Titan Protection releases comment framework for FAA Part 108 BVLOS rulemaking

KANSAS CITY, Kan.—Titan Protection has released a public comment framework designed to help security industry operators participate in the FAA's proposed Part 108 rulemaking for Beyond Visual Line of Sight (BVLOS) drone operations.

The proposed rule, published in August 2025, represents the most significant advancement in commercial drone regulations in over a decade. However, security-specific operational requirements have received limited attention in the rulemaking process.

"The security industry has a unique operational perspective that needs to be heard," said Ryan Smith, founder and president of Titan Protection. "We operate 24/7 in controlled environments. We respond to threats in real time. We protect critical infrastructure. These operational realities require different capabilities than package delivery or agricultural monitoring."

Titan Protection's comment framework addresses four critical areas for security operations: manual control requirements, shielded operations, risk assessment refinement, and performance-based standards. 

"We're not asking for special treatment - we're asking for regulations that acknowledge the operational realities of professional security operations," Smith added. "The FAA has explicitly requested real-world operational data. Security operators have exactly that."

The comment framework is designed to require personalization rather than serving as a form letter, consistent with regulatory best practices. The FAA's Administrative Procedure Act prioritizes quality and substance over quantity in public comment processes.

Part 108 will establish the first comprehensive framework for routine BVLOS operations in the National Airspace System, moving beyond the current case-by-case waiver system. The rule is mandated to be finalized by February 2026 under Executive Order 14307 "Unleashing American Drone Dominance."

The public comment period for FAA Docket FAA-2025-1908 closes Oct. 6, 2025, at 11:59 PM ET.

Titan Protection's comment framework and submission guide are available at https://www.tpcsecurity.com/en/faa-part-108-boilerplate-comments.