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National Agricultural Aviation Association eNewsletter
Voice of the Aerial Application Industry
July 20, 2023
NAAA Taking Every Opportunity to Press FAA on Safe UAS Integration

NAAA commented against the concept of a single registration number being used for an entire UAS swarm but in favor of the FAA providing an alternative method for standard reregistrations to be applied for in a batch format to relieve unnecessary administrative overhead within the private sector and the FAA itself.

Last week, NAAA submitted comments on two Petitions for Exemption to the Federal Aviation Administration (FAA). These petitions, both from Uncrewed Aircraft System (UAS) light show companies, were seeking relief from portions of the 14 CFR Part 48 requirements for registration and marking of small UAS. The basis for each company’s claim is financial, as they have thousands of UAS in inventory that require individual marking, registration and (every three years) reregistration.

One petition was merely seeking an alternative process to renew all their previously registered/marked UAS at once (think a spreadsheet of registration numbers). The other petition sought to apply for a single registration number for their entire swarm of UAS, though it was not clear how they would achieve this through the specific sections of the CFR they requested exemption from.

NAAA commented against the concept of a single registration number being used for an entire UAS swarm but in favor of the FAA providing an alternative method for standard reregistrations to be applied for in a batch format to relieve unnecessary administrative overhead within both the private sector and the FAA itself. However, NAAA also used these comments as a platform to continue imparting the importance of UAS safety to the FAA. An excerpt, included in both comments, is copied below:
NAAA has a shared goal with the FAA of enhancing aviation safety, not abating it. As incremental changes are continually made with precedent-setting exemptions to 14 CFR regarding UAS, NAAA grows increasingly concerned of the hazard posed for crewed aircraft. Alone, exemptions such as this may not seem significantly impactful. However, put together in the broader context, it appears that the FAA has found itself on a path toward prioritizing the integration of UAS into the NAS over the safety of crewed aviation.

NAAA would like to reiterate to the FAA its position that the safety of crewed aircraft should always be prioritized, and that UAS should always give the right-of-way to crewed aircraft. Regarding beyond visual line-of-sight (BVLOS) operations, NAAA also reiterates to the FAA that detect and avoid (DAA) systems should be certified and that shielded operations, as prescribed by the UAS BVLOS Aviation Rulemaking Committee (ARC), should not be permitted in any environments or under any circumstances. NAAA has continually urged the FAA to prioritize safety regarding these matters, most recently in a 2022 letter regarding the UAS BVLOS ARC Final Report and again in a 2023 comment on Docket FAA-2023-1256 regarding BVLOS operations.
You can view the petitions, as well as NAAA’s comments on them, at 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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Oct. 3-5

2023 RPAAS Workshop (Remotely Piloted Aerial Application Systems)

(In Person + Virtual + On Demand) 

University of California, Davis

Davis, CA


Oct. 5-7

NAAA & NAAREF Board Meetings

Marriott at the University of Dayton (meetings at Dayton Convention Center)

Dayton, OH

Lindsay Barber

(202) 546-5722


Full Calendar of Events




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
NPDES PGP Compliance Tools
Shooting-Response Checklist
NAAA UAV Encounter Checklist
Tower Outreach Tools
Tower Marking Warning Letters
NAAA UAV Safety Stuffers
NAAA Professional Operating Guidelines Booklet
Aerial Applicator’s Manual
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