When a helicopter air ambulance transports a critically ill or injured patient, every second counts. At hospital heliports, some of those seconds occur in one of the most demanding portions of flight: low, slow, close to structures, managing turbulence, often under time pressure and during what is defined as a “Critical Phase of Flight.” Add an unidentified drone to this environment and a routine arrival or departure can become an immediate collision-avoidance situation, with consequences not only for the flight crew, but also for the patient whose survival may depend on uninterrupted and timely access to specialized care.
This operational reality should be central to the Federal Aviation Administration’s (FAA) effort to implement Section 2209 of the FAA Extension, Safety, and Security Act of 2016. The FAA’s proposed rule would establish a process through which operators or proprietors of eligible fixed-site facilities could request unmanned aircraft flight restrictions, or UAFRs. The proposal is an important step toward distinguishing lawful drone operations from flights that create safety or security risks near critical infrastructure.
For healthcare, however, the proposed eligibility framework narrowly focuses only on Level I adult and pediatric trauma centers with heliports. It risks confusing an administrative designation with actual patient criticality. The better question is not which designation appears on a hospital’s certification, but what the consequences would be for patients and the regional healthcare system if safe aeromedical access were disrupted.
Criticality Measured by Consequence
Federal law defines critical infrastructure by consequence: systems and assets so vital that their incapacity or destruction would have a debilitating effect on security, the economy, national public health or safety, or some combination of those interests. That definition does not say that only the highest administrative tier within a particular sector is critical. Yet the proposed healthcare criterion in the FAA’s draft 2209 rule effectively uses Level I trauma designation as a proxy for the public-health consequences of disruption.
That proxy does not match how emergency medical transportation actually works in the real world. Air-medical destination decisions depend on the patient’s condition, specialty care needs, bed and physician availability, weather, geography and transport time. A helicopter may bypass the nearest Level I trauma center because the patient needs a verified burn center, comprehensive stroke capability, neonatal intensive care, pediatric specialty care, cardiac intervention or an organ-transplant team. In some cases, a Level II center may provide the appropriate comprehensive trauma care necessary for patient survival based on time and distance. Importantly, the distinction between Level I and Level II trauma centers hinges substantially on research, teaching and program requirements, not on the criticality of the patients they treat, or the level of lifesaving care they can provide.
Level III trauma centers also perform an indispensable function, particularly in rural regions where there are no Level I or Level II facilities. They provide assessment, resuscitation, emergency operations, intensive care and stabilization while arranging transfers when patients require resources beyond the facility’s capabilities. Compared with Level II centers, Level III facilities generally have more limited specialist availability and resource depth, but they remain essential access points within regional trauma systems.
A key point to remember is that patients do not only arrive at a Level I facility in critical condition. They are first transported from outlying healthcare facilities and emergency scene locations in that same, if not worse condition, often being provided lifesaving medical treatment during the takeoff and enroute phases of flight.
A Risk-Based Healthcare Standard
A more defensible rule would allow any healthcare facility with a heliport or vertiport that routinely supports time-critical aeromedical transportation to apply for a UAFR. Eligibility should not guarantee approval, but it should open the door to a documented, risk-based review. The facility would still need to demonstrate operational dependency, exposure to UAS activity and the likely consequences of interrupted access to patient care.
At a minimum, the FAA should allow applications from Level II and Level III trauma centers, verified burn centers, comprehensive stroke centers, ST-elevation myocardial infarction receiving centers, neonatal intensive care centers, pediatric specialty hospitals, organ-transplant centers, regional referral hospitals and critical-access hospitals with established helicopter programs. Other facilities should be eligible when they can show comparable reliance on aviation for patients, organs, blood products, pharmaceuticals, medical personnel or specialized equipment.
This approach would align regulatory eligibility with the statutory standard while avoiding an indiscriminate expansion of restricted airspace. It would also recognize that criticality can be regional. A facility that appears modest in a national database may be the only practical point of access to definitive healthcare across hundreds of square miles.
The Blind Spot Around Heliports
The policy challenge extends far beyond deciding which hospitals should be allowed to apply. The FAA must also confront its significant information gap concerning hospital heliports in the U.S. As of today, the nation does not have a sufficiently complete, standardized picture of healthcare aviation infrastructure.
While the FAA Airport Master Record includes a “medical use” indicator, that field does not reliably identify hospital heliports. Some facilities marked as medical use are not located at hospitals, while other hospital heliports are not classified as medical use. The FAA also does not systematically track whether a facility is associated with a trauma center, burn center, stroke center, neonatal unit, transplant program or other specialty care services.
My company, Five-Alpha, reviewed FAA data, which listed 5,678 U.S. heliports as of September 19, 2026, including 2,971 categorized for medical use. But the actual number of hospital heliports still remains unknown. A detailed examination of Indiana’s hospital heliports illustrates the problem. FAA records identified 112 heliports in the state of Indiana, including 70 categorized for medical use. An independent review identified that there are in fact 144 heliports in the state, 113 of which were associated with a hospital. Relative to the independent inventory, the FAA heliport total was approximately 22 percent lower, while its medical-use count was approximately 38 percent lower than the number of identified hospital heliports. Because the two classifications are not equivalent, the comparison illustrates a classification and inventory gap rather than a precise error rate.
While one state does not establish a national error rate, it does expose a structural weakness. A UAFR program cannot protect infrastructure the government cannot accurately identify or does not even know exists. Nor can drone operators be expected to reliably avoid locations and flight paths that are absent, incomplete or poorly classified in the data sources supporting their flight planning efforts.
Low Altitude Does Not Mean Low Risk
Hospital helicopter operations and small UAS operations occupy overlapping low-altitude airspace. Helicopters arriving at and departing from heliports commonly operate below 500 feet above ground level, well beyond the landing pad. These aircraft may be descending, climbing, turning to align with prevailing winds, or maneuvering around buildings, terrain, obstacles or noise-sensitive areas.
For a heliport, the protected airspace is not confined to the painted touchdown area or the heliports primary surface. Under 14 CFR § 77.23, the heliport approach surface begins at the edge of the primary surface and extends outward and upward for 4,000 feet at an 8:1 slope for civil heliports, widening to 500 feet at its outer end. On level terrain, a drone operating at 400 feet above the heliport’s elevation would therefore begin to penetrate that approach surface approximately 3,200 feet from the edge of the primary surface. Where surrounding terrain is higher than the heliport’s elevation, that potential conflict can extend even farther.
The problem is then compounded because heliport approach and departure surfaces are rarely, if ever, recorded in the FAA’s Airport Master Record. This includes critical information such as whether the approach and departure path is straight or curved. A UAS operator will therefore only see a point representing the heliport without seeing the actual airspace being used by helicopters. Unlike a tower or crane, a drone is mobile. It can change position and altitude quickly, making it a dynamic hazard within an already compressed decision environment made more difficult by higher closure rates.
5,000 Feet Is a Reasonable Starting Point
Five-Alpha has recommended a 5,000-foot UAS restriction around designated healthcare heliports. That distance is not arbitrary. Section 77.9(b)(3) already uses a 5,000-foot, 25:1 notice-screening surface for construction or alteration near certain public-use, federal, military and instrument-procedure heliports. Although that provision does not encompass every hospital heliport, it demonstrates that the FAA already recognizes 5,000 feet as a relevant distance for screening potential impacts on heliport airspace.
Part 77’s notice criterion is not, in and of itself, a ready-made drone exclusion zone. The operational and legal questions are different, and any final rule must account for terrain, facility configuration, legitimate UAS missions, authorization procedures and the vertical limits of a restriction. Still, 5,000 feet provides a technically grounded starting point given that actual approach and departure paths are not available. It creates a buffer beyond the 4,000-foot approach surface and reduces dependence on infrastructure data that are known to be incomplete.
As healthcare systems increasingly use UAS for laboratory samples, pharmaceuticals, blood products, logistics, inspection and emergency response, the objective should be targeted protection, not a blanket ban on beneficial drone activity. These operations should be accommodated through coordination and authorization when conducted for or with the facility. The restriction should focus on nonparticipating or unauthorized aircraft that have not been integrated into the hospital’s aviation and emergency care plans.
Build the Data System the Rule Requires
The FAA should pair the UAFR rule with a national initiative to improve healthcare aviation infrastructure data. The need for better national data was recently addressed in the Air Ambulance Quality and Patient Safety (AAQPS) Advisory Committee Report to Congress, made publicly available by CMS in June 2026. This need is specifically addressed in Section 4.3, Modernizing Helipad Data, Infrastructure, and Safety Standards, and in AAQPS Recommendation 10, which states, “Congress should authorize funding and establish initiatives to modernize and digitize the Airport Data Information Portal (ADIP) in collaboration with the Federal Aviation Administration (FAA) and industry stakeholders.”
The Airport Master Record needs dedicated fields for healthcare-facility type, trauma level, burn and stroke capability, neonatal and transplant services, hospital association, ownership and use status, helicopter-air-ambulance capability, vertiport and powered-lift capability and the frequency or general level of aeromedical activity.
That inventory should encompass heliports, vertiports, droneports, and other emerging advanced air mobility facilities. It should also include usable information about approach and departure paths while protecting genuinely sensitive operational details. Better data would benefit far more than the UAFR program. It would improve our nation’s emergency planning and preparedness, UAS flight planning, infrastructure investment, safety analysis, and the integration of crewed and uncrewed aircraft in the National Airspace System.
Data modernization will require coordination among the FAA, healthcare systems, state aviation offices, emergency medical services, UAS operators and air-medical providers. It will also require a practical method for validating records and keeping them current. A database that is populated once and then allowed to age without oversight has already been proven to be a failed system.
A Narrow Rule Misses the Highest Consequences
The FAA deserves credit for moving Section 2209 toward implementation and for recognizing healthcare and public health as part of the nation’s critical infrastructure. The agency must balance safety and security with public access to the National Airspace System and the continued growth of legitimate UAS operations. That balance is achievable, but only if the healthcare critical infrastructure standard reflects the reality of how patients and aircraft actually move.
A Level I-only criterion would be simple to administer, but simplicity is not the same as accuracy. It could protect a major teaching hospital while excluding a regional burn center, neonatal referral center, rural stabilization hospital, or Level II trauma center on which an entire community depends. It could also embed today’s incomplete heliport data into tomorrow’s airspace decision-making.
The final framework should use consequence-based eligibility, allow a broader range of healthcare facilities to demonstrate need, establish technically supportable protective boundaries, accommodate authorized missions and improve the national infrastructure inventory. This is not an argument against UAS integration. It is an argument for integration based on accurate data, clearly defined operating expectations, and risk-informed decisions. When a helicopter departing or approaching a hospital is carrying a critically ill or injured patient, ambiguity in the surrounding low-altitude airspace can have consequences measured in minutes, and, potentially, in lives.