The FAA has taken visible, necessary steps to prepare the national airspace for Advanced Air Mobility. Its Innovate28 implementation plan lays out an actionable near-term path for piloted eVTOL operations, and the agency has updated operational thinking with the UAM Concept of Operations v2.0.

That said, the FAA’s draft regulatory posture — particularly the powered-lift pilot and certification proposals in the June NPRM — leans heavily on traditional airplane and rotorcraft paradigms. The agency proposes type certification of eVTOL and other AAM aircraft as a special class under 14 CFR 21.17(b) and intends to leverage performance-based Part 23 airworthiness rules as the certification basis.

Operationally, the draft rules are sensible in one major respect. The FAA is explicitly planning for near-term operations to be piloted and to use existing ATS structures while the ecosystem matures. That pragmatic, crawl-walk-run approach recognizes current constraints around infrastructure, ATC integration, and community acceptance.

But from the cockpit point of view several core problems remain unresolved and risk becoming real bottlenecks if not reworked.

1) Type-rating every powered-lift will drive training cost and slow scale-up

The NPRM and implementation plan foresee pilots holding type ratings for powered-lift types. For novel, low-weight, but numerous eVTOL models that share flight control philosophies and automation, a one-type-per-aircraft approach will multiply training burdens and fleet operating costs. The Flight Standardization Board process and type-rating system serve safety for unique, complex types. They are not optimized for a future where dozens of designs share common flight deck logic, automation modes, and high levels of system redundancy. The regulatory toolbox should allow for type-grouping, common-type credit, and clear paths for documenting commonality instead of an automatic, per-model type-rating default.

2) Experience-hour baselines do not match the operational profile of air-taxi work

The agency has signaled that AAM operators will largely use Part 135 frameworks and that pilots will have to meet updated qualification rules consistent with safe passenger-carrying operations. At the same time, regulatory material around powered-lift shows the FAA is hesitant to adopt dramatically lower hours-based thresholds without evidence. The result could be a mismatch: eVTOL air taxi services will look operationally like short, repetitive, highly scripted hops in defined corridors. Requiring pilots to meet full legacy hours minima for long-haul airline or traditional rotorcraft operations risks producing a pilot shortage and pricing services out of the market. The FAA should move to a competency-based, scenario-driven qualification path that leverages advanced simulators, structured supervised operating experience, and curriculum credit for automation management rather than relying primarily on block-hour accumulation.

3) Simulator and training device credit must be explicit and scalable

If eVTOL platforms incorporate more automation and redundancy than legacy helicopters, training strategy should reflect that. Many of the FAA’s contemporaneous documents describe using Means of Compliance and accepted consensus standards to show compliance, but the standards and simulator credit pathways remain underdeveloped for powered-lift. The FAA should publish clear, objective guidance on acceptable Flight Simulation Training Device levels, validation methods for automation failure scenarios, and a plan to accelerate instructor and check airman pipelines for AAM. Industry-grade simulators can safely reproduce the high-frequency, low-altitude emergency scenarios these aircraft will face. That capability should count for more than it often does today.

4) Special class certification is useful, but it must avoid ad hoc means-of-compliance

Type-certifying eVTOL as a special class makes sense because designs are novel. The special class path must, however, commit to a set of repeatable, harmonized Means of Compliance so OEMs and operators can plan certification programs without bespoke rulemaking for every design feature. The AAM plan recognizes the need for accepted MOCs and consensus standards, but work remains to define standardized MOCs that consider distributed propulsion, large battery systems, and integrated flight-control architectures. The absence of standardized MOCs will increase certification cost and lengthen timelines.

5) Airspace, vertiport, and community integration are as important as aircraft rules

The ConOps and implementation plan correctly put vertiports, corridors, noise, and community engagement front and center. Early operations will rely on existing heliports and airports, but those sites will need practical, locally implementable guidance for charging, firefighting, passenger flow, and noise mitigation. Regulations that only focus on aircraft and pilot boxes without matching, publishable vertiport standards and integration pathways will create operational friction for carriers and airports alike.

Practical fixes I would press the FAA to adopt now

  • Allow a type-group or commonality credit path. If several eVTOLs share flight-control laws, automation modes, and failure-mode characteristics, permit a shared type or cross-credit process to avoid unnecessary type-rating proliferation.

  • Move from hours-first to competency-first for initial pilot qualification. Use high-fidelity FSTDs, structured IOE, and a graduated supervised operations regime to demonstrate PIC proficiency for corridor-based, low-altitude service. Establish objective performance measures and scenario-based checkouts rather than fixed hours alone.

  • Define validated simulator standards and MOC packages for common automation failures and degraded-mode handling. Give explicit FSTD credit for mastery of those scenarios.

  • Publish a prioritized list of MOCs and consensus standards the FAA will accept for common eVTOL architectures. Harmonize early with EASA and other civil authorities to reduce divergent certification paths for manufacturers targeting multiple markets.

  • Couple the pilot qualification path to an industry-backed ab initio pipeline. Part 135 demand will spawn training needs. The FAA and industry should co-author training syllabi, accepted proficiency checks, and instructor qualification pathways so the instructor shortage does not become the rate-limiting step.

Bottom line

The FAA is right to publish roadmaps and to avoid reckless speed. The agency is balancing safety, community acceptance, and industry momentum. The problem with the current draft rules is not the safety-first intent. It is the default to legacy structures where newer, more efficient regulatory constructs would better match the operational realities of air-taxi style AAM. If the FAA recalibrates around competency, commonality, and scalable MOCs, we can get safe, routine eVTOL operations without strangling the nascent industry under training and certification overheads that were designed for a different era of flight.