Last month the Federal Aviation Administration (FAA) approved airworthiness criteria for two drone models—Zipline International and Matternet Inc. NAAA submitted comments to the FAA last November opposing the approval due to a lack of safety provisions in the proposals.

NAAA reported on the proposed airworthiness criteria in the December 3, 2020 eNewsletter. In the comments, NAAA stressed the importance of aerial application and the necessity for safe, low-altitude airspace to ensure that agricultural pilots flying manned aircraft can continue to do their jobs safely. NAAA questioned that the drone proposals could ensure a safe operating environment due to exempting drones from airworthiness criteria and not requiring drones to have any type of sense-and-avoid technology. Lack of sense-and-avoid technology is especially dangerous for UAS operating beyond visual line of sight (BVLOS), which was proposed in the airworthiness criteria for both the Zipline and Matternet drones. NAAA also registered concerns with the proposals allowing a 20-to-1 UAS-to-pilot ratio, and statements in the proposals such as “the aircraft must not require exceptional piloting skill or alertness”—conditions adding peril to low-altitude manned aviators.