As the Federal Aviation Administration (FAA) advances its efforts to establish a formal framework for Beyond Visual Line of Sight (BVLOS) drone operations through its proposed Part 108 rule, Bulbul Inc. conducted an in-depth internal review of the Notice of Proposed Rulemaking (NPRM) and developed a detailed set of recommendations reflecting the realities of commercial drone delivery operations.
We believe it is important to share our perspective publicly to contribute to the ongoing dialogue around safe, standardized, and scalable BVLOS operations in the United States.
Understanding the FAA’s Part 108 Proposal
The FAA’s proposed Part 108 – Normalizing Unmanned Aircraft Systems Beyond Visual Line of Sight Operations aims to transition the industry from waiver-based permissions under Part 107 to a structured, repeatable regulatory framework.
If implemented, Part 108 will enable routine BVLOS operations for logistics, healthcare, infrastructure inspection, and public safety applications — paving the way for broader unmanned integration into the National Airspace System (NAS).
For Bulbul, this initiative represents a major step forward in aligning regulation with the capabilities of our Automated Drone Flying Platform (ADFP) and AeroCore Onboard Computing System, both built with compliance, redundancy, and real-time mission intelligence at their core.
Key Recommendations from Bulbul’s Analysis
As part of our review, Bulbul identified several areas where the FAA’s proposal aligns with industry needs — and others where greater clarity could accelerate innovation.
1. Operator-Based Approval Model: We strongly support the FAA’s shift toward organization-level accountability via Operating Permits and Certificates. This structure allows responsible operators to scale safely without redundant pilot-level waivers.
2. Tiered Safety Management Systems (SMS): We recommend that the FAA adopt tiered SMS requirements, enabling smaller operators to maintain compliance without excessive administrative overhead.
3. Preflight Automation and Digital Checklists: Bulbul’s ADFP already performs automated mission approvals through digital preflight checks — covering airspace authorization, weather, battery health, and risk assessment. We encourage the FAA to formally recognize such machine-logged preflight compliance as equivalent to manual processes, ensuring both safety and traceability.
4. Consensus Standards for Airworthiness: We support the use of performance-based certification and recommend publishing a clear list of accepted consensus standards to guide manufacturers in compliance validation.
5. Automated Data Service Providers (ADSPs): We advocate for interoperability benchmarks for ADSPs — ensuring reliable airspace awareness and allowing multiple data service providers to operate collaboratively within the same region.
6. Transition Path for Existing Operators: The FAA should define a fast-track transition mechanism for existing Part 107 BVLOS waiver holders to migrate into Part 108 once finalized, rewarding early adopters who already operate safely under controlled environments.
Bulbul’s Broader Vision
At Bulbul, we view regulation not as a barrier but as a catalyst for responsible innovation.
Our Menifee, California pilot program — supported by the city, local law enforcement, and healthcare advisors — demonstrates the readiness of both our technology and our community for regulated BVLOS operations.
Through our AeroCore and ADFP systems, we aim to set new standards for predictive safety, compliance automation, and operational scalability — aligning fully with the FAA’s long-term vision for integrated airspace management.
We believe that open collaboration between regulators, technology developers, and community stakeholders is essential to making drone delivery a trusted part of everyday infrastructure.
About Bulbul Inc.
Bulbul Inc. is a U.S.-based drone delivery technology company developing the Automated Drone Flying Platform (ADFP) and AeroCore Onboard Computing System, designed to enable safe, compliant, and autonomous BVLOS operations across logistics, healthcare, and emergency response sectors.
Want to know more? Email us at [hello@bulbuldelivery.com]
