NAAA recently commented on a Petition for Exemption to the Federal Aviation Administration (FAA). The petitioner, Amazon Prime Air, is seeking to amend its existing exemptions (18601B and 18602B) to utilize their proprietary detect and avoid (DAA) system in lieu of visual observers (VOs) to conduct beyond visual line of sight (BVLOS) Part 135 package delivery operations with their MK27-2 uncrewed aircraft system (UAS). 

 

The petitioner claims that their DAA system “provides equivalent levels of safety to those required by the see‐and‐avoid provisions in 14 CFR § 91.113 and significantly enhances safety by exceeding the average expected human visual performance of the operator in command (OIC) and [VOs].”  

 

As in other recent comments, NAAA reminded the FAA of the unique nature and concerns of crewed Part 137 operations, including the safety threat of aircraft flying BVLOS. Regarding this petition specifically, NAAA questioned whether the proprietary DAA system was tested to perform in the vicinity of aerial applicators. While NAAA supports the adoption and implementation of DAA technology, the Association maintains that unbiased, transparent FAA certification of any such technology is the only way to ensure a safe national airspace for all crewed operations.