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National Agricultural Aviation Association eNewsletter
Voice of the Aerial Application Industry
March 10, 2022
NAAA Comments to FAA to Deny Exemptions to Package Delivery Drones Compromising Aviation Safety

This week, NAAA submitted comments to the FAA on two drone operators’ requests for exemptions from parts of the aviation safety regulations. Ameriflight LLC and Amazon Prime Air have submitted requests for relief from Parts 61, 91 and 135 of the federal register to allow package delivery options without meeting certain aviation safety requirements that NAAA believes are necessary to maintain the safety of the National Airspace System. The drone companies’ requests for relief are available here (Ameriflight) and here (Amazon).


NAAA does not believe there has been sufficient information furnished to determine whether these companies have provided for an equivalent level of safety. These package delivery operations are expected to be conducted Beyond Visual Line of Sight (BVLOS) deliveries. The requests for relief from this broad package of regulations are not supported by the documents provided. NAAA commented against exemptions from regulations dealing with drones providing right of way to manned aircraft, abiding by minimum altitudes, equipping drones with altitude indicators, having pilot requirements, aircraft airworthiness certification and more. To read NAAA’s comments, look in the comments section for Ameriflight or Amazon.


While technologies are being developed that look promising for these and other unmanned operations to safely occur, NAAA is not aware of any testing that has been done to examine whether they work with low-flying agricultural aircraft. NAAA continues to insist on this testing being completed before unmanned BVLOS operations are allowed.
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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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