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Part 108 Compliance

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Part 108 Compliance

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  • Home
  • BVLOS
  • Part 108
  • Part 146
  • Operations
    • Agriculture
    • Package Delivery
    • Aerial Survey
    • Civic Interest
    • Training
    • Demonstration
    • Recreational
    • Flight Test
    • Hazardous Materials

What is Part 146?

Introduction

14 CFR Part 146 is one of the most important supporting pillars of the new BVLOS framework. While Part 108 governs the operators, Part 146 governs the Automated Data Service Providers (ADSPs) — the organizations that supply the digital infrastructure (UTM services) necessary for safe, scalable BVLOS operations. Chapter 10 explains what ADSPs are, what services they provide, how they are regulated, and why they are essential for routine uncrewed aircraft operations in the National Airspace System.

Purpose and Structure of Part 146

Part 146 creates a formal certification and oversight framework for entities that provide automated data services to support uncrewed aircraft operations. These services form the backbone of Uncrewed Aircraft System Traffic Management (UTM) — a new, digital layer of the NAS designed specifically for low-altitude, high-density BVLOS flights. Unlike traditional ATC, which is centralized and human-intensive, UTM is distributed, automated, and highly scalable.

Core Services Provided by ADSPs

ADSPs are required to deliver several critical capabilities, including:

  • Strategic Deconfliction: Pre-flight coordination and reservation of safe flight trajectories to      prevent conflicts before they occur.
  • Traffic Awareness: Real-time broadcast of nearby aircraft positions and intentions.
  • Conformance Monitoring: Continuous verification that each UAS is following its approved      operational intent.
  • Emergency Coordination and Lost-Link Support: Standardized procedures for handling contingencies.
  • Data Exchange and Security: Secure, reliable sharing of operational data between operators, ADSPs, and the FAA.

These services are mandatory for most Part 108 operations and represent the primary mechanism for safe separation in low-altitude airspace where traditional radar coverage is limited.

Certification and Oversight of ADSPs

To become an approved ADSP, an organization must:

  • Submit a detailed application demonstrating technical capability, data security, and reliability.
  • Meet performance standards for availability, accuracy, and cybersecurity.
  • Implement a robust quality management and safety assurance program.
  • Undergo FAA audits and ongoing surveillance.

The FAA’s role shifts from direct air traffic control to oversight of these service providers, ensuring the system remains safe while encouraging innovation and competition in the UTM marketplace.

How ADSPs Support Part 108 Operators

Operators must connect to at least one FAA-approved ADSP before conducting BVLOS flights. The ADSP becomes an essential partner, providing the real-time data and coordination services that replace the visual observer’s role in traditional VLOS operations. This integration is what allows one operator or flight coordinator to safely supervise multiple aircraft simultaneously.

Current Status and Future Outlook

As of the 2025 NPRM, the FAA is establishing the initial certification process for ADSPs. Multiple industry consortia and technology providers are already developing UTM platforms in anticipation of Part 146 approval. Once operational, this ecosystem will be one of the most significant advancements in airspace management since the introduction of radar.

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