NAAA’s comments opposed the CPA’s requests for exemptions dealing with airworthiness, safe altitudes, fuel requirements and maintenance and reiterated that the requirements for heavy drones outside of FAR Part 107 should be identical to those of manned aircraft. NAAA also commented on unsubstantiated and inaccurate claims made in a document prepared for CPA by UASolutions Group LLC as to the purported advantages of unmanned applications over manned applications. As one of the risk mitigations that CPA is promoting is that the operations will occur “under controlled conditions in predetermined airspace that is, 1) Limited in scope 2) Controlled as to access by mission essential personnel only.” NAAA reminded the FAA that the national airspace (NAS) is not private, and access is not controlled by private entities. Short of temporary flight restrictions (TFR), the NAS is accessible to aircraft such as manned agricultural aircraft to do their jobs properly. Other claims made and NAAA’s response are:

Central Plains Agronomy’s claim that their drones “reduced exposure to chemicals for applicators” was met with the NAAA response that there is a far greater likelihood due to the small hopper size and exponentially more times a worker will have to refill a small drone that it will result in greater exposure to chemicals for those workers. The drone will most likely be refilled at a temporary site in or near the field, where the lack of closed-contained facilities will make decontamination difficult.

Central Plains Agronomy’s claim that their drones’ “reduction in chemical drift compared to manned aircraft application and reduced exposure of surrounding beneficial vegetation” was met with the NAAA response that the claims were completely unproven and that drift from drones has not been adequately studied. Further, there are many factors that indicate drift from a drone will be equal to or greater than from manned aircraft. Drones are light and do not have the weight necessary to bring the product down to the crop canopy. The multi-rotor design appears to send the spray in many different directions, and to get a decent spray pattern requires drones to apply at about 10 to 12 feet above the crop canopy, which is the same height as manned aircraft.

Central Plains Agronomy’s claim that their drones result in a “more environmentally friendly application with reduced noise” was met with the NAAA response that while the decibels may be lower, the time spent in the area will be substantially longer due to a drone’s low productivity, causing the acoustic imprint to remain. One of the most promising developing uses for drones is hazing (harassing) blackbirds in sunflower fields to prevent depredation. Such a use would require constant activity in the blackbird invaded area with the constant audible whining of the drone. Unlike the [CPA] claims made, drones are not environmentally benign either audibly, to the physical land or to human exposure.

Central Plains Agronomy’s claim that their drones result in a more “selective use of chemicals for a safer more targeted application, and better value for the customer” was met with the NAAA response that there is no difference in the selectivity in the use of chemicals between unmanned and manned aircraft. The operators of manned aircraft are constantly looking for the best value for the customer. Manned aircraft can and do perform variable rate and selective applications when it is of value to the customer.

View the request for relief, submit your own comments or view NAAA’s comments here. Comments are due by April 21.