Comment from Essential Aero, Inc.

Essential Aero, Inc. respectfully submits the attached comments on Draft FAA Order 5100.38E, the Airport Improvement Program (AIP) Handbook. Essential Aero is a U.S. manufacturer of autonomous airfield safety equipment, including the FOD-Bot autonomous foreign object debris (FOD) removal system (U.S. Patent No. 12,045,059), developed in collaboration with and with funding from the U.S. Air Force. We support the Draft Order's continued recognition of FOD removal equipment as eligible airfield safety equipment in Appendix C, Table C-4.1, and request two clarifications in the final Order: 1. Clarify that self-propelled FOD removal systems, including autonomous systems, qualify as eligible power sweepers under Appendix C, Table C-4.1, and that the exclusion for towed FOD sweepers applies only to passive sweeping implements that require a separate host vehicle and operator. 2. Clarify that airport-owned autonomous or remotely supervised ground vehicles operated under the authority of the airport sponsor are eligible for Vehicle Movement Area Transmitter (VMAT) acquisition and installation on the same basis as driver-operated vehicles under Appendix C, Table C-4.1. The full discussion and suggested language for both requests are provided in the attached letter. Thank you for your consideration. Robert Kupsh Business Development, Essential Aero, Inc. robert.kupsh@essentialaero.com