NAAA this week submitted comments to the FAA on UPS Flight Forward’s (UPS FF) request for exemption from several Federal Aviation Regulations. Formed this past July, UPS Flight Forward is the UAV subsidiary of UPS.

The petition requested UPS FF use the Matternet M2 sUAS for package delivery. The M2 is approximately 50 x 50 x 10 inches in size, with a maximum gross takeoff weight of 29.1 pounds. The maximum payload capacity is 4.4 pounds.

NAAA explained it is critical UAVs be equipped with both an FAA-approved sense and avoid system to automatically ground the UAV when a manned aircraft is in the vicinity and with ADS-B Out-like technology. ADS-B Out-like technology would allow a manned aircraft to track the vicinity of a UAV. That technology is not enough, however, due to the difficulty of manned aircraft seeing small UAVs. An automatic grounding mechanism would act as a failsafe against collisions. 

The UPS FF M2 is already conducting operations 5 days a week under North Carolina’s UAS Integrated Pilot Program (IPP) delivering blood samples from WakeMed Hospital in Raleigh, NC to a laboratory on the WakeMed campus. Since this operation is part of North Carolina’s IPP, the public could not comment on the operations. 

The UAS IPP program is the result of an October 2017 Presidential Memorandum directing the Department of Transportation to establish a pilot program allowing state and local governments to loosen restrictions on UAV operations for the purpose of collecting data on UAV flights.  NAAA submitted comments to the U.S. Department of Transportation outlining the concerns the UAS IPP program presents for low-flying and other manned aviators. NAAA requested the FAA consider the safety and importance of the agricultural aviation industry when developing UAV policy so as not to jeopardize this key component to agricultural production.

You can read NAAA’s full comments the UPS FF exemption request here.