Last week the FAA approved airworthiness criteria for four drone models—Wingcopter, Telegrid, Flirtey and 3DRobotics. NAAA submitted comments to the FAA in November of 2021 opposing the approval due to a dearth 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 and questioned that the drone proposal could do that due to exempting drones from airworthiness criteria and not requiring drones 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 being proposed in the airworthiness criteria for some of the drone models. 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.
NAAA’s comments also touched on the overreliance of software with drones and lack of human oversight. Additionally, the proposal lacked ADS-B In/Out and traffic avoidance technology on the drones, in addition to lacking strobe lights and high-visibility paint schemes. While the FAA did not find it necessary to change the airworthiness criteria, the FAA did state that several of NAAA’s comments will be addressed during operational approval for these drones, which is forthcoming. NAAA continues to monitor these requests and insist that our recommendations, if not included in the airworthiness criteria, be included in the operational approval.
