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Voice of the Aerial Application Industry
December 3, 2020
NAAA Comments to the FAA Urging More Safety Provisions to its Beyond Visual Line of Sight UAS Airworthiness Criteria Approval Proposal

What NAAA found to be the most concerning in these proposals is the lack of any traffic avoidance elements with manned aircraft.

This week NAAA submitted comments to the FAA opposing the approval of nine unmanned aircraft systems’ (UAS) airworthiness criteria due to a dearth of safety provisions in the proposals. The nine companies involved include well-known names such as Amazon.

The airworthiness criteria include both the UAS itself and the operating systems. All nine included the following: Beyond Visual Line of Sight (BVLOS), flights conducted with a ceiling of 400 feet AGL, and a 20-to-1 ratio of UAS to pilots. The expected uses are package delivery, medical supply delivery, survey mapping, infrastructure inspection and patrolling. The proposals did not mention aerial application. The maximum takeoff weights range from 23 pounds to 89 pounds. To view the complete proposals or to submit a comment, click any of the following: Airobotics, Amazon, Flirtey, Flytrex, Matternet, Percepto, Telegrid, Wingcopter, Zipline.

What NAAA found to be the most concerning in these proposals is the lack of any traffic avoidance elements with manned aircraft. Neither visual aids such as strobes and high-visibility paint schemes nor electronic solutions such as ADS-B are included in the design and construction criteria or the operating limitations for the UAS. Since remote identification (RID) is only in the concept stage and ADS-B is not required on most manned or unmanned flights, NAAA does not believe BVLOS flights should be allowed. Although not mentioned in the proposals, ground-based radar is sometimes offered as an enabling technology. NAAA believes that ground-based radar is an unproven and ineffective technology to rely on for the purposes of low-altitude traffic avoidance.

Allowing a 20-to-1 UAV-to-pilot ratio and statements in the proposal such as “the aircraft must not require exceptional piloting skill or alertness” indicate that these aircraft will be mostly operated autonomously by computer software. NAAA reminded the FAA that overreliance on aircraft piloting software has and continues to result in aircraft accidents. A recent notable example is the Boeing 737 MAX.

NAAA concluded each comment by reminding the FAA that the issue of protecting all pilots from midair collisions when they are operating near unmanned aircraft is vitally important. In the case of agricultural aviators, timely treatment of the crop is an issue of great importance to the safe, affordable and abundant production of food, fiber and biofuel to our global population. Allowing BVLOS operations without adequate sense-and-avoid technology is a danger to not only low-altitude manned aircraft but all manned aircraft. You may read NAAA’s comments here.

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This newsletter is intended for NAAA members only. NAAA requests that should any party desire to publish, distribute or quote any part of this newsletter that they first seek the permission of the Association. The views, thoughts, and opinions expressed herein do not necessarily represent those of the National Agricultural Aviation Association (NAAA), its Board of Directors, staff or membership. Items in this newsletter are not the result of paid advertising and are only meant to highlight newsworthy developments. No endorsement by NAAA is intended or implied.
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