Drones: Beyond Visual Line of Sight Rulemaking

The FAA’s proposed Part 108 rulemaking is a critical opportunity for us as balloon pilots to ensure our continued safety in the evolving National Airspace System (NAS). With drones and BVLOS operations expanding rapidly, we must advocate for solutions that allow balloons and other non-electrical aircraft to “see and be seen.”

Hot air balloons cannot equip with traditional ADS-B, but the FAA is considering low-cost, portable Electronic Conspicuity (EC) devices—like the uAvionix SkyEcho—that can broadcast our position to drones and other aircraft. This is the single best step we can take to protect balloon pilots, passengers, and our industry.

We need to make our voices heard so the FAA acts quickly and decisively. The more balloon pilots submit strong comments, the better our chances of securing this vital safety enhancement.

Key Points to Include in Your Comment

 Safety First: Balloon pilots and passengers have a right to “see and be seen” in the NAS—especially with drones sharing our airspace.

Balloon Reality: Balloons cannot install ADS-B, but portable EC devices are affordable, battery-powered, and proven to work.

FAA’s Own Data: The FAA’s 2024 EC testing showed these devices perform reliably, even in less-than-ideal conditions.

Passenger Safety: With over 100,000–250,000 balloon passenger rides annually, visibility is not optional—it is essential.

Low Burden Solution: FAA should allow voluntary equipage under streamlined approval (NORSEE/ASTM standards) without costly certification hurdles.

Mutual Responsibility: Larger drones, especially BVLOS, should also carry cooperative EC to share the responsibility for safety.

Right-of-Way Protection: Equipping balloons with EC ensures our right-of-way is recognized and enforced.

I strongly support the FAA enabling and encouraging the voluntary use of portable EC devices for balloons and other non-electrical aircraft under Part 108. Safety is the FAA’s North Star, and ensuring balloons can “see and be seen” is the most effective way to protect pilots, passengers, and the NAS as a whole.