Despite different regulatory frameworks, aviation officials at Commercial UAV Expo pointed to common challenges in risk, data and managing increasingly busy low-altitude airspace.
The United States and Europe have taken different paths toward enabling advanced drone operations. As both markets move toward more routine beyond visual line of sight (BVLOS) flight, however, regulators are confronting many of the same challenges.
Europe developed the U-space concept to support more complex drone operations in low-altitude airspace. The regulatory framework, adopted in 2021 and applicable since 2023, establishes services including network identification, geo-awareness, flight authorization and traffic information within designated U-space airspace. In practice, however, operational U-space areas have been slower to emerge than the regulatory framework itself.
The United States took a different approach. Beginning with the FAA’s Integration Pilot Program (IPP) in 2017, regulators worked with state, local and tribal governments and industry partners to test advanced operations in selected locations. Those projects included BVLOS flight, package delivery, operations over people and detect-and-avoid technologies. The FAA subsequently continued that work through the BEYOND program and other initiatives.
More recently, the Dallas-Fort Worth area has become a key proving ground for UAS Traffic Management (UTM), as the FAA and industry work toward routine BVLOS operations using interoperable services for strategic coordination. UTM is designed to support functions such as flight planning, authorization, surveillance and conflict management as drone traffic increases.
Now, the U.S. is moving toward Part 108, designed to provide a regulatory framework for routine BVLOS operations rather than relying as heavily on individual waivers and exemptions.
Europe approaches many higher-risk operations through its “specific” category and the Specific Operations Risk Assessment, or SORA. Rather than prescribing one set of requirements for every operation, SORA evaluates the risks of a proposed flight, including risks to people on the ground and encounters with crewed aircraft. The resulting risk level determines the mitigations and safety objectives an operator must meet. EASA adopted the latest SORA 2.5 methodology in 2025, with the goal of making the process more proportionate to the risk of the operation.
Against that background, a discussion between U.S. and European regulators at Commercial UAV Expo in Las Vegas offered an opportunity to compare where the two systems are heading.
“Two Skies, One Conversation: Comparing FAA and EASA Approaches to BVLOS Drone Operations” brought together Robert Reckert, Acting Division Manager of the FAA’s Emerging Technologies Division in Flight Standards, and Dan Dousi, Head of Department, Innovative Air Mobility at the European Union Aviation Safety Agency (EASA). Avtrain CEO Julie Garland moderated the discussion.
Despite the different regulatory structures, one of the clearest messages from the panel was how much common ground exists in the underlying approach to safety.
“I don’t think that our methodology and outcomes are that different – the framework is different,” Reckert said. “The idea of assessing risk is the same, we talk about it differently.”
Different Frameworks, Similar Goals
Europe has built much of its regulatory approach around risk assessment. Dousi noted that Europe’s structure adds another layer of complexity, with 31 member states and at least 31 aviation authorities.
“SORA was a good compromise,” he said.
EASA is also working toward greater proportionality and flexibility. Ground risk, for example, can change with population density at different times of day or days of the week.
In the U.S., the FAA uses its Safety Management System methodology to evaluate risk. The agency has also used existing operations to collect data that can help inform future rules.
“Although EASA and FAA take a different approach, the safety outcome that we’re looking for is the same,” Reckert said.
That data goes beyond aircraft telemetry. Regulators must consider the interaction between people and technology, along with factors such as training.
“We’re trying to enable operations, learn, and use that data to apply to rulemaking,” Reckert said.
Part 108 Will Not Finish the Work
For the U.S. drone industry, much of the current attention is focused on Part 108 and the prospect of moving away from case-by-case approvals toward a regulatory framework for routine BVLOS operations.
Reckert cautioned that publishing a rule will not resolve every challenge.
“One of the big challenges going forward is how do we communicate policies,” he said. “Just because the rule [Part 108]is done doesn’t mean that the work is done.”
The point emerged again when Reckert described one of the FAA’s major lessons from existing operations.
“The big lesson learned is the need to gather the data,” he said.
That includes safety and flight data, but also information about what happens when something goes wrong. Maintenance capabilities, weather, environmental conditions and the people supporting an operation all contribute to safety.
Part 108 could therefore represent an important transition rather than an endpoint. A rule can establish the framework for more routine operations. Real-world experience will help determine how those operations work at scale.
Regulators “Can’t Write Enough Rules” to Manage Low-Altitude Traffic
Scaling BVLOS raises another question: what happens as more aircraft begin sharing low-altitude airspace?
Asked how increasingly crowded airspace should be managed, Reckert offered a one-word answer: “Collaboration.”
“We as a regulator can’t do it alone,” he said. “We can’t write enough rules to make the congestion manageable.”
The FAA has responsibilities that include aircraft separation, certification and outreach. However, Reckert said everyone using low-altitude airspace will need to participate in making the system work.
Garland pointed to interoperability as another critical part of the equation.
Dousi said the issue is also becoming more important in Europe. General aviation operators had previously been told they would not need to become visible to drones, he said. As low-altitude operations increase, however, visibility is becoming more important. EASA is working toward a solution that is equitable for different airspace users.
The discussion points to how the challenge may change as BVLOS operations scale. Establishing a regulatory path for routine BVLOS is one step. Managing growing numbers of drones alongside other aircraft will require regulators and industry to address interoperability, operational practices and shared use of low-altitude airspace.
On that challenge, despite their different regulatory structures, the FAA and EASA appear to be moving toward much the same destination.
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Miriam McNabb is the Editor-in-Chief of DRONELIFE and CEO of JobForDrones, a professional drone services marketplace, and a fascinated observer of the emerging drone industry and the regulatory environment for drones. Miriam has penned over 3,000 articles focused on the commercial drone space and is an international speaker and recognized figure in the industry. Miriam has a degree from the University of Chicago and over 20 years of experience in high tech sales and marketing for new technologies.
For drone industry consulting or writing, Email Miriam.
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