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.

NAAA submitted 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 catastrophic

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 regulations.

You can read NAAA’s full comments here.