On Monday, NAAA submitted comments to the Federal Aviation Administration (FAA) regarding a recently published petition by
Wing Aviation LLC (Wing) to amend its
existing exemption to conduct 14 CFR Part 135 package delivery operations using an uncrewed aircraft system (UAS). Wing is a subsidiary of Alphabet, Inc., the parent company of Google. Wing is focused on expanding global drone delivery networks to bring residential drone delivery to major metro areas. Wing received their
initial exemption in 2019, for which
NAAA commented in opposition (
also see our eNews archive). Wing has since been granted several amendments to their exemption. Their
most recent petition details proposed use of ADS–B for primary detect and avoid (DAA) during beyond visual line-of-sight (BVLOS) operations without visual observers (VOs).
NAAA’s comments provided a detailed and data-driven overview of the aerial application industry, its significant impact on the agricultural economy and the unique challenges faced by its operators. More specifically, NAAA outlined the mid-air collision risk imposed by UAS operating BVLOS without vetted and FAA-certified DAA technology. Wing’s proposal to utilize ADS-B as their primary DAA system would necessarily allow them to operate BVLOS without a primary means to detect and avoid any non-ADS-B-Out aircraft. While NAAA continues to advocate for DAA technology equipage for all UAS, it must be proven (and FAA-certified) effective against cooperative (ADS-B Out) and noncooperative (Non-ADS-B Out) aircraft.
In their petition, Wing clarified that they were not seeking any relief to
14 CFR §91.113 Right-of-way rules. However, it is the opinion of NAAA that their proposed removal of VOs for BVLOS operations, without additional demonstrable risk mitigations, would impede their ability to maintain vigilance, in accordance with §91.113(b), to see and avoid other aircraft. For this reason and those outlined above, NAAA urged FAA to prioritize safety and not grant the petitioned amendments.
