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National Agricultural Aviation Association eNewsletter
Voice of the Aerial Application Industry
June 22, 2023
NAAA Defends Safety of Ag Aviators Against Proposed UAS BVLOS Operations
If adopted, some of the most troubling recommendations from the UAS BVLOS Aviation Rulemaking Committee report may become a reality. Of specific concern to ag aviators, the rule would give UAS the right of way over crewed aircraft in so-called “shielded” areas.
Under pressure from deep-pocketed corporations seeking regulatory relief to operate uncrewed aircraft systems (UAS) beyond visual line-of-sight (BVLOS), the Federal Aviation Administration (FAA) is pushing to expand BVLOS operations.

In what appears to be a tactical move, on May 24, the FAA published four precedence-setting BVLOS Exemption Petitions alongside a broader proposed rule for public comment. If adopted, some of the most troubling recommendations from the UAS BVLOS Aviation Rulemaking Committee (ARC) report released last year may become a reality. Of specific concern to ag aviators, the rule would give UAS the right of way over crewed aircraft in so-called “shielded” areas. In addition, the FAA steamrolled NAAA and nine other crewed aviation groups by denying a joint request in a letter seeking additional time to comment on these five paradigm-shifting proposals (the FAA only allowed 20 days for comment).

The proposed shielded areas, wherein UAS would now have the right of way over crewed aircraft, are defined as “a volume of airspace that includes 100’ above the vertical extent of an obstacle or critical infrastructure and is within 100 feet of the lateral extent of the same obstacle or critical infrastructure.” The ARC contends that these shielded operations should be permitted based on “the limited likelihood of crewed aircraft operations in [these] areas.” Agricultural aviators were clearly not considered in this assessment, as this would place UAS squarely into what are already the most statistically dangerous areas in and around an applications site, such as around electric infrastructure.

The FAA, it seems, plans to lean heavily on the required use of Detect & Avoid (DAA) systems to mitigate the risk of the proposed UAS BVLOS operations. Each of the four exemption petitions submitted planned to employ radically different DAA techniques, but none provided public evidence of their efficacy. The FAA is seeking to employ a combination of industry standards to approve or disapprove DAA systems in exemption petitions; however, it is unclear whether the agency will actually verify a petitioner’s claimed DAA performance. Moreover, NAAA is unaware of any DAA system that has been tested against the unique nature of aerial applications.

NAAA commented in opposition to all four exemption petitions as well as the proposed rule on BVLOS expansion and shielded operations. We will continue to beat the drum of the necessity to have UAS certified as airworthy and that UAS must always give the right of way to crewed aircraft. In addition, we will assert that DAA systems must be certified by the FAA and be performant against aerial application operations. As the momentum behind UAS integration into the national airspace pushes regulation forward, the safety of the humans working in that airspace cannot be set aside.

You can view the above-mentioned dockets (and NAAA comments) using the links below:
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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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Ag Aviation Expo Hotel Info
NAAA Award Nomination Form
GPS Data Collection Project to Protect Ag Aircraft from Drones
Certified-Professional Aerial Applicator Safety Steward
(C-PAASS) Program

DropFlight App Makes Spray Pattern Testing a Snap
2023 NAAA “Ag Wings of Tomorrow” Scholarship
2023 Charles Stokes Memorial Turbine Training Scholarship
Agriculture’s Air Force Book
100th Anniversary Press Room
Aerial Applicators’ Growing Role Video Download Files
Agricultural Aviation Mag.
NAAA/NAAREF Safety Videos
Turn Smart: Respect the Safety Margin Video
NAAA Media Relations Kit
Customizable Aerial Application DIY Press Releases
Shooting-Response Checklist
NAAA UAV Encounter Checklist
Tower Outreach Tools
Tower Marking Warning Letters
NAAA UAV Safety Stuffers
Ag Aviation 101 Presentation
NAAA Professional Operating Guidelines Booklet
Aerial Applicator’s Manual
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National Agricultural Aviation Association, 1440 Duke Street, Alexandria, VA 22314
Phone: 202-546-5722 | Fax: 202-546-5726 |

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