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National Agricultural Aviation Association eNewsletter
Voice of the Aerial Application Industry
December 7, 2023
NAAA Submits Comments on Guardian Agriculture Part 137 UAS Operations
This week, NAAA submitted comments on a petition from Kiwi Technologies, Inc. d/b/a Guardian Agriculture to amend their existing exemption to conduct Visual Line of Sight (VLOS) uncrewed aerial application operations incorporating new and broadened operating parameters for its SC1 electric vertical takeoff and landing (eVTOL) uncrewed aircraft system (UAS).
The petition seeks to increase maximum takeoff weight to 645 lbs., increase maximum airspeed to 45 kts., reduce horizontal standoff distances from vehicles/structures and permit operations at night. Further it proposes removal of the requirement for a visual observer (VO) in conducting these amended operations.
NAAA’s comments centered on the safety concern that the UAS presents to crewed operations sharing the same seasonally congested Part 137 airspace. The petitioner states that its flight termination system (FTS) can detect impending encroachment and respond accordingly; NAAA asserts that the FAA should consider crewed aerial application operations, potentially operating in adjacent fields, when assessing the FTS as a means of risk mitigation.
For night operations, the petitioner plans to utilize strobe lighting visible for 3 statute miles. NAAA requested that the equipped strobe lighting be required to be on for all (day and night) operations as an additional means for collision mitigation. 
Finally, NAAA took issue with the petitioner’s statement that their platform offers a “greater degree of precision application than have been previously attainable by farmers through traditional application methods.” Corporate interests are driving this false narrative; continued efforts to highlight the facts are the best tool we have to affect change on the regulatory landscape.
You can view NAAA’s comments 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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