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National Agricultural Aviation Association eNewsletter
Voice of the Aerial Application Industry
July 20, 2023
NAAA Responds to FAA Part 137 Certification Changes for UAS, Highlighting Safety and Competitive Concerns
This week, in coordination with industry stakeholders, NAAA issued a letter to Federal Aviation Administration (FAA) Acting Administrator Polly Trottenberg regarding changes to the Part 137 certification process for Uncrewed Aircraft Systems (UAS) operators outlined in FAA Notice 8900.659. This notice was issued June 13 and was summarized in the June 22, 2023 NAAA eNewsletter.

In the letter, NAAA addressed the changes and expressed concern over FAA policy that may impact the safety of its crewed ag aircraft pilots who share this airspace and competitive concerns favoring new UAS businesses entering the aerial application industry over veteran crewed and UAS aircraft businesses.

The notice relaxes the requirement for FAA-administered § 137.19(e) Knowledge and Skills tests, allowing for new UAS applicants to self-administer the test. It also completely relieves the FAA of any required regular surveillance for UAS operators. The FAA justified these changes by deeming UAS operations as “lower risk” than other operations. NAAA pressed for clarity on how this risk assessment was made and to whom the “lower risk” is in reference. Citing specific NTSB accident reports, NAAA asserted that crewed Part 137 operators and pilots are a clear risk bearer of uncrewed Part 137 operations. Further, the unique nature of already busy airspace in agricultural areas during key application windows heightens the need for UAS operators entering this airspace to have rigorous FAA-verified competency to safely operate there.

The notice details a new streamlined process for Part 137 UAS applicants to receive their operating certificate through a central office via email. NAAA expressed concern that this separate centralized approach for UAS may prove to further alienate crewed and uncrewed Part 137 operators, as they would deal with distinctly different FAA officials and oversight, even if treating adjacent fields. NAAA stressed that as airspace becomes concentrated with interacting crewed and uncrewed Part 137 operations, FAA safety coordination becomes more and more important.

There were also distinctly positive changes in the notice, in which NAAA commended the FAA. A minimum of a third-class medical will be required for UAS operators, something NAAA has pushed for across all commercial UAS operations for years. UAS operators will also have a new requirement to generate operations manuals and training programs. Regarding the shift to a UAS central office, it is hoped that the relief FSDOs will get through these changes will subsequently expedite processing for crewed and mixed (crewed/uncrewed) Part 137 applicants.

NAAA will report updates on this matter, including the associated update of Advisory Circular (AC) 137-1, when it is made available.

You can read the letter in its entirety 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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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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National Agricultural Aviation Association, 1440 Duke Street, Alexandria, VA 22314
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