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National Agricultural Aviation Association eNewsletter
Voice of the Aerial Application Industry
May 5, 2022
NAAA Submits Augmented Tower Marking Proposal to Congressional Transportation Committees as 2023 FAA Reauthorization Process Begins

The number of wind energy, meteorological evaluation and communication towers is expected to grow significantly in the next decade and beyond, exacerbating the risks for aerial applicators, which is why towers that fit certain physical and dimension specifications, regardless of their use, must be both marked and logged.

Earlier this spring, the two congressional transportation committees requested legislative proposals directly from NAAA for the upcoming 2023 FAA Reauthorization. The FAA functions under a five-year congressional reauthorization that provides the agency with a host of new authorities and responsibilities on a broad range of aviation issues. Congress last authorized it in 2018 through 2023.

This week NAAA submitted a proposal for the upcoming reauthorization that would strengthen a tower marking statute that it successfully had included in the 2018 bill by requiring all towers between 50 and 200 feet in rural areas meeting certain physical standards to be marked and logged into an FAA database. Already staff for the chair and ranking members of the House Transportation & Infrastructure Committee and ranking member staff of the Senate Commerce Science & Transportation Committee have acknowledged receipt and appreciation of NAAA’s proposal.

Unfortunately, due to pressure from the Goliath communications industry, language was added to the 2018 reauthorization bill that allowed communications towers to only be marked or logged, but not both, while all other towers would be required to both mark and log—even if they had identical physical characteristics and dimensions.

NAAA informed the two transportation committees in its letter this week about the importance of the aerial application industry—that it treats approximately one-third of our nation’s commercial cropland (127 million acres of a total of roughly 347 million acres); that it is the most economical method for timely pesticide applications to be made due to its speed and ability to treat rolling hills and wet land that terrestrial equipment is unable to work; and that the industry’s value to farmers, input suppliers, processors and agricultural transportation and storage industries for just corn, wheat, cotton, soybeans and rice production in the U.S. is estimated to be about $37 billion annually. NAAA added that aerial application’s importance is expected to grow substantially as food prices increase and food production becomes an issue of growing importance due to the Russian invasion of Ukraine, supply and demand issues, and a growing global population, hence, assuring aerial applicators’ safety is paramount.

NAAA included statistics in its proposal to both committees that due to the industry treating at 120 mph just 10 feet off the ground, from 2008 to 2018, there were 22 agricultural aviation accidents from collisions with METs, communication towers, towers supporting powerlines and wind turbines that resulted in nine fatalities. For all general aviation, there were 40 tower-related accidents and incidents, resulting in 36 fatalities over the same 11-year period. NAAA also mentioned that the National Transportation Safety Board recommended guidance for marking certain towers below 200 feet. These recommendations included creating and maintaining a database for the required registration of certain towers and a requirement to mark and light (where feasible) certain towers.

NAAA also stated that the number of wind energy, meteorological evaluation towers and communication towers to broadcast broadband and the like is expected to grow significantly in the next decade and beyond. In 2000 there were 60,000 towers for wireless communication in the U.S. Today there are 150,000 such towers; by 2025, 200,000 are expected. Renewable energy policies in the early 2000s led to extensive growth of wind turbines and METs being erected in rural areas, causing more and more accidents for low-altitude ag aircraft. Furthermore, last year’s infrastructure law funds a huge expansion for rural broadband. NAAA concluded that this exacerbates the risks for aerial applicators and towers that fit certain physical and dimension specifications, regardless of their use, must be both marked and logged.

To read NAAA’s legislative proposal letter to the Senate, click here. To read NAAA’s legislative proposal letter to the House, click 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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