The Federal Communication Commission (FCC) has proposed new rules affecting the aviation industry. Proposed changes aim to generate new operational bandwidths and support the growing advanced air mobility (AAM) sector, most specifically Uncrewed Aircraft Systems (UAS) operations, while simultaneously ensuring efficient spectrum use and minimizing interference with any existing spectrum services.

The FCC has announced proposed changes to rules surrounding three spectrums for UAS in several key proposals in a recent NPRM:

  • Opening the 450 MHz band for aeronautical command and control operations with a single, nationwide licensing framework
  • Creating flexible licensing, operating, and technical rules to enable robust operations at various altitudes while minimizing interference
  • Expanding radiolocation operations in the 24.45-24.65 GHz band specifically for detecting UAS
  • Modernizing power regulations for Commercial Aviation Air-Ground Systems in the 849-851 MHz and 894-896 MHz bands used for in-flight connectivity

Public comments are due by April 16, 2025.

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Photo of Mary-Caitlin Ray Mary-Caitlin Ray

A former attorney for the Federal Aviation Administration, Mary-Caitlin represents aircraft owners, operators, and manufacturers as well as investors into aviation related businesses, advising on regulatory and transactional matters. Her clients come to her for practical and strategic advice on navigating complex aviation…

A former attorney for the Federal Aviation Administration, Mary-Caitlin represents aircraft owners, operators, and manufacturers as well as investors into aviation related businesses, advising on regulatory and transactional matters. Her clients come to her for practical and strategic advice on navigating complex aviation challenges. She has significant experience advising clients on the impacts of and solutions for emerging technologies in the aviation sector, including uncrewed aircraft systems (UAS or drones) and electric vertical takeoff and landing (eVTOL) aircraft.

Mary-Caitlin’s practice spans the crewed and uncrewed side of the aviation world.

She has advised Fortune 500 flight departments, high net worth individuals, and manufacturers and suppliers on regulatory concerns related to the operation and production of aircraft, including complex issues related to permitted compensation, pilot licensing, operating structures such as dry leasing, timesharing and fractional ownership agreements, and emergency and Letter of Investigation response related to quality escapes and incidents. She also represents clients in the acquisition and sale of business aircraft, including cross-border transactions requiring the export or import of aircraft.

Mary-Caitlin counsels drone and eVTOL manufacturers, operators, and owners on all aspects of FAA regulatory compliance, including the business impacts of the evolving global regulatory framework for emerging aviation technologies. She also advises drone manufacturers and operators developing internal aviation-related corporate policies and best practices.

Mary-Caitlin has significant experience advising investors on the regulatory implications of investment into a wide array of aviation-related businesses, including MROs, manufacturers (including eVTOL manufacturers), and businesses that own and/or operate aircraft.

Photo of Amna Arshad Amna Arshad

Amna Arshad, a former senior trial attorney at the U.S. Department of Transportation, has deep knowledge and experience in aviation issues, having drafted regulations, and led investigations, audits, and enforcement actions. Her government insights and relationships combined with her several years of…

Amna Arshad, a former senior trial attorney at the U.S. Department of Transportation, has deep knowledge and experience in aviation issues, having drafted regulations, and led investigations, audits, and enforcement actions. Her government insights and relationships combined with her several years of experience at top US Am Law 100 firms advising all types of global transportation clients—from major U.S. and non-U.S. passenger and cargo airlines, to transportation start-ups, as well as Fortune 200 companies—provide her a unique ability to counsel her clients through their most pressing challenges, including internal or government investigations, litigation/enforcement defense, and compliance counseling. Amna is a trusted leader who works with her clients to craft business-focused legal strategies, manage risk, and resolve complex issues with practical solutions.

Amna’s practice spans across a wide range of matters including but not limited to: enforcement and litigation defense, investigations, antitrust/competition, joint ventures and alliances, airports/slots, route proceedings, rulemakings, international law, consumer protection, economic/licensing matters as well as regulatory due diligence on mergers and acquisitions involving aviation interests. Amna also has experience advising companies that are investing in and creating new aviation technologies, including UAS and eVTOLs, on emerging regulatory issues and trends. Amna counsels clients on matters before all federal agencies that regulate the aviation sector including the U.S. Department of Transportation (DOT), FAA, NTSB, DOJ, and DHS (CBP/TSA).

Amna’s passion to advance diversity is a hallmark of her leadership. She is a member of the governing committee and chair of the diversity, equity, and inclusion committee for the ABA Air & Space Law Forum; the 2023-2024 president of the International Aviation Club of Washington; a member of the International Aviation Womens Association; a member of the Legal Advisory Committee of the Amica Center for Immigrants Rights; and a member of The Columbian Women of The George Washington University.

Amna is a thought leader and frequent author and speaker on a myriad of transportation and aviation legal topics. She has been recognized as “Aviation Lawyer of the Year,” Washington Business Journal’s “40 Under 40,” Law360’s “Transportation Rising Star,” and Chambers-ranked.

Photo of Amy Karnikian Amy Karnikian

Amy Karnikian is a seasoned aviation attorney and serves as counsel in the Aviation Group. Amy’s practice focuses on business and commercial aircraft, general aviation transactions, aviation regulatory compliance, and advising clients on emerging technologies such as unmanned aircraft systems (Drone/UAS) and electric…

Amy Karnikian is a seasoned aviation attorney and serves as counsel in the Aviation Group. Amy’s practice focuses on business and commercial aircraft, general aviation transactions, aviation regulatory compliance, and advising clients on emerging technologies such as unmanned aircraft systems (Drone/UAS) and electric vertical takeoff and landing (eVTOL) aircraft.

She advises high-net-worth individuals, Fortune 500 corporate flight departments, and airlines on operating structure matters such as leasing, timeshare and fractional ownership agreements, and the sale and purchase of aircraft. Amy also advises investors on the regulatory impact of investment in aviation-related businesses or those that own and/or operate aircraft.

Amy previously served as senior associate at a major law firm, where her practice focused on commercial aircraft sales, leasing, finance, restructuring, and a variety of other cross-border transactions. Her clientele included aircraft lessors, financial institutions, and airlines. During her tenure at that firm, she led the negotiations of high value sale-leaseback and financing transactions spanning various jurisdictions, aircraft maintenance contracts with OEMs and MROs, lease novations in connection with sale and purchase transactions, and various other corporate and transactional matters in the aviation space.

In addition to her work at that firm, Amy spent a year as a secondee at Amazon, where she supported the Global Amazon Air cargo business on a wide range of matters.

Amy earned her J.D. with a concentration in Corporate Law from Loyola Law School of Los Angeles and her B.A. in Global and International Studies from the University of California, Santa Barbara. Prior to her legal career, she worked for a leading aircraft lessor, where her passion for aviation took root.