• Some are for surveillance or have features that are not necessarily user-friendly. Although this list is primarily for the Department of Defense’s use of UAS, it may be used as a high-level guide by state DOTs regarding UAS procurement.

  Another consideration for state DOTs looking to procure UAS is the 2024 National Defense Authorization Act (NDAA), which further restricts UAS manufactured in foreign countries that present potential national security threats from being used on any federally funded projects (Plaza 2024). NDAA certification is documented using the government-supplied NDAA-889-Representation Form: Contractor’s Certification on Compliance with NDAA. A government agency may ask for this certification to verify NDAA compliance, which makes the manufacturer responsible for compliance with the law. Another resource to identify NDAA-compliant UAS is the Green UAS list (https://www.auvsi.org/green-uas enabled), enabled in early 2023 by the Association for Uncrewed Vehicle Systems International in partnership with the Defense Innovation Unit.

  State DOTs have mixed opinions and concerns about an eventual all-out ban on particular UAS and how it will be enforced. Greater clarity on whether country-of-origin bans fall under federal purview and will eventually be enforced, or if discretion will remain with state DOTs, would help streamline regulatory compliance and provide valuable information as state DOTs are renewing UAS fleets.

• Establishing Federal Standards for Professional UAS Operators: The FAA plays a central role in establishing and enforcing standards across aviation operations and oversees the licensing of pilots, including UAS pilots. Various public and private stakeholders have expressed concerns about the lack of practical UAS experience needed to become a certified UAS pilot. A potential role of the FAA could be to establish a federal standard for professional UAS pilots that offers clarity and greater certification rigor on UAS pilot responsibilities, practical qualifications, licensing requirements, and the impacts of autonomy. The establishment of practical UAS qualifications to be added to the current certification written examination could promote operational consistency, risk management, and safer continuous integration of UAS into the NAS.

AAM Topics

The federal role as related to AAM topics includes framework development, UTM, and internal and external coordination efforts.

Framework Development

One of the primary topics that emerged in the focus group data was that the role of federal agencies, as it relates to AAM, is to provide leadership by developing frameworks that can enable the integration of AAM. The role of the federal government becomes paramount in the safe, efficient, and widespread integration of AAM into the NAS and existing transportation and logistics ecosystems.

• Guidance for Advanced UAS Operations and AAM Integration: As UAS technologies advance and the prospect of AAM becomes more tangible, the role of the FAA in defining the certification and practical training standards becomes increasingly important. Bridging the gap between traditional UAS operations and AAM use cases using UAS will require comprehensive regulatory frameworks, operational standards, certification standards, and safety protocols. The FAA has been demonstrating its commitment to this role by publishing various ConOps documents. The FAA has also been working to allow the traditional aviation operational frameworks to include UAS and eventually eVTOL aircraft (e.g., allowing UAS package delivery companies to operate under current Part 135 Air Carrier regulations). The FAA’s top priority is the safety and safe integration of these emerging technologies, which, at times, is at odds with the fast-paced innovation of the industry. Industry stakeholders and state DOTs

• are seeking additional guidance on what roles they should play from the federal perspective. This is a topic that federal agencies can consider in future versions of the current ConOps documents.
• Ensuring Continuity and Common Interoperability: A foundational aspect of AAM integration is the establishment of common standards, interoperability protocols, and equipment that will be used across the air transportation ecosystem. Traditional aviation infrastructure is largely for public use, and if the goal for AAM is to benefit humanity and not just a select few, it may be important to take a similar approach to AAM infrastructure. The federal government can coordinate with industry and other state and local government stakeholders to develop standards that enable interoperability. One example would be standardizing the type of charging infrastructure and charging apparatus that will be used to serve electric aircraft. Through the establishment of regulatory frameworks and guidelines, AAM vehicles, infrastructure, and airspace management systems will be able to communicate and operate cohesively.
• Modernizing Existing Aviation Infrastructure for AAM: The network of airports and heliports across the country presents a valuable existing resource that could be leveraged to enable RAM and UAM operations. However, many of these facilities require modernization to accommodate AAM aircraft (e.g., greater electrical infrastructure to provide charging capabilities). The federal government can update traditional aviation infrastructure funding mechanisms, such as the Airport Improvement Program or the Passenger Facility Charges. In addition to potential updates of these traditional funding mechanisms, the federal government could consider establishing new funding mechanisms to incentivize the modernization of existing infrastructure and the development of new facilities to enable greater-scale AAM operations. By making necessary funding changes and incentivizing P3s, the federal government could stimulate investment in AAM infrastructure, which could enable greater access by the average person to these technologies.
• Policy Framework for Cross-Border Operations: AAM integration extends beyond national borders, necessitating collaboration and harmonization of regulations with neighboring countries. During the focus groups, multiple industry and border state stakeholders raised the example of cross-border operations between the United States and Canada to illustrate the importance and need for bilateral agreements and policy frameworks to facilitate seamless AAM operations across international boundaries. There are traditional frameworks for dealing with airplanes full of passengers and cargo that cross borders daily, but stakeholders involved in conducting operations across borders with UAS discussed regulatory and legal issues because existing legal language does not include UAS. Additionally, there are national security concerns around UAS sensors, technology, and data tracking. The federal government can lead diplomatic efforts to negotiate reciprocal agreements with foreign governments, addressing regulatory and legal roadblocks. By fostering international cooperation, the government can unlock new opportunities for AAM operators while enhancing regional connectivity and economic growth.

Unmanned Traffic Management

The FAA manages all airspace over the United States and its territories and has longstanding legal jurisdiction over the airspace (United States V. Causby, 328 U.S. 256 [1946]). The FAA manages this airspace with the Air Traffic Management system, largely relying on the Air Traffic Control system, which uses air traffic controllers. These legacy airspace management systems are unable to scale with UAS and AAM operations. This is the role of UTM, which is an airspace traffic management system that will be separate from Air Traffic Management but complementary to and integrated with these legacy systems. UTM would manage unmanned operations. (Source: FAA (2020a).

Figure 22 graphically highlights the operational context for UTM.

accessibility, and sustainability. Effective coordination among federal agencies is essential to realize and maximize the potential benefits. The federal government has taken this role seriously by organizing the AAM IWG discussed earlier in Chapter 5 in the “Broader AAM Coordination” section. While this working group facilitates coordination across the various departments of government, greater coordination within the USDOT and within the FAA would be helpful.

Given the nature of eVTOL aircraft, one area where enhanced coordination may be beneficial is the collaboration between the FAA, FHWA, Federal Railroad Administration, and Federal Transit Administration. The Federal Railroad Administration, which oversees rail transportation, and the Federal Transit Administration, which oversees public transit systems, may be able to participate more fully with the FAA and FHWA, especially concerning mature AAM operations and multimodal opportunities. In a recent publication, Schwartz et al. (2024) explore AAM and how rail facilities can plan for the future integration of vertiports to provide multimodal transportation options to passengers. The FAA’s Innovate 28 Initiative outlines the short-term vision where AAM aircraft will largely use existing aviation infrastructure. The long-term vision of a mature AAM operation includes integrating AAM with existing rail and highway networks in an effort to create more transportation options and more robust transportation systems. Another key government organization that can enhance coordination is the Joint Office of Energy and Transportation,

which coordinates expertise between the US Department of Energy and the USDOT. By fostering dialogue and sharing expertise, these federal agencies can identify synergies and develop integrated strategies for AAM deployment across different modes of transportation.

Within the FAA, breaking down silos is paramount to fostering innovation and accommodating the diverse needs of AAM stakeholders. The FAA organizational structure encompasses 14 different offices, many of which, if not all, will play a role regarding AAM (FAA 2023g). Silos within the agency between these different offices can hinder communication, decision-making, and the overall regulatory processes. To overcome these barriers, the FAA would want to consider prioritizing cross-functional collaboration and knowledge sharing among its offices and divisions. By fostering a culture of greater coordination, the FAA could better address the evolving challenges and opportunities posed by AAM, including airspace management, certification standards, and infrastructure needs.

The State Role

Many of the roles a state DOT should play in UAS programs and operations have been explored throughout the previous chapters of the Guide; therefore, this section summarizes UAS topics with a focus on AAM topics.

UAS Topics

The main roles and responsibilities of a state DOT regarding UAS operations are rooted in safety. State DOTs should provide robust basic, intermediate, and expert-level training, not just exam preparation, but practical UAS training. It is imperative to have comprehensive UAS policies and procedures to guide the safe integration of UAS technologies into state DOT operations. Additionally, a state DOT is responsible for making sure all UAS operations comply with federal regulations. Once a state DOT has a strong, well-established UAS program, it can take on a leadership role and assist other state and local agencies seeking to implement UAS. It can facilitate cross-training on UAS with other agencies and be a leader in safe operations and effective data use.

The role of a state DOT in managing its UAS data is crucial to efficient operations. A state DOT bears the responsibility of implementing robust data management practices, encompassing the collection, storage, and analysis of UAS data. This includes organizing data in a systematic and accessible manner and adhering to any internal data standards or best practices to enhance interoperability and compatibility across various platforms. Moreover, facilitating data sharing among relevant stakeholders fosters collaboration and informed decision-making processes within the transportation ecosystem. When meeting these responsibilities, a state DOT can harness the full potential of UAS technology while safeguarding privacy, security, and regulatory compliance.

AAM Topics

The state DOT can take a leadership role across multiple initiatives to advance AAM within its state. The state role, as related to AAM topics, includes coordination, leadership, planning, UTM, outreach, and support.

Coordination Leadership

While some regions or cities within a state may be more forward-leaning in their pursuits of adopting AAM, it is important that the state DOT take a leading role in coordination efforts to facilitate a statewide systematic approach. The state DOT can facilitate the assembly of

stakeholders from academia, various levels of government, and industry to address the challenges associated with AAM adoption. These cooperation efforts should include coordination between cities, metropolitan planning organizations, associations of government, and other transportation authorities. This involves planning for multimodal integration and ensuring seamless connectivity across transportation networks. By convening the diverse perspectives of multiple stakeholders, the state DOT can leverage expertise and resources to develop comprehensive roadmaps for AAM integration.

Another key piece of coordination is legislative coordination. The state DOT can play a role in coordinating with state legislators and the legislative transportation committees. The state DOT can promote enabling legislation to establish the necessary collaboration frameworks between state and city jurisdictions, transportation planning organizations, and other relevant stakeholders. This legal framework can provide overarching guidance and support for effective coordination and integration of multimodal transportation systems, including AAM technologies.

State DOTs are actively involved in addressing existing transportation problems with existing resources while also planning for future transportation technologies. This involves leading coordination efforts and establishing robust steering committees to drive innovative progress. To enable greater collaboration, any intra-agency and interagency silos should be broken down. State DOTs should emphasize cross-disciplinary collaboration—the state DOT may implement strategies such as integrating aviation planners into the planning division to work on multimodal solutions to facilitate untraditional coordination between the divisions of aeronautics and other transportation planning divisions within the state DOT.

In addition to the coordination outlined earlier, state DOTs can be proactive in collaborating with other state DOTs, encouraging cooperation rather than competition. This involves sharing ideas, grants, and best practices to optimize resources and foster innovation collectively. Furthermore, collaboration with standards bodies may also be helpful as state DOTs develop implementation plans for AAM technologies.

Planning

Perhaps one of the larger roles a state DOT can play in preparing for AAM is leading the efforts on the development of an all-encompassing plan. AAM presents many opportunities and associated challenges that will need to be addressed with thorough planning and preparation. The American Planning Association’s (APA) PAS Report 606: Planning for Advanced Air Mobility is a resource that can provide additional details and information regarding planning, land use, zoning, and policymaking for AAM (Cohen et al. 2024). A comprehensive approach involves detailed analysis and strategic initiatives across various facets, including the following:

• Infrastructure Evaluation: There are over 19,000 aviation infrastructure facilities (airports, heliports, seaplane bases) across the United States (Bureau of Transportation Statistics 2014). State DOTs can conduct thorough assessments of the existing aviation infrastructure within their state. This evaluation aims to identify facilities suitable for repurposing or adaptation for public AAM use. The analysis can rank the existing infrastructure according to suitability, use case, condition, or other key considerations. As part of the infrastructure assessment, state DOTs should determine the technological readiness of existing infrastructure to support AAM operations. This includes evaluating the availability of necessary communication systems, navigation aids, radar systems, weather reporting systems (including Roadway Weather Information Systems), safety equipment, and other infrastructure needed to support UAS and AAM operations.
• Use Case Analysis: State DOTs can perform a state-specific use case analysis. This assessment can be done from two different perspectives. One perspective can be from a state DOT use perspective, seeking to understand how AAM can better serve the operations of the state DOT

• itself. This assessment can include an analysis of scenarios such as emergency preparedness and response, the transportation of tools and resources for a project, or the transportation of state officials. The second perspective would be to study potential use cases from a constituent’s standpoint. The evaluation would focus on understanding transportation system deficits and determining how AAM use cases could assist.
• Resource Study: The state DOT can identify resources required for AAM implementation, such as funding, skilled workforce, regulatory frameworks, and technological innovations. The state DOT can then study and inventory existing state programs, funding sources, potential partnerships, and other resources available to support AAM initiatives.
• Gap Analysis: Conducting a gap analysis helps identify deficiencies and areas needing improvement to facilitate AAM implementation, including gaps in infrastructure, regulatory frameworks, public awareness, and stakeholder coordination. The state DOT can take the lead in performing this gap analysis and determining the findings based on the efforts noted earlier.
• Ecosystem Roadmap Development: Building on the assessments and studies noted earlier, the state DOT should take the lead in fostering a comprehensive statewide ecosystem that facilitates UAS and AAM operations. This involves developing a framework or roadmap on the necessary steps to accomplish the vision and goals for equitable and sustainable integration of AAM technologies and use cases throughout the state.
• Policy Formulation: Once a state DOT has an actionable AAM implementation roadmap, it can proceed to develop a legislative advocacy strategy to enable legislation to enact the plan. This strategy includes establishing overarching rules and regulations for consistency while respecting the autonomy of local jurisdictions.
• Localized Planning: While the state DOT does take on a leadership role in planning and, in many cases, will have an oversight or regulatory role, the planning efforts at a local level should be done together with local agencies. When it comes to the identification of use cases, addressing transportation gaps, and potential vertiport locations, these tasks should be done collaboratively with the cities. State DOTs should respect local jurisdictions and planning procedures, but can assist local entities from a regional ecosystem perspective.
• Land Use Compatibility: State DOTs can assist and collaborate with regional or metropolitan planning organizations and local governments on master land-use planning. Proper land-use planning can help increase safe operations and mitigate noise and visual pollution. Compatibility of land use near airports has always been an important planning principle, but land use compatibility considerations increase in importance in new areas outside of airports during the planning of vertiports (Thompson et al. 2024). The APA Planning for AAM report referenced at the top of this section offers information on land use compatibility planning.
• Infrastructure Licensing: Some state DOTs have state licensing or permitting requirements for aviation infrastructure, such as heliports, through their office or division of aeronautics. Caltrans is an example of a state DOT that has a heliport permitting and inspection program in which it defines heliports, the site approval process, permit issuance requirements and conditions, and outlines the reasons heliports in California may have the permit revoked or suspended (Caltrans 2024). State DOTs’ heliport licensing or permitting standards vary from state to state, but understanding these procedures can assist states in exploring a licensing program for vertiports. A state licensing program can help improve the safety of existing heliports and the aviation system while also helping prepare for the future of AAM. For additional considerations on licensing and permitting, see Urban Air Mobility Policy Framework Considerations (Los Angeles Department of Transportation 2021).

Unmanned Traffic Management

There is potentially a role state DOTs can play in UTM, although, as noted earlier in the “Federal Role” section regarding UTM, it is currently unclear how state DOTs can assist the FAA in the management of airspace. There are pioneering state DOTs seeking to lead the way in developing

infrastructure to manage airspace corridors for UAS and AAM operations. These state DOTs understand their traditional role of designing, building, and managing transportation infrastructure, including aviation infrastructure, and envision having similar responsibilities for AAM integration.

Some examples of these efforts include Michigan DOT’s recently published comprehensive study on the feasibility of a UAS-connected corridor, which shares the findings of a project dedicated to understanding the need to develop the digital and physical infrastructure that would enable mature UAS operations across the state (Airspace Link Inc. 2023). Ohio DOT has also engaged in various efforts to lay the foundation for low-altitude air traffic management. One primary effort is the Ohio UTM project, which seeks to build a framework for UTM across Ohio. A pilot project of the concept will likely be implemented along the 33 SMART Mobility Corridor, which is a real-world test bed for automated ground vehicles and automated aircraft such as UAS (Judson et al. 2022). Utah DOT is another state that has conducted studies related to AAM integration into the airspace; it has studied corridors and investigated how the airspace could potentially be managed (Utah DOT, n.d.).

The efforts of these innovative state DOTs may complement the role of the FAA in airspace management. The concepts being developed by states regarding the needed digital infrastructure may pioneer the currently available technology, but as AAM operations increase over time and integrations evolve, it is likely that UTM solutions will evolve.

Outreach and Support

State DOTs can also take an active leadership role in outreach. A proactive approach is essential, and state DOTs can identify potential challenges and actively engage in devising solutions to address them. This proactive stance involves outreach efforts to diverse stakeholders, including local stakeholders, the FAA, and other federal agencies working on AAM advancement.

Counties and municipalities throughout the state will look to the state DOT to be the regional leader in spearheading the statewide efforts for AAM adoption. Many cities will not be able to do this on their own because they do not have the current bandwidth necessary. These city agencies are often understaffed and do not have the resources to actively plan for UAS and AAM adoption.

Recognizing these disparities in resources and capacity among local governments, state DOTs should bolster their own resources through legislative outreach, grant applications, and P3s to help these local entities. State DOTs can extend their support to cities that may lack the resources or expertise to explore UAS and AAM independently. This support can take various forms, such as providing technical assistance, facilitating partnerships, and offering funding opportunities to enable communities to assess how AAM can benefit their specific needs and priorities.

A critical aspect of state DOT involvement in AAM outreach is advocacy and community engagement. They play a pivotal role in raising awareness about the anticipated benefits and potential applications of UAS and AAM within communities. This involves being a leader in public outreach and facilitating the outreach efforts explained previously in the “AAM Outreach” section of Chapter 6.

The Local Role

As noted in the “State Role” section earlier in this chapter, state DOTs will be working with local governments and transportation agencies. To create a comprehensive resource, this section discusses AAM topics from a local authority perspective.

Local transportation agencies or local governments play a crucial role in preparing for AAM by addressing various aspects of infrastructure, regulation, and community engagement. These entities

must collaborate with state authorities to plan and site the physical ground infrastructure necessary for airside operations and airspace management. While cities have the power to dictate where UAS package deliveries or eVTOL services take place, they may require support in vertiport siting from an airspace perspective. However, cities should maintain ownership of zoning and siting decisions from a land-use perspective.

There is often a legitimate concern from the local agency perspective that federal or state authorities might have directives regarding the placement of vertiports, which could override local needs. By taking ownership of zoning regulations and land-use policies related to AAM infrastructure, local governments can actively shape the development of AAM within their communities while collaborating with state authorities to navigate regulatory frameworks effectively. Therefore, it is important for local governments to communicate and collaborate with higher levels of government to ensure that decisions align with local community needs and priorities.

Cities can begin early policy development by utilizing completed analyses and identifying proposed vertiport sites. As land-use regulators, they can adjust zoning laws as necessary to designate areas for future AAM ground infrastructure. Once these zoning regulations are enacted, it is important for cities to ensure that AAM-related terminology and definitions are clearly established and standardized. Additionally, cities can explore which local regulations can be implemented to accommodate AAM integration (Organ 2022). The Los Angeles DOT published Urban Air Mobility Policy Framework Considerations in 2021 that cities may find helpful (Los Angeles Department of Transportation 2021).

To avoid overplanning, local authorities should focus on realistic timelines, considering the development of AAM infrastructure over 5- to 10-year periods. Cities should maintain the broader view when developing city plans and include AAM use cases while participating in long-term city planning discussions. The following is a list of considerations a city can examine when developing an AAM plan:

• Identify viable markets and routes that will be beneficial and bring value to the city and community members.
• Plan vertiport locations from a transportation network systems perspective.
• Identify vertiport locations along chosen routes, accounting for land-use plans, zoning, current airspace, and community factors.
• Identify funding strategies.
• Organize a methodical stakeholder engagement plan.

Overarching Considerations

Based on the prevalent themes, the overarching considerations regarding the suggested roles and responsibilities of each level of government around AAM are provided in the following list:

• Federal Role: The federal role would primarily focus on establishing comprehensive regulations and guidelines for AAM operations, airspace management, and UAS operations. Additionally, the federal government could promote collaboration, provide funding opportunities, and support the modernization of infrastructure.
• State Role: State DOTs should take a proactive approach by coordinating and collaborating with various stakeholders, including other states, local governments, and industry. They should evaluate infrastructure, potential UAS and AAM use cases, and resources, including workforce, and identify existing gaps to develop a comprehensive statewide implementation roadmap. With an overarching roadmap, state DOTs can assist in the formulation of policies and work directly with local governments to integrate AAM.

• Local Role: Local governments should have the authority to determine zoning and siting regulations for AAM infrastructure, with support and coordination from state governments. They should actively engage with the public, communicate and collaborate with federal and state entities, and address local concerns related to AAM operations.

By being proactive concerning these roles and responsibilities, federal, state, and local governments can work together to facilitate the successful implementation of AAM while considering regulatory, infrastructure, and community needs.