The countdown to Part 108 has been underway for a while. But soon enough the drone industry will discover that winning permission to fly beyond visual line of sight (BVLOS) is only half the battle. The harder question, raised repeatedly during an expert session at the recent Commercial UAV Expo, revolves around exactly how the airspace will absorb thousands of BVLOS flights a day without falling apart.
Nathan Ruff, who leads UTM and strategic partnerships at AirWise Solutions, moderated the session and opened with the fact that strategic deconfliction transactions in UTM systems surpassed 1.5 million so far this year, up from one million just months earlier. “It’s a hockey stick,” he said. “It’s accelerating really quickly. I think that’s good news for the industry. It means that UTM isn’t just a concept. It’s real, it’s here.” But are we ready?
Amazon Prime Air: Real-World Delivery At Scale
Carmen Simboli, an airspace integration specialist at Amazon Prime Air, offered a picture of what “real world” actually means for BVLOS operations today. Amazon runs 11 operational delivery sites across the U.S. and completes tens of thousands of deliveries every month, with hundreds of thousands logged so far this year. A recent company announcement calling for coverage of 500 cities and municipalities represents a sixfold increase over current site counts.
Simboli’s team operates under existing exemptions and Part 135 air carrier certification, so a finalized Part 108 rule will not impact Amazon’s operational footing significantly. His bigger concern is systemic. “It doesn’t change too much (for us),” Simboli said, “just the regulatory framework in which we operate.” He continued, “But I don’t think that a lot of the other operators are prepared for that transition. They’re not necessarily ready to onboard with a UTM service provider.”
And perhaps the system, itself, is also not quite ready to absorb those who are not yet flying BVLOS as routinely as Amazon. Simboli pointed to a specific technical gap, prioritization within UTM, as an example. In his world, prioritization currently runs on a binary standard-or-high system. It does not have pairwise deconfliction when multiple high-priority operators, such as a fire department drone and a police response, converge in the same airspace. Simboli and others continue to work on an appendix to the ASTM F3548 standard to build a more granular prioritization schema, but he acknowledged such work will take more time. “The corridor system that we use as a delivery operator is totally different from public safety,” he explained. “We need to adapt to regulations and the standards will need to adjust.”
Public Safety Operator: We Are Behind the Curve
Gabriel Graveline brought the panel’s public safety perspective as founder of RespondAir UAS and a Tulsa Fire Department veteran who has spent nearly a decade building the department’s drone and robotics programs. His work now extends into Drone as a First Responder (DFR) operations and coordination through the newly formed Oklahoma Public Safety Coordination Group. His assessment of readiness for a fast-approaching regulatory change was equally skeptical.
“I can tell you there’s maybe a handful of agencies across the country that truly understand (UTM) or that are tied to an aviation program,” Graveline said. Varying levels of training and infrastructure across fire and police departments will complicate onboarding to shared UTM systems. He described how his department manages overlapping manned and unmanned assets today mostly through radio coordination and altitude separation, keeping drones below 400 feet while manned aircraft hold above 600 feet. But he acknowledged that most incidents, even large-scale ones, lack a designated “air boss” empowered to manage that airspace in real time.
“The problem right now for most incidents, even large, let’s just say fires or searches, you don’t necessarily have an air boss that’s been designated,” Graveline said, contrasting it with his experience under Coast Guard command during Hurricane Harvey, where a clear air boss structure existed. “When it comes to the local level, I mean, I’m probably the closest thing there is to an air boss, and there are not a lot of people that listen to me.”
On the question of whether public safety agencies would slow down to file UTM flight plans mid-emergency, he said, “We’re going to have to send the traditional response until we can work out what this is going to look like in the air.” Graveline added that the gap between emergency response speed and UTM participation “needs to close.”
AirWise Solutions: The UTM Infrastructure Layer
Josh O’Leary, Chief Technology Officer and co-founder of AirWise Solutions, represented the infrastructure side of the equation. He explained the practical distinction between the two forthcoming rules for an audience still catching up. “108 is the operator, 146 is the UTM,” O’Leary said. “We provide the infrastructure, they provide the service.”
O’Leary has flown drones for 18 years across pipeline inspection, electric line work and public safety missions, which gives him a field-level view of the stakes when situational awareness fails. He recalled flying inspection patterns near a low-flying Cessna without being able to tell whether the manned aircraft was 50 feet above or below his own altitude, a margin-of-error problem that UTM and remote ID are meant to close.
That experience shaped how AirWise built its own platform, Nexus, which fuses radar, remote ID, ADS-B and raw partner telemetry into a single operating picture rather than forcing operators to stitch together separate feeds. Tulsa’s Skyway Range, a dedicated UTM test corridor where AirWise is headquartered, now runs on that same fused-data approach. Washington State Patrol has credited the platform with supporting tactical operations, including the resolution of a multistate wilderness manhunt.
O’Leary cautioned that scaling this kind of awareness gets complicated fast. Remote ID broadcasts remain inconsistent in accuracy and latency, he said, so UTM telemetry-sharing will carry the bulk of the deconfliction burden while other detection layers, including radar and RF sensing, fill in for aircraft operating outside the system entirely. He also warned against burying operators in more data than they can use. “You don’t want to overwhelm the user and see too many things, too many blips on a screen,” O’Leary said. Systems need to highlight the aircraft that matter to a given operator while filtering out the rest.
Retired FAA Official: Rule Is Not Ready
Kerry Fleming spent nearly four decades at the FAA, including the final 18 in airspace security, where he became known as one of the country’s foremost authorities on temporary flight restrictions (TFRs) and emergency airspace waivers. He now consults through UAS LLC and serves on the board of DRONERESPONDERS. He expressed concerns about the current rulemaking draft. “There are so many things in that proposal that right now cannot work,” Fleming said.
Fleming revealed that first responders and critical infrastructure operators felt underrepresented in the original draft, while operators of traditional manned aircraft raised concerns about how they would even know where drone traffic exists without new detection equipment. He is skeptical that UTM as currently deployed could handle nationwide scale on day one. “We’re still not even through the walking stage,” Fleming said, referring to isolated regional successes which cannot compare to the vast stretches of the country that have no UTM infrastructure at all.
Prioritization: The Central Unsolved Problem
Across every speaker, one theme kept resurfacing: prioritization schemes need more nuance than today’s binary standard-or-priority model allows.
Simboli argued for a tiered system resembling air traffic terminology like “immediate” versus “expedite,” so a routine patrol does not automatically override every other operator’s flight the same way a structure fire might.
Graveline agreed that public safety needs to use priority access judiciously rather than by default, drawing a parallel to police discretion around lights and sirens. “We’re going to have to prioritize these types of calls,” he said, acknowledging that not every dispatch call warrants overriding shared airspace.
O’Leary warned that prioritization gets harder, not easier, once the airspace picture expands beyond drones. UTM systems can sort out conflicts between participating operators, he said, but general aviation aircraft without ADS-B, along with future advanced air mobility traffic flying at higher altitudes, sit largely outside that framework today. “People act like UTM is going to solve everything, but then we have advanced air mobility,” O’Leary said. “How’s that going to deal with the general aviation guys, especially if they’re not using ADS-B out? And how do you deconflict that?” Whether it is 200 feet or a thousand feet, he added, the industry will eventually need to blend every layer of traffic into one coordinated system rather than solving prioritization one altitude band at a time.
Fleming offered his own long-range prediction, forecasting private-sector infrastructure overseen loosely by the FAA, punctuated by real operational failures as networks scale. “There’s going to be a lot of drones that fall out of the sky because of switching over to different networks and different software providers that are incompatible,” he said. “We’ll get there. We always do, but it’s not going to be easy.”
Part 108 might finally answer the question operators have asked for years: how do I get permission to fly BVLOS? But this panel made clear that the industry’s next fight will be to make sure that the thousands of simultaneous answers to that question do not collide in the sky.