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National Agricultural Aviation Association eNewsletter
Voice of the Aerial Application Industry
October 26, 2023
NAAA Firm on Safety in the FAA’s Heedless March Toward UAS BVLOS Operations
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. 
View NAAA’s UAS Policy Page to learn more. 
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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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Apply for C-PAASS 2023 by December 11
Beware of Fraudulent Email with Ag Aviation Expo Name & Logo
Support NAAA by Renewing Your Membership for 2024
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Nov. 5-7

PNW AAA Convention

Coeur d’Alene Resort

Coeur d'Alene, ID

Tara Lea Brown

(509) 989-9098


Nov. 7-9

Mid-States Convention

Isle of Capri Casino / Quad Cities Convention Center

Bettendorf, IA

Quentin Childs

(515) 967-3761


Nov. 14-16

Colorado AAA Convention

Island Grove Regional Park 

Greeley, CO

Jessica Freeman

(970) 217-5293


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NAAA Media Kit
Customizable Aerial Application DIY Press Releases
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Shooting-Response Checklist
NAAA UAV Encounter Checklist
Tower Outreach Tools
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NAAA Professional Operating Guidelines Booklet
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