By: James Grimsley*
An important part of aviation rulemaking is the involvement of public stakeholders. Submitting effective public comments on the FAA’s Part 108 Notice of Proposed Rulemaking (NPRM) is an essential step to shape the future of drone regulations in the United States. The official deadline for public comment submission is October 5, 2025. Comments can be submitted directly through the Federal Register at the following link: Submit Public Comments.
Why Public Comments Matter for FAA’s Part 108 NPRM
Public feedback is crucial in the regulatory process. It ensures that the rule not only reflects expert recommendations but also addresses the concerns and collective wisdom of industry participants and the public. The regulatory journey is not complete until public feedback is considered. Drawing from our industry experiences with the Part 107 and Remote Identification (Remote ID) public comment process, we all should understand the significant impact that well-reasoned and well-written public comments can have on shaping the final rules. Here are my thoughts on how to provide the most impactful submissions.
Essential Tips for Impactful FAA Public Comments
Contributing to the FAA’s Part 108 draft rule is a vital opportunity to influence the future of drone regulations and to ensure that the rule provides the proper balance between all stakeholders. It is critical to submit comments that are thoughtfully constructed and specific, as well-written feedback ensures your voice is genuinely heard and considered during rulemaking.
Don’t Just Criticise: Propose Constructive Approaches
Effective comments go beyond pointing out flaws. They present concrete solutions, share meaningful industry experiences and focus on advancing safety. This multi-layered approach helps regulators shape rules that serve both innovation and public good. Instead of only critiquing proposed regulations, offer practical alternatives or improvements that address the root of the challenge. Solutions-oriented feedback is far more likely to influence regulatory outcomes in a positive way.
Champion Practical Solutions: Innovation, Safety & Resilience
Along those lines, acknowledge the difficult balance between safety, innovation, flexibility and responsibility. Remember that regulations have to balance technology innovation, flexibility, agility, safety and responsibility. This is a difficult balance many times. As we adopt more technologies, we have to think about resilience and reliability as well. But we have to be practical. So your proposed solutions should likewise be practical.
Provide Personal Insights: Illustrate With Firsthand Experiences
Avoid cut and paste form letters. Personalize your comment with unique experiences and professional observations to clarify why portions of the rule matter and support your points with real-world examples. Adding a human perspective makes your comments more impactful.
Advocate For Safety: Anchor Arguments to Aviation Standards
Connect your reasoning to universally accepted aviation safety standards, accepted principles and practice. We have fundamental safety tools in the toolbox that will never be outdated, so always use fundamental principles in your argument if possible. This strengthens your case and ensures regulators take your recommendations seriously.
Balance Critique with Support: Reinforce The Positive
I also strongly encourage positivity. Make sure to comment on the portions that you agree with and indicate support. Don’t just focus on the things that need to be changed but also reinforce support for the portions that you believe are strong and beneficial. Otherwise, there may be negative comments that are not balanced/countered by the supportive ones.
Collaborate and Highlight Key Points
Well-crafted comments are concise, organized and easy to read. They clearly present the main arguments and supporting evidence. For example, during the Remote ID NPRM, commenters who organized their feedback with bullet points and bolded highlights saw their concerns more readily addressed, compared to lengthy, unstructured submissions. Before submission, draft your comment and share it with colleagues or industry groups to enhance its clarity and depth. The value of qualified and dedicated teams as collaborative comments often bring together multidisciplinary insights and peer-reviewed suggestions.
Show Respect and Professionalism
Address opposing views constructively and refrain from generalizations. Maintaining a respectful tone, even in disagreement, increases the likelihood that your comment will be taken seriously by regulators. From my own personal observation on past public comment periods, commenters who avoided emotional or inflammatory language, and focused on evidence-based points, communicated concerns more effectively.
Examples from Prior Comments
- The original draft NPRM for Part 107 required medical certificates for visual observers. Ultimately the final Part 107 rule did not require this as a result of well-written public comments that addressed the practicality of this draft and drew parallels to the responsibilities of the PIC and flexibility of the PIC to make decisions based on his/her local situation and environment based on safety.
- A Remote ID public comment suggested encrypted access for enhanced privacy, proposing two practical alternatives: “general encrypted access” for trusted users and “strict encrypted access” for government agencies. While not ultimately accepted by the FAA in the final Remote ID rule, this type of suggestion demonstrates both constructive solution-building and strong advocacy.
- Industry submissions also highlighted broadcast-based Remote ID, with supporting operational data, referenced European practices and provided factual comparisons and cost implications to bolster recommendations.
By collaborating, highlighting key points and maintaining professionalism, contributors position their feedback to better influence FAA decisions. Thoughtful and respectful submissions set a standard for productive regulatory engagement.
Submit Your Comments: A Pivotal Milestone
The significance of this moment cannot be overstated. With almost two decades dedicated to drone regulatory advocacy, I recognize the critical juncture we are at collectively. This period marks a pivotal milestone for all involved.
Participating in FAA rulemaking is most successful when comments are clear, focused and collaborative. Drawing on best practices from previous rulemakings like Remote ID, effective submissions stand out by showcasing originality, collective expertise and professionalism. The FAA values comments that are substantive, solution-oriented, and respectful, making these strategies essential for anyone seeking real impact.
We are getting close! Submit your comments now and be heard:
- Go to the Federal Register’s official Part 108 NPRM page: FAA Part 108 NPRM Comments.
- Submit feedback before the October 5, 2025 deadline.
- Follow submission guidelines, including clarity, structure, and supporting evidence.
*James Grimsley the Executive Director of Advanced Technology Initiatives for the Choctaw Nation of Oklahoma. An aerospace and aviation executive with 35+ years’ experience in engineering, management, academic research and entrepreneurship, he is a renowned expert in technology policy for aviation and advanced transportation. James is also a passionate STE(A)M advocate, educator and team builder dedicated to empowering tribal and rural communities, inspiring future technologists, and fostering innovation. He served on the FAA’s BVLOS Aviation Rulemaking Committee (ARC) and the UAS Detection and Mitigation ARC.