San Antonio Air Charter - Exemption/Rulemaking

GAMA is a global trade association devoted to fostering and advancing the general welfare, safety, interests and activities of general aviation. General aviation technology is rapidly evolving beyond traditional, piloted airplanes and helicopters, and the possible combinations of human, automation, and aircraft configuration and operation concepts is vast. The approach the authorities take relative to this emerging industry will determine it's success or failure. This petition for exemption includes considerations important for GAMA's broader membership and for that reason, we offer the following comments in support of the San Antonio Air Charter (SAAC) petition for exemption— •As we move towards automation that replaces the pilot, so-called "unknown-unknowns" will arise and must be addressed to safely move forward, and that can help to foster the certification process of new technologies in this sector. Some unknown-unknowns will be found during early developmental flight test, but at some point, the technology must be tested in operationally representative scenarios to uncover as many of the unknown-unknowns as possible. This does not imply completely trusting the technology, but rather using a safe, incremental approach that includes operations with a proven airplane, operated by an appropriately rated pilot and ground system in appropriate weather conditions. This approach should provide a level of safety similar to a single pilot allowing an autopilot to fly the airplane from just after takeoff to just before landing; something that has become commonplace for even small GA airplanes. •As with the development of other recent technologies like Enhanced Vision Systems (EVS), certification and operations are integrating more closely. This situation makes operationally representative testing critical for understanding shortcomings in the technology. Once the EVS was thoroughly tested in a simulator, flight testing of these experimental systems were permitted during quiet times at airports equipped for precision approaches in low traffic areas. This included testing in poor weather conditions because the EVS equipment was intended to provide a safety enhancement in these conditions. •The SAAC exemption petition is the logical continuation of already approved exemptions for UAS operations. This exemption aligns with the FAA mandate to integrate UAS into the NAS and does so with little new risks to the public. We respectfully ask the FAA to consider allowing our emerging AAM industry to start capturing operationally relevant data while providing mitigations that keep the whole operation within a level of safety equivalent to many GA operations today.