The airspace demands predictability. That means situational awareness grounded in shared understanding, behaviors, standards and regulation. Commercial drone operators trying to scale beyond visual line of sight (BVLOS) are learning this the hard way. The National Airspace System (NAS) wasn’t designed to adapt to evolving business models, and today’s airspace accessibility rules often hinder the safe paths to drone economic growth. In practice, the FAA system rewards aircraft that show up where they’re expected within a tolerable margin. The agency issues normalized safety restrictions for everything else. Operators who understand this interoperability trade space will scale with routine access. Those who keep building custom frameworks will stay stuck in one-off waiver processing.
Last month, I spoke with Greg Dyer of Woolpert about mapping drone performance testing into existing FAA structures. Dyer advises clients on unmanned systems and airport infrastructure, bringing a deep airspace management perspective from his years at the FAA and his research on performance-based navigation at NASA Ames. We share a conviction that drone operations need “unified NAS thinking” that treats crewed and uncrewed traffic as parts of one operating environment to integrate cleanly into the only NAS we have.
The Waiver Trap

Commercial and public safety drone operators know the frustration firsthand. They file for a waiver, then wait. They build preplanning and mission execution to a temporary accommodation just to get moving and wind up building operational procedures around an interim process not designed to scale. The FAA knows this is tough and keeps looking for ways to streamline without sacrificing safety.
I see this every month with clients running pipeline inspection, precision agriculture and public safety overwatch missions. They have the aircraft, trained pilots and sensor packages to execute the mission. They lack a regulatory framework that treats their operations as routine rather than as exceptions. While Part 108 is intended to relieve some of that workload, each expansion beyond Part 108 regulatory language requires a new negotiation and a new risk assessment. The overhead puts a strain on profitability, slows deployment, and continues to add manual workload to the FAA.
Sustainable near-term scaling depends on feeding aircraft performance data into architectures the FAA already understands. The FAA knows how to manage performance-based airspace. It has been doing it for crewed aviation for decades. The drone community needs to learn how to feed performance data into that same architecture.
RNP as the Shared Language
Required Navigation Performance (RNP) defines how accurately an aircraft must navigate within a given volume of airspace, essentially a performance contract between the aircraft and the system. The aircraft promises a level of precision, and the system promises safe separation from other differently performing aircraft and obstacles. When both sides deliver, we achieve NAS predictability.
Greg and I walked through drone vehicle control, navigation, position reporting, communications and failure modes. The resulting picture closely mirrored today’s FAA risk continuum. Crewed aviation already speaks this language fluently. RNP 0.3, for example, means an aircraft will stay within 0.3 nautical miles of its intended path 95 percent of the time. RNP 1 means one nautical mile. Controllers understand exactly what those numbers imply. We already have the automation to build RNP procedures. We have well-trained drone pilots to fly within precise boundaries. We should test drone ops against existing RNP standards and document the results. We can do this today.
“Legacy FAA performance-based navigation engineering is advancing rapidly, and some traditional metrics are already being exceeded,” Dyer noted during our discussion. “The task is to document those advances and show the complete performance equation so integration continues with confidence and consistency.”
Every drone that can hold position within a defined volume should be generating performance data that feeds directly into NAS architecture. Every operator that documents its performance is helping build the dataset the FAA needs to write enabling policy.
Plain Language as Operational Discipline

Dyer and I also discussed clarity, plain language and strict definitions. I take a hard line on word accountability, because when stakeholders assume shared meaning around buzzwords, technical errors creep into coding, implementation and regulation. Walking back something already in motion, assumptions turn out to have been misaligned, gets expensive fast.
The FAA is navigating a transition in its own vocabulary. The UAS Integration Office is now the Advanced Aviation Technologies Office. It reports to Chris Rocheleau, with Jessica Jones as Executive Director and Paul Strande as Deputy. That reorganization signals a shift toward treating advanced aviation as a unified portfolio. The terminology has to keep pace. Operators, manufacturers, service suppliers, trainers, infrastructure developers and regulators need to agree on what performance standards mean before they can understand what operational approvals require.
Learning by Doing Inside the eIPP
That brings us to the eVTOL Integration Pilot Program, where these ideas get put under real operational stress. The eIPP uses the aircraft, procedures and infrastructure we already have today to work through real issues and inform FAA enabling policy.
I view this from multiple angles. Through Future Flight Global, I work with state transportation authorities to align operational concepts with route viability and infrastructure realities. Through 3 MAD Air, I connect ecosystem partners with other eIPP teams. These are real operators planning real flights in real airspace, generating data the FAA can use to write regulations that safely enable advanced aviation at scale.
Learn by Doing means we don’t wait for a perfect policy before we operate. We operate carefully, document rigorously, and feed the results back into the policy process. The eIPP provides a regulatory sandbox to do that within the current and near-term environment. It spans 26 states across 8 lead authorities and includes major OEMs, service suppliers, airport authorities, public safety and operators. Every flight adds evidence. Every anomaly teaches us something about where the standards need nuanced guidance, not just for eVTOLs but for drones as well.
The Path Forward for Commercial Operators

So what should a commercial operator do with this information? Start measuring your navigation performance against RNP standards now. Document your accuracy. Test your aircraft in controlled environments and record the results. Build the dataset before the regulation requires it. The operators who arrive with performance data already in hand will get routine approvals faster than the operators who wait for the FAA to invent a custom framework for their aircraft class.
The Center for Advanced Aviation Technologies (CAAT) airspace working group at Texas A&M University-Corpus Christi provides the industry a venue to conduct these tests and formalize this work. CAAT, managed by the Autonomy Research Institute (ARI), gathers diverse perspectives on national strategy work areas and channels them into funded FAA tasks. It is a place where operators, researchers and regulators can collaborate on both simulated and operational evidence. Dyer and I both agreed that CAAT’s white paper process offers a practical path to propose drone RNP adherence testing. These efforts will generate evidence. Evidence generates policy. Policy generates routine operations.
I’ll close with the reminder that vocabulary literally determines operational reality. The NAS will absorb drones at scale once our industry starts speaking the same language the FAA already understands.
