The U.S. Advanced Air Mobility Comprehensive Plan and Strategy: A Long-Range Look Forward

U.S. Department of Transportation (DOT) Secretary Sean Duffy invited leaders in the Advanced Air Mobility (AAM) industry and throughout the U.S. government to the DOT headquarters on Dec. 17, 2025, as he issued both the AAM Interagency Working Group's National Strategy (Strategy) and its Comprehensive Plan (Plan).¹ The decision to unveil the Strategy and Plan on Wright Brothers Day is a reminder of the great progress the U.S. aviation industry has experienced.²

Both the Plan and Strategy contain thought-provoking ideas and intriguing concepts for advancing AAM operations. These announcements seek to leverage innovation in regulatory approvals, changes in federal policy and the power of the federal purse to help the U.S. lead the world into the next generation of aviation manufacturing and future of flight. Action plans within the Plan and Strategy focus on recommendations to:

• capitalize on existing air traffic modernization systems and communication methods to enable increased automation and flexibility for airspace management
• reauthorize and appropriate an AAM Infrastructure Pilot Program for future years and prompt funding for infrastructure to enable early operations
• take steps to ensure security of operations and address supply chain challenges
• communicate with communities and governmental entities about AAM
• address workforce and training needs
• ensure AAM development benefits from automation.

Scalable Solutions for Long-Term Success

The Plan, which is based on the Advanced Air Mobility Coordination and Leadership Act (Act),³ provides long-term goals consistent with the Act, which specifically requires review of steps that will mature AAM operations, concepts and regulatory frameworks beyond initial operations. The Act requires evaluation of air traffic and safety concepts as part of enabling AAM operations at "higher levels of traffic density."⁴ The Act appears to anticipate review of potential funding opportunities, as it requires examination of how current federal programs might be used to advance the AAM industry.⁵ The U.S. Congress anticipated a long-term strategy under the Act, as the statute requires examination of infrastructure of all types to accommodate and support AAM operations after initial implementation of the planning and coordination that it requires. The Act also mandates examination of steps needed to ensure a robust and secure domestic supply chain and review of other factors that "may limit the full potential of the AAM industry," such as community acceptance.⁶

The Act, combined with the Plan and Strategy documents released on Dec. 17, 2025, anticipates that efficient decisions will occur and the federal government will maintain a fast pace. The Act requires development of an AAM National Strategy that contemplates support of "the evolution of early AAM to higher levels of activity and societal benefit."⁷ Subsequently, the Strategy, subtitled "A Bold Policy Vision for 2026-2036," states that "By 2027, there will be demonstrations and initial operations for contemporary aircraft as we leverage and modify our extensive airport infrastructure."⁸ By 2030, the Strategy anticipates new air operations in multiple urban and rural areas, "including quiet flights with Powered Lift aircraft," and short-takeoff-and-landing flights that will increase travel options and reduce noise impacts."⁹ This 2030 milestone also anticipates reaching various areas in which current aviation operations might be limited, such as flights in over water and rural areas. The Strategy further states that by 2035, advanced air options and "exciting use cases" will exist, such as fully autonomous flight in challenging areas.¹⁰

Consistency with Other Ongoing Plans

At the same time, the Federal Aviation Administration (FAA) has committed to completing a comprehensive overhaul of the air traffic control system and begun a measured, deliberate method for addressing aircraft certification challenges that arise from proposed integration of novel aircraft designs. Both principles and approaches are evident in the Plan and Strategy documents that address AAM.

Air Traffic Modernization

The Plan and implementation steps described in the Strategy address, in broad terms, the Trump Administration's current emphasis on achieving air traffic modernization goals. In furtherance of ensuring the federal government capitalizes on current and upcoming modernization efforts to transform air traffic control systems, the Plan requires development of a "roadmap" for airspace modernization to integrate new systems that support mature-state AAM operations within the FAA's Automation Evolution Strategy framework. The Plan anticipates new automation systems and use of "third-party service systems with autonomy and intelligence-based computing."¹¹

This emphasis of use of automation and modern tools for airspace management is consistent with recent FAA statements and efforts to achieve air traffic control modernization. In particular, in his recent testimony before the U.S. Senate Committee on Commerce, FAA Administrator Bryan Bedford described the agency's recent selection of an Integrator that will oversee transformational air traffic modernization projects, which will provide necessary updates to communication, radar and software systems.¹² Bedford cited Congress' initial appropriation of $12.5 billion in the One Big Beautiful Bill Act (OBBB) as a critical step toward air traffic control modernization but stated the agency needs approximately $20 billion in additional funding.¹³

Similarly, in his testimony before the U.S. House Transportation and Infrastructure Committee Subcommittee on Aviation on Dec. 16, 2025, Bedford said the FAA had already begun its modernization efforts, stating it had "taken the FAA's 15-year radar modernization roadmap and compressed it into a three-year timeline."¹⁴ The Administrator characterized such improvements as a means that will enable the Integrator to begin work immediately to improve air traffic infrastructure. In addition to the selection of an Integrator that will oversee all work for air traffic modernization under the OBBB, other recent developments in air traffic improvements indicate the FAA is already underway with its efforts: The agency recently concluded an opportunity for interested parties to respond to a Request for Information regarding a Common Automation Platform that would unify several platforms into a single solution that will be adaptable to meet the needs and increase efficiency of air traffic controllers as they provide services needed for ensuring safety in the increasingly congested and complex National Airspace System.¹⁵ Overall, the Plan and Strategy contain additional recommendations, such as those regarding autonomous supporting systems for aircraft, infrastructure and for airspace operations, that are generally consistent with ongoing modernization efforts already underway at the FAA.

Aircraft Certification

The Plan and accompanying Strategy also align with recent FAA actions and statements concerning one of the most notable challenges of integrating AAM operations into the National Airspace System: certification of aircraft. In general, in order to provide air carrier services, aircraft must have an appropriate type certificate and airworthiness certificate. As noted in a recent Holland & Knight alert, the FAA recently issued a final rule in furtherance of modernizing the process and standards for obtaining airworthiness certificates for aircraft that have "special" airworthiness certificates.¹⁶ Such modernization will occur by the FAA's use of performance-based standards, rather than prescriptive standards that do not provide flexibility. At approximately the same time that the FAA issued its final rule, it also issued a long-awaited Advisory Circular concerning 14 CFR 21.17(b), which is a regulation that permits the selection of a combination of aircraft certification standards that will lead to certification of aircraft. These steps provide a glimpse into the agency's mindset: It intends to move forward by generally accepting industry's feedback and proposed solutions and using an iterative approach by considering new standards and potentially adopting them. Although these steps might not immediately permit air carrier operations that manufacturers or operators may ultimately seek to conduct, they are important opportunities for manufacturing and testing of novel types of aircraft designs.

Though the Plan and Strategy do not directly address aircraft certification standards as an action step, the documents are consistent with the approach of using performance-based standards and innovative solutions for aircraft certification. The Recommendations and Action Plans category of each document contains an "Automation" pillar, which contemplates use of automation at almost all steps of the certification and integration processes for AAM operations. In particular, the Plan and Strategy state that the FAA and NASA, with support from the DOT and U.S. Department of War (DOW), will assess and deploy virtual testing to provide data needed to understand use of autonomous aircraft and scaled operations with widescale use in mind. The agencies will also maintain and coordinate aircraft testing and evaluation efforts to accelerate safe introduction and operations of AAM aircraft. The Plan states the research, development and implementation actions will consist of, in part:

• forming a research, development, testing and demonstration plan that will prompt acceptance of autonomous supporting systems for both "vehicle" and infrastructure, as well as airspace operations
• developing a comprehensive architecture that describes the functions and interactions, and describes automation at task, system and vehicle levels, to enable safe, scalable operations
• planning for tools to reduce cost, time and development of certified systems
• researching risks and benefits of Simplified Vehicle Operations (SVO) and Simplified Flight Controls (SFC), while examining pilot training, evaluation and accessibility of SVO and SFC, which might include time credited in an appropriate aircraft simulator, in various types of operation (such as piloted or autonomous)

In implementing the above steps, the Plan indicates sharing of resources and information among agencies in the Interagency Working Group in a variety of contexts in addition to testing new aircraft designs; for example, vertiport design and advanced air traffic concepts will benefit from sharing and coordination of testing resources. Such collaboration is also a theme of the Trump Administration's mindset with regard to modernizing certification of aircraft: In its June 2025 issuance of the Advanced Air Mobility Roadmap, the federal government described its multilateral agreement with other states to share means of compliance with aircraft certification standards in an effort to increase efficiency of aircraft certification.¹⁷

Partnering with industry stakeholders to achieve efficiency of certification of aircraft is consistent not only with the FAA's Modernization of Special Airworthiness Certification final rule and accompanying documents, but also with new proposed regulations concerning unmanned aircraft systems (UAS). In response to inquiries about airworthiness acceptance for UAS, Bedford indicated the agency intends to partner with industry, stating, "We're not telling industry how to do it. We're partnering with industry on how to figure out how to do it and make sure we as regulators and compliance personnel understand that and can actually manage this process safely."¹⁸ Observation of this same principle – relying on industry to introduce acceptable solutions – appears to be generally underway in determining and adopting appropriate certification standards for AAM.¹⁹

Infrastructure Development: Interaction Among Government Entities

The Plan and Strategy contain broad steps in furtherance of ensuring necessary infrastructure is available for AAM operations; in particular, the federal government anticipates collaboration with state, local, Tribal and territorial (SLTT) government entities and funding opportunities.

Regarding design and development of necessary infrastructure, the Plan and Strategy focus on vertiport solutions.²⁰ The Strategy acknowledges that updates to FAA guidance concerning development of vertiports are underway, as Congress directed the agency to issue revised guidance for vertiport design in the FAA Reauthorization Act of 2024.²¹ The Act also directed the FAA to streamline environmental review of vertiport projects by listing vertiports as a categorical exclusion under the National Environmental Policy Act (NEPA); the agency took such action in its updated NEPA Implementing Procedures publication.²² These developments clearly show that the federal government anticipates streamlined, efficient development of vertiports that will enable safe operations while remaining flexible by using performance-based design standards. The Plan and Strategy anticipate specific steps to address:

• using existing heliport designs while engaging with SLTT governments and industry to provide future models for planning and financing
• considering remotely piloted or autonomous aircraft when determining how existing infrastructure guidance for signage, marking and lighting should be updated or adapted
• researching energy infrastructure needs for AAM by engaging in demonstrations and working with industry stakeholders to determine best practices to ensure ample energy distribution
• addressing spectrum needs and spectrum bands for future airspace management transformation
• developing Complementary Positioning, Navigation and Timing (CPNT) options, which are capabilities that determine location, track movement and synchronize time that are critical for accurate navigation; the Strategy anticipates appropriate CPNT will function as a backup service to existing GPS to fulfill AAM performance requirements
• developing enhanced weather detection, as AAM operations will occur at low altitudes, where weather sources are less stable and where accurate detection of "microscale" weather will be critical for safe operations

Given that infrastructure development is a principal tenet of AAM operations, the Plan and Strategy emphasize a comprehensive approach in which the federal government will coordinate with SLTT government entities. In furtherance of such coordination, and considering a variety of potential solutions, the Plan calls for congressional reauthorization of an AAM Infrastructure Pilot Program for future years.²³

Financial Considerations and Opportunities for Funding

The Plan and Strategy both refer to private funding sources as well as potential options for federal funding or public-private partnerships. With regard to vertiport infrastructure, the Strategy anticipates that by 2030, AAM operations may occur from new and accessible vertiports that will be "funded mostly by private sources" and are able to reach currently underserved areas, such as over-water and rural areas.²⁴ The Strategy recommends engagement with SLTT governments and industry to review future models for planning and financing AAM infrastructure while funding existing programs for early operations.

Though the Plan specifically identifies discrete projects and goals for which the Trump Administration intends to request funding from Congress, both the Plan and Strategy first recommend that all agencies should "plan to incorporate existing recommendations in the Strategy and Plan into their annual budget requests and spending plans beginning in Fiscal Year (FY) 2027."²⁵ Both the Plan and Strategy indicate that the federal government anticipates a combination of public and private funding will further AAM solutions; in particular, the documents state that leveraging existing federal resources and public-private partnerships to support SLTTs and industry in workforce development and encouraging a talent pipeline are important goals.

Many of the specific recommendations concerning funding emphasize the need for infrastructure financing solutions and broadly assume that SLTT governments will partner with the federal government. For example, the Strategy states expansion and funding of existing infrastructure programs will include deliberations both with SLTT governments and with industry concerning future programs and funding mechanisms to sustain federal support for infrastructure needs, such as vertiports. This recommendation might give rise to a range of ideas for solutions, from innovative funding vehicles to traditional grants to SLTT government entities in furtherance of infrastructure development. More specifically, the Strategy indicates experts should convene now to determine infrastructure needs, financing solutions and "how to evolve Federal programs to address" infrastructure development.²⁶ Implementation of the Strategy's recommendations for infrastructure funding is a priority for the Interagency Working Group, as the action step of deliberating with SLTT governments appears in three of the four action phases of the Plan, followed by the initial step of analyzing existing federal financing programs for AAM infrastructure support.²⁷

The Strategy also addresses requests for funding for enhancement of research and development to include the following:

• continued development of pre-market technologies for safety and efficiency
• development of advanced electrified propulsion and energy storage systems
• improvement of occupant safety and comfort during operations
• reduction of noise and emissions
• advancement of high-rate composite manufacturing technology
• development of innovative simulation tools for use by "leading AAM companies"²⁸

In addition to funding research projects, the Strategy recommends the FAA work with NASA, the DOW, Federal Communications Commission, and National Telecommunications and Information Association in funding for air traffic control modernization. The Strategy anticipates that funding will be available for establishment of requirements for future air traffic control automation and decision support tools, as well as for research and development of new systems and tools that will increase data sharing and collaboration among all airspace users. In this regard, the Strategy's action phases appear to favor solutions that are generally consistent with the FAA's approach for managing airspace for unmanned aircraft operating beyond visual line of sight in its recent Notice of Proposed Rulemaking, along with statements the agency has made concerning the Brand New Air Traffic Control System.²⁹

Conclusion and Key Takeaways

The AAM Interagency Working Group's Plan and Strategy are a strong signal that the U.S. seeks to maintain leadership in aviation as it enters the third revolution in flight. The Plan and the Strategy provide a litany of recommendations and action steps in the interest of enabling AAM operations.

The federal government is signaling that it is receptive to solutions that include and defer to industry ideas, from initial designs to testing and ensuring reliability, with regard to aircraft certification, air traffic modernization and vertiport design. Interested stakeholders should remain aware of this receptivity in planning and taking action in furtherance of these opportunities.

Notes

¹ U.S. Department of Transportation, Advanced Air Mobility Interagency Working Group, The Advanced Air Mobility National Strategy: A Bold Policy Vision for 2026-2036 (Dec. 17, 2025); The Advanced Air Mobility Comprehensive Plan: LIFTing AAM to Maturity in the United States (Dec. 17, 2025). "Advanced Air Mobility" refers to an air transportation system that moves people and cargo between places using new aircraft designs that are integrated into existing airspace operations as well as operated in local, regional, intraregional, rural and urban environments. Pub. L. 117-209, 136 Stat. 2227 (Oct. 17, 2022). The FAA Reauthorization Act of 2024 later stated, for purposes of Title IX, Subtitle B of the Act, "[t]he terms "advanced air mobility" and "AAM" mean a transportation system that is comprised of urban air mobility and regional air mobility using manned or unmanned aircraft." Pub. L. 118-63 at § 951(1), 138 Stat. 1025, 1375 (May 16, 2024).

² 36 U.S.C. § 143 (designating Dec. 17 each year as Wright Brothers Day, to commemorate the first successful flights heavier than air).

³ Pub. L. 117-209, 136 Stat. 2227 (Oct. 17, 2022).

⁴ Id. § 2(e)(2), 136 Stat. at 2228.

⁵ Id. § 2(e)(3), 136 Stat. at 2228 (stating, "the working group shall complete a review and examination of … current Federal programs and policies that could be leveraged to advance the maturation of the AAM industry").

⁶ Id. § 2(e)(8), 136 Stat. at 2229.

⁷ Id. § 2(f)(1), 136 Stat. at 2229 (emphasis added).

⁸ DOT AAM Interagency Working Group, The Advanced Air Mobility National Strategy: A Bold Policy Vision for 2026-2036 at i (Dec. 17, 2025)

⁹ Id.

¹⁰ Id.

¹¹ DOT AAM Interagency Working Group, The Advanced Air Mobility Comprehensive Plan: LIFTing AAM to Maturity in the United States at 7 (Dec. 17, 2025).

¹² Testimony of Bryan Bedford, Hearing Before the U.S. Senate Committee on Commerce, Science, and Transportation Subcommittee on Aviation, Space, and Innovation on FAA's Plan for ATC Modernization: Evaluating Progress, Ensuring Accountability and Results (Dec. 17, 2025) The description of the work of the Integrator and the need for additional funding from Congress is consistent with the FAA's previous announcement that the federal government had selected Virginia-based company Peraton to serve as the Integrator. FAA, Trump's Transportation Secretary Duffy & FAA Administrator Bedford Announce Prime Integrator to Oversee Construction of Brand New Air Traffic Control System (Dec. 4, 2025).

¹³ As reported in Holland & Knight's 2026 Legislative and Regulatory Outlook, the OBBB provided $12.5 billion in several specific categories for the spending, which includes $4.75 billion for telecommunications infrastructure upgrades, $3 billion to replace radar systems and $1.9 billion to construct new air route traffic control centers (ARTCCs). The OBBB also called for spending of $100 million to conduct further ARTCC realignment and consolidation, $1 billion to support recapitalization and consolidation of terminal radar approach control facilities (TRACONs) and several million dollars to address air traffic controller training, air traffic control tower upgrades, remote towers and research.

¹⁴ Testimony of Bryan Bedford, Hearing before the U.S. House of Representatives Committee on Transportation and Infrastructure Subcommittee on Aviation on the State of American Aviation (Dec. 16, 2025) (further emphasizing the work the FAA had already undertaken, the Administrator stated, "[w]e have transitioned over one-third of our copper wire to fiber, and have begun modernizing radios, upgrading voice switches, and improving digital communications, among other critical improvements").

¹⁵ Platforms that the FAA intends to unify include En Route Automation Modernization (ERAM) and Standard Terminal Automation Replacement System (STARS) systems, which track and control aircraft. ERAM manages high-altitude flights in en route airspace at ARTCC. In contrast, STARS tracks and coordinates flights in TRACONs facilities and air traffic control towers; air traffic controllers use STARS for sequencing, issuing conflict alerts and providing weather updates to operators.

¹⁶ "A MOSAIC of Changes: Recent FAA Actions Promote Advanced Air Mobility," Holland & Knight alert (Aug. 5, 2025).

¹⁷ "NAA Network Releases First Roadmap for Advanced Air Mobility Aircraft Type Certification," Holland & Knight Aviation Blog (June 20, 2025).

¹⁸ FAA Administrator Testifies on Air Traffic Control Modernization, C-SPAN.org, at 1:03:00 (Dec. 17, 2025).

¹⁹ "A MOSAIC of Changes: Recent FAA Actions Promote Advanced Air Mobility," Holland & Knight alert (Aug. 5, 2025).

²⁰ As defined by FAA Reauthorization Act of 2024, a vertiport is an area of land, water or a structure used or intended to be used to support the landing, takeoff, taxiing, parking and storage of powered-lift aircraft or other aircraft that vertiport design and performance standards, established by the Administrator of the FAA, can accommodate. Pub. L. 118-63 § 951(5) (2024). More information regarding legal considerations that apply to vertiport development is available in Holland & Knight's previous alert, "Advanced Air Mobility and Vertiport Development: Effects of New Legislation in Florida" (July 1, 2025).

²¹ FAA Reauthorization Act of 2024, Pub. L. 118-63 at § 958(a)(3), 138 Stat. 1025, 1382 (May 16, 2024) (directing revision of FAA Advisory Circular titled "Heliport Design" (Advisory Circular 150/5390)); in addition, Section 958(a)(2) directed the FAA to publish a performance-based vertiport design advisory circular.

²² FAA Order 1050.1G (June 30, 2025); 90 Fed. Reg. 29615 (July 7, 2025).

²³ DOT AAM Interagency Working Group, The Advanced Air Mobility Comprehensive Plan: LIFTing AAM to Maturity in the United States at 9 (Dec. 17, 2025); see also FAA Reauthorization Act of 2024, Pub. L. 118-63 at § 960, 138 Stat. 1025, 1383 (May 16, 2024) (referring to and amending Section 101 of Division Q of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 4459, 5246 (Dec. 29, 2022)).

²⁴ DOT AAM Interagency Working Group, The Advanced Air Mobility National Strategy: A Bold Policy Vision for 2026-2036 at i (Dec. 17, 2025).

²⁵ Id. at 48; see also DOT AAM Interagency Working Group, The Advanced Air Mobility Comprehensive Plan: LIFTing AAM to Maturity in the United States at 4 (Dec. 17, 2025).

²⁶ DOT AAM Interagency Working Group, The Advanced Air Mobility National Strategy: A Bold Policy Vision for 2026-2036 at 14 (Dec. 17, 2025).

²⁷ Action Phases (titled "LIFT") of the Strategy include "Leveraging" existing resources, "Initiating" engagement with partners, research and development, and smart planning, "Forging" new policies and models responsive to public needs, and "Transforming" the aviation ecosystem.

²⁸ DOT AAM Interagency Working Group, The Advanced Air Mobility National Strategy: A Bold Policy Vision for 2026-2036 at 21 (Dec. 17, 2025).

²⁹ Holland & Knight alert, "Drone Beyond Line of Sight Proposed Rule: Top 10 Things You Need to Know" (Aug. 6, 2025) (stating that the proposed rule would require that most UAS operations use the services of an automated data service provider (ADSP) to ensure safe separation from other aircraft and would establish means of approval of ADSPs, with such entities being regulated by the FAA after ensuring they conform to industry consensus standards); See also FAA, Brand New Air Traffic Control System (BNATCS) Fact Sheet (Dec. 4, 2025) (stating the air traffic modernization project will broadly address updates to communications, surveillance, and automation equipment, among other categories it will update).

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