is to develop an 'AAM National Strategy' that includes (a) recommendations for federal investment and actions to support the evolution and growth of AAM and (b) a comprehensive plan detailing the roles and responsibilities of each federal agency to facilitate or implement the recommendations.

DOT's AAM Interagency Working Group. In March, DOT established the AAM IWG, which consists of representatives from 22 different federal agencies. The group has created five distinct subgroups that will focus on (1) automation strategy, (2) security requirements, (3) air traffic management, (4) infrastructure development, and (5) community roles. Under the law, the AAM IWG must complete its recommendations and AAM national strategy by February 2024. In May, DOT released an RFI that sought general feedback on what should be addressed in the AAM national strategy, focusing on twenty areas of interest from safety implications to vertiport development.

Summary of AAAE's Comments and Key Points of Emphasis. AAAE staff conducted extensive outreach efforts with its members to collect feedback through a survey and webinar discussion in July. We also met with airports to understand their perspectives. Based on these discussions, there are several key points of emphasis that we have brought to the attention of DOT and the AAM IWG through an in-person meeting and our comments:

• Most Likely Use Cases Supported by Airports: We surveyed our airport members to determine what types of AAM use cases and applications airports expect to support or accommodate. Responses largely depended on the size of the airport and the local community or region they serve. However, the use cases cited fell into three general categories: (1) short-distance cargo deliveries where efficiencies could be gained using electric vertical takeoff and landing (eVTOL) aircraft; (2) regional and local passenger-carrying services (e.g., intracity travel); and (3) other operations that currently utilize traditional helicopters (e.g., medical emergency flights). 

• Siting Considerations and Planning: For vertiports that are located on airport property, most AAAE members expect that AAM operations would occur either at dedicated facilities for fixed-based operators (FBO) or Part 135 operations, or a location on the unsecured landside portion of the airport. It is unlikely that these operations would occur on or near a commercial airport terminal in the short to medium term. There was also consensus that enabling a seamless passenger experience for AAM-e.g., allowing eVTOLs to land on an airport terminal and transfer passengers into the terminal-is not feasible without substantial capital improvement upgrades, which are unlikely to occur until AAM operations are well developed. 

• Challenges with Meeting AAM Power Demands: The lack of electrical capacity was the most consistent challenge cited by airports on what types of barriers exist for AAM implementation. The recent increased demand from airport users for electrical capacity has well exceeded existing supply. The nationwide consumer movement toward electric vehicles (EVs) is leading rental car companies and other users to request charging stations and other electrical infrastructure. Absent substantial investments to upgrade power grids, AAM operators will be competing with other users for a limited supply of power. 

• Uncertainty over AAM Commercial Operators: The eVTOLs being evaluated under FAA's aircraft certification process are not expected to be operated in instrument meteorological conditions, which could limit their commercial value. There is an uncertain timeframe for FAA to certify and allow AAM operations on a wide scale, especially from an air traffic and airspace integration perspective. Many members indicated that these factors, along with an unproven business model, create some uncertainty as to how much demand there will be for AAM operations. This obviously influences the willingness of airports to invest in AAM infrastructure. 

• New Safety Risks with Electric Propulsion: We noted that electric propulsion, a core piece of AAM operations, presents new and unique hazards for emergency response and aircraft rescue and firefighting (ARFF) personnel at airports. Firefighters and emergency managers are already trying to better understand how to respond to lithium-ion battery fires, both onboard and off-board aircraft. In FAA's vertiport design brief, the agency noted that the firefighting techniques for eVTOL aircraft are still unknown. We strongly urged the AAM IWG to ensure that FAA is addressing the lack of guidance on how to ensure that airport personnel are trained properly to manage risks associated with electrical propulsion. 

• Need for FAA Planning Guidance: We emphasized that FAA should be responsible for establishing performance-based vertiport design standards, guidance for airports and local governments to determine appropriate locations for vertiport siting, and airspace and air traffic planning around vertiports. These responsibilities would help ensure consistency and the safety of AAM operations throughout the NAS. In addition, we expressed our support for FAA to create a new systemic planning program that focuses on ensuring off-airport vertiport siting and development does not disrupt existing aircraft operations. 

• Statutory and Regulatory Changes: We highlighted two specific issues that the AAM IWG should consider including in their recommendations to Congress. First, we need to ensure that AAM operators, along with other new entrants, are paying their fair share of the costs of ATC services and the infrastructure needed to accommodate their operations. Second, many of our members expressed support for a federal grant program to support the development of vertiport infrastructure. However, any such program, if recommended, must be funded by a source independent of the Airport Improvement Program (AIP), which is already significantly oversubscribed. 

What's Next? DOT and the AAM IWG will review the comments submitted and continue to engage with stakeholders in the industry to develop its AAM national strategy. The AAM IWG is required to develop its recommendations and strategy by February 2024. In the meantime, AAAE is committed to making sure the airport community's voice is heard in the ongoing discussions on this topic and the federal government provides the resources necessary for airports to effectively plan for and support AAM operations.