Last week NAAA submitted comments on an exemption request from Moog Inc. to the FAA detailing why commercial UAV users must hold commercial pilot certificates.  Moog Inc. is seeking permission to operate a UAV over 55 pounds for commercial purposes with only a Part 107 remote pilot certificate. NAAA commented that the additional hours required to earn an advanced pilot license required for commercial operations is justified since commercial operations are more complicated than pleasure flights. A higher class of license is justified because this requirement increases safety in the National Airspace System, and safety should not be compromised. UAV’s will be operating within airspace shared by manned aircraft, who need to be assured that UAV pilots are competent at operating their aircraft.

Furthermore, NAAA Moog Inc. does not describe what type of commercial activity it seeks to undertake with this exemption. “The public cannot fully evaluate the risk associated with this petition when it does not know what type of commercial activity will take place, or the specifications and operational limitations of the UAV itself. The petition only states operations will take place below 400 feet AGL in Class G airspace within visual line of sight,” the comments read.  

“The petitioner and the FAA must recognize agricultural aircraft primarily operate under 400 feet AGL, ferrying to and from the job site at 500 feet AGL. Every other phase of the flight is conducted below 400 feet AGL, with the aircraft as low as 10 feet off the ground at speeds of up to 140 mph during an application pass, making UAVs a collision risk, as previously stated in these comments.”