On Nov. 25, NAAA submitted a letter to FAA Administrator Billy Nolen registering serious concerns about the sharp uptick in Part 107.31 waivers issued for unmanned aircraft (UA) to operate beyond visual line of sight (BVLOS). Many of these waivers permit BVLOS operations where the remote pilot in command (RPIC) or the visual observer (VO) can monitor the surrounding airspace of the UA in flight but cannot see the UA itself.
In a recent two-month span, from Sept. 1 to Nov. 3, there were 16 such waivers issued, while only 17 were issued the entire year in 2020. This represents a substantial increase in BVLOS waivers without any required detect-and-avoid technology.
In the letter, NAAA asserts that the provisions of these waivers compromise the safety of manned aviation in low-altitude airspace. Put plainly, if an RPIC or VO cannot see the UA due to terrain, structures or general visibility problems, they may not be able to see low-flying agricultural aircraft. Supporting evidence for this was cited from the Mississippi State University’s Raspet Flight Research Laboratory, explaining that an agricultural aircraft making application passes and turns (at a combined average of 38 feet AGL) may escape the notice of an RPIC or VO scanning for traffic.
Most of these waivers also include a requirement for high-visibility painting and/or strobes to increase visibility. However, if these measures were adequate, it would not be necessary to issue the waiver in the first place, as the UA could be seen by its own RPIC and/or VO.
NAAA concluded the letter by reiterating the need to suspend the issuance of Part 107.31 waivers until adequate traffic management systems, such as detect-and-avoid technologies, are developed and approved. Allowing BVLOS operations without these technologies poses a significant safety threat to the agricultural aviation industry and all other manned aviation operating in low-altitude airspace. You can read the full letter here.