IAFC’s comments to the Federal Aviation Administration’s (FAA) proposal
October 9, 2025 – the International Association of Fire Chiefs filed comments to the Federal Aviation Administration’s (FAA) proposal. on rules for unmanned aircraft systems (UAS) operating beyond the visual line of sight (BVLOS). This proposal was intended for commercial UAS operations; however, the IAFC wanted to ensure that FAA includes the needs of public safety UAS in its new rules.
In its comments, the IAFC highlighted that the FAA’s new BVLOS rules should favor innovation and not hinder public safety operations. The IAFC requested that the FAA explicitly accommodate public safety BVLOS operations —including Drone as a First Responder (DFR) and First Responder Tactical BVLOS (TBVLOS).
To promote greater use of UAS by fire and EMS departments, the IAFC made the following recommendations:
- Create an explicit Public Safety pathway in Part 108 that accommodates Drone as a First Responder (DFR) and tactical BVLOS (TBVLOS) at ≤400’ above ground level under shielded, human-in-the-loop UAS operations.
- Preserve and integrate today’s effective waiver process for DFR/TCBVLOS operations, so public safety agencies do not lose operational gains.
- Ensure inclusivity beyond public aircraft operation (PAO) status for volunteer fire companies and non-governmental search and rescue teams.
- Provide priority handling in unmanned aircraft system traffic management (UTM)/automatic data service providers (ADSP) for authenticated emergency flights.
- Accept GIS-based operational mitigations (route/altitude constraints, ground-risk scoring, dynamic geofences) in lieu of cost-prohibitive equipment for cases where UAS are being used in low altitude operations and being protected from other air traffic by being shielded from view.
The FAA will review all comments it received in response to the proposed draft BVLOS proposal. The IAFC will keep its members informed as the FAA formulates its final rule.
Overview
Through this advocacy, the IAFC works to ensure fire and EMS leaders have a voice in federal aviation policy and can safely leverage emerging drone technology to protect responders, strengthen situational awareness, and save lives.
How does it benefit IAFC members and the fire & EMS service?
The letter specifically asks the FAA to recognize public safety missions, protect existing drone operating permissions, accommodate volunteer fire departments, and establish practical safety and training requirements
- Improves emergency response: Supports expanded drone use for assessing incidents, locating victims, and providing real-time situational awareness.
- Enhances responder safety: Allows incident commanders to evaluate hazardous or inaccessible areas before deploying personnel.
- Supports search and rescue: Advocates for drone capabilities that assist with locating stranded individuals, including during flooding and water rescues.
- Expands EMS capabilities: Supports innovative applications such as transporting lifesaving medications and medical tests.
- Reduces financial barriers: Encourages affordable safety requirements and consideration of grant-eligible equipment.
- Represents volunteer departments: Seeks to ensure smaller and volunteer fire departments have access to the same regulatory opportunities as larger agencies.
- Strengthens operational coordination: Recommends integrating drone operations with incident command systems, airspace management, and emergency response procedures.