Leading Edge Associates, a UAV technology company with a
Part 137 operating certificate, submitted a request to the FAA to be exempt
from various federal aviation regulations in order to operate its PrecisionVision
35 UAV for agricultural spraying purposes.
comments explaining that UAVs must first be equipped with certain safety
equipment to ensure the safety of manned aviators in the national airspace. The
Precision Vision 35 UAV has a maximum takeoff gross weight of 79 pounds. A
collision between one of these unmanned aircraft and a manned aircraft could be
Explaining the importance of maintaining an adequate level
of safety in the national airspace, NAAA wrote, “UAS should be equipped with
ADS-B Out-like technology and sense and avoid technology that lands the
unmanned aircraft when a manned aircraft is approaching an unsafe range. ADS-B Out-like technology would allow a
manned aircraft to track the vicinity of a UAV yet, due to the difficulty of
seeing small UAVs it wouldn’t act as the failsafe that an automatic grounding
mechanism would have.”
Leading edge sought to be exempt from certain sections of
the Part 137 knowledge and skills test as well as other training requirements
that apply to manned applicators, such as having a commercial pilot license.
Regarding this, NAAA wrote, “While UAS were not envisioned when Part 137 was
originally written, we believe the intention of the section needs to be
applicable to all agricultural aircraft and not limited to manned aircraft.
NAAA believes UAV pilots with recreational licenses should not be exempt from
the prohibition on recreational pilots from piloting aircraft for compensation
or in furtherance of a business.”
NAAA also stressed that UAVs must continue to give way to
manned aircraft in all circumstances and comply will all existing EPA pesticide
You can read NAAA’s full comments here.