NAAA eNewsletter

January 23, 2020

NAAA eNewsletter

NAAA Requests EPA Verify Precision, Safety and Efficacy of Applications Made by Drones

Last week NAAA submitted a letter to EPA Administrator Andrew Wheeler. The purpose of the letter was to urge the EPA to promptly evaluate UAS’ ability to make safe and precise and efficacious applications of pesticides, similarly to how other forms of application—ground, air-blast and single rotor and single propellered manned aircraft—were evaluated and tested in each pesticide active ingredient evaluation. UAS, in some instances, are now being used for making small-scale aerial applications, yet without being tested and modeled to determine drift potential.

Manned agricultural aircraft, along with ground rigs and airblast sprayers, have all been evaluated in extensive field studies, many as part of the Spray Drift Task Force project, and the data collected is used in the AgDRIFT model. For aerial application, the model allows for a variety of variables to be examined, including aircraft properties, boom and nozzle configuration, and wind speed. While EPA typically uses the Tier 1 assumptions when running AgDRIFT, which uses an AT-401 with specific setup parameters, they do have the ability to change variables and explore alternatives. As an example, AgDRIFT was used to verify reducing boom length reduces drift. This helped secure 15 mph wind speed limits for many pesticides during their registration review process.

AgDRIFT is used in the pesticide registration and registration review processes to model the amount of drift from aerial and other forms of applications. The estimated amounts of drift are then used in the human health and ecological risk assessments. In turn, these risk assessments are used to determine if a pesticide will be approved, what application methods can be used to apply it, and what restrictions need to be placed on the label. NAAA pointed out that because no UAS are currently modeled in AgDRIFT, it is currently impossible to evaluate the risk from making an aerial application with a UAS. Without proper risk assessments, it is impossible to know how safely and accurately aerial applications with UAS are.

Many consider UAS to be an aerial application and thus already an approved application platform for any pesticide with an aerial label. However, NAAA pointed out in the letter to Administrator Wheeler that there are considerable differences between UAS and manned agricultural aircraft. One critical difference is weight. Most UAS being marketed for making aerial applications are much lighter than manned agricultural aircraft. Weight affects the strength of an aircraft’s wake, which is what pushes the spray down and out from the aircraft and into the plant canopy. Lighter aircraft do not have as strong of wakes, which will affect their efficacy and drift potential.

Another key difference between most UAS and manned aircraft are the number of rotors used. While helicopters utilize a single rotor, UAS commonly have multiple rotors which is expected to have a significant impact on vortices generated by the aircraft. In terms of current label restrictions about boom length relative to wingspan or rotor diameter, there is no data if these restrictions are appropriate for multi-rotor UAS. NAAA verified the uncertainty surrounding the accuracy of UAS applications with current research published in the Transactions of the ASABE (American Society of Agricultural and Biological Engineers).

NAAA pointed out several other differences, including that the UAS certification process is not nearly as rigorous and UAS pilots do not have to have a commercial pilot’s license. PAASS and Operation S.A.F.E. were described in the letter to demonstrate to the EPA the dedication and professionalism of the agricultural aviation industry. NAAA also reminded Administrator Wheeler that Canada’s Pest Management Regulatory Agency (PMRA) has already determined that the use of UAS to apply pesticides is not permitted until UAS testing has been completed.

NAAA urged the EPA to begin the field trials for UAS evaluation so that UAS can be added to AgDRIFT. This is essential for ensuring that risk assessments accurately reflect the drift potential of UAS, and that label language can be written specifically for UAS. NAAA will continue to push for a safe and legal process for UAS to enter the aerial application industry. UAS may allow for more acres to be treated by air efficaciously and safely but the data must be generated first so that a proper risk assessment can be developed for its legal use. A copy of NAAA’s letter to the EPA can be viewed here.

Fixed-Wing Spray Drone Startup Receives $11 Million in Seed Money

A fixed-wing drone manufacturer has received a sizable capital investment to help fund its efforts to bring an unmanned electric airplane designed for agricultural spray operations to market. Pyka, an unmanned electric airplane design, development and services company in Oakland, California, received $11 million in venture capital funding, DroneDJ reports.

Pyka’s product is a fixed-wing electric aircraft for agricultural spray operations. It is designed for row crops and applications near sensitive crops or areas. The P-400b Egret has a wingspan of 34 feet and a 450-pound payload capacity. Lithium polymer battery packs power three 20 kw electric motors. Pyka’s spray system includes a proprietary, high-speed centrifugal pump. The pump delivers chemical to a pair of lightweight carbon composite spray booms. According to the company, the autonomous airplane is capable of spraying 135 acres an hour at a rate of 2 gallons per acre (gpa) or 85 acres an hour at 5 gpa.

Pyka has been testing its unmanned aircraft in New Zealand under a certification program with the Civil Aviation Authority of New Zealand. The company is also in discussion with the USDA-ARS Aerial Application Technology Research Unit about setting up a spray categorization and drift study in the U.S. Results on the application efficacy and precision of Pyka’s autonomous airplane will be interesting to see once testing data becomes available.

Pyka states its autonomous airplane is able to identify and avoid obstacles within its flight path by using 3D aerial mapping and optimized path planning. Pyka also recently joined NAAA as an allied member.

Pictured above: Rear view of Pyka’s P-400b Egret (courtesy of Pyka)

NAAA Starts 2020 Pesticide Reregistration Efforts with Nine Comments to EPA

Last Friday NAAA submitted nine comments to the EPA for the agency’s re-registration review of pesticide active ingredients. The EPA is required by FIFRA to review the registrations for all crop protection products every 15 years to ensure dietary, water, environmental, occupational and endangered/threatened species safety. The active ingredients that NAAA commented on were for the following products: Boscalid, Fenpyroximate, Flonicamid, Mandipropamid, Metolachlor/S-Metolachlor, Myclobutanil, Propanil, Terbacil, and Triclopyr. The documents that EPA had submitted for comment were all risk assessments, conducted for each active ingredient to assess the risk to the environment and human health of the products being evaluated.

In all of the comments NAAA stated that the usage of the Tier 1 model in AgDRIFT for conducting the risk assessments is not an accurate representation of how modern aerial applications are conducted. The faulty assumptions used in the model include a small droplet size, a non-dropped boom, a short swath offset, near-inversion conditions, and spraying over a bare surface. All of these assumptions result in a higher than realistic risk of drift assessment for aerial applications and are not the conditions that exist when aerial applications are made. NAAA provided more realistic assumptions and sources of data to back up those assumptions. While the risk assessments for three of the products did examine the impact of using a larger droplet size, they still had all of the other faulty assumptions.

For Boscalid, the ecological risk assessment stated that some of the labels with this active ingredient required a 100-foot buffer near water. NAAA commented that all buffer zones should only be required on the downwind side of the application and provided scientific evidence and currently approved labels to back up this argument. The comments also pointed out that if the EPA would use more realistic assumptions in AgDRIFT, the distance required for the buffer zone would be less than 100 feet.

The human health risk assessments for Myclobutanil found risks of concerns for flaggers and pilots when making applications of the dust formation. The EPA did not have direct exposure data for either pilots or flaggers for dust formulations, so they adjusted data for using a hand shaker can to apply dust. For the risk to flaggers, NAAA pointed out that 99 percent of aerial applicators use GPS for swath guidance, and that flagging is rarely used. In terms of the risk to pilots, NAAA commented that even when exposure estimates from a shaker can are adjusted, it is highly unlikely they accurately reflect the exposure to a pilot from inside a cockpit.

For Propanil, a herbicide used on rice, the ecological risk assessment found a risk of concern for chronic exposure to bees, both on the field and off the field. The risk assessment clearly states that bees are not attracted to rice, so NAAA questioned that there could be an on-field chronic exposure risk if bees were not likely to be in rice. For the off-field chronic exposure risk, a result of estimated drift, NAAA pointed out that the drift estimates were based on the inaccurate assumptions used in AgDRIFT.

In 2019, NAAA commented on registration review documents for 72 pesticide active ingredients. NAAA will continue to monitor the pesticide registration review process in 2020 and beyond for both risk assessments and interim decisions and comment accordingly to the EPA. We will fight to make sure aerial applicators have access to the pesticides their customers need in order to control insects, diseases, weeds, and other pests.

It’s that Time Again: Renew Your Membership Today!

Renewals are now open! You can renew online today. As a member of NAAA, you associate with the best and brightest in the agricultural aviation industry and your support is imperative in helping us accomplish our initiatives. We’d like to remind you of just a few new offerings NAAA has recently released such as:

NAAA is now offering legal services on Federal Transportation Laws to Operator and Pilot Members
Receive the 2019 NAAA Operator and Pilot Survey Report which is chockful of key statistics providing a healthy status of the U.S. aerial application industry.
Be listed in an receive the NAAA Membership Directory. It’s your one-stop shop where you can find members and allied services in the industry.
Stay up-to-date on the latest issues affecting your profession through the NAAA eNewsletter, Agricultural Aviation magazine and exclusive member resources online such as our Media Relations Kit.
Don’t forget to take advantage of financial incentives such as our Operation S.A.F.E. Rebate Program and our Recruitment Rewards Program.

NAAA is dedicated to protecting and advancing the needs of the industry by improving the public's perception of the aerial application industry and spearheading the industry's environmental stewardship and safety initiatives. If you haven’t reviewed all our accomplishments this past year in the 2019 NAAA Membership Directory, you can download our Annual Report here.

We appreciate your membership as it will help us continue to fight and win on important issues like unfair user fees and taxes; tower marking requirements; integration of drones into the national airspace; and ensuring EPA keeps a healthy inventory of crop protection products for aerial use without restrictions. Your membership helps us better represent your interests; renew your membership today!

Update Your Information by Tomorrow for the 2020 Membership Directory!

Have you moved or changed employers since you renewed your 2020 NAAA membership? Allied companies, have you reviewed your company description lately? Ensure your listing in the 2020 NAAA Membership Directory is correct today by logging into your account. If any information has changed, please let us know right away. You can provide your information by:

Updating your information online at AgAviation.org. Log in using your username and password and update your information under My Profile;
Responding to the letter or email that you will receive soon;
Emailing your changes to information@agaviation.org;
Faxing your changes to (202) 546-5726; or
Calling the NAAA office at (202) 546-5722.

We must have your updated information by January 24, 2020 to guarantee accurate inclusion in the 2020 NAAA Membership Directory!

NAAHOF Accepting Nominations for 2021 Induction into Hall of Fame

The National Agricultural Aviation Hall of Fame (NAAHOF) Nomination Board has changed its procedure for evaluating candidates for induction into the NAA Hall of Fame. Under the policy change, the Nominations Board will consider individuals one year before their induction to allow more time to deliberate on NAAHOF nominees’ credentials. NAAHOF has updated its nomination form accordingly and is accepting nominations for people who would be inducted in 2021. Nominations to be considered for induction into NAAHOF in 2021 are by due Sept. 1, 2020. The 2021 NAAHOF Candidate Nomination Form is available here.

The National Agricultural Aviation Hall of Fame is located in the National Agricultural Aviation (NAA) Museum in Jackson, Mississippi. The purpose of the NAA Museum is to educate the general public about the contributions of the agricultural aviation industry. Induction into the NAA Hall of Fame is the highest honor that can be paid to agricultural aviation achievers. The Hall of Fame honors agricultural aviation leaders, pilots, operators, scientists, engineers, inventors and other individuals who have helped promote the agricultural aviation industry with their outstanding contributions.

The National Agricultural Aviation Hall of Fame is not affiliated with NAAA, but new members are inducted at the Excellence in Ag Aviation Banquet at NAAA’s convention. Previous inductees include such industry-shaping individuals as Lt. John A. Macready, Dick Reade, Fred Ayres and Leland Snow. A complete list of enshrined members into the NAA Hall of Fame is available on NAAA’s Industry Links webpage.

Eligibility for NAAHOF Enshrinement

All nominations must be documented. All information that has to do with the reasons/accomplishments of the nominee must accompany the written/typed nomination letter. The utmost attention should be paid to all accomplishments of the nominee.
A nominee must have made a significant contribution to the agricultural aviation industry in the United States. Accomplishments must be national in scope.
Any person currently sitting on this Nominations Board is automatically ineligible for consideration for enshrinement to the NAAHOF until such time as they are no longer an active part of the governing process of this institution.
Any person nominated for enshrinement must not have anything in their past which will reflect in a negative manner upon the agricultural aviation industry.

The NAAHOF Nomination Board is chaired by Brian Rau. NAAHOF nominations may be sent directly to the chairman at:

Brian Rau

4142 57th Avenue SE

Medina, ND 58467

medinaflying@aol.com

For more information, please contact Brian Rau at (701) 486-3414 or medinaflying@aol.com.

Colorado Aerial Applicators Win Major Victory Over Bogus Drift Cases, NAAA and COAAA Attorney Instrumental in Decision

In January 2019, three Colorado aerial applicators made the bold decision to fight alleged drift cases brought against them, knowing the claims had no basis in fact or science. After over a year of litigation, a final court order was issued Wednesday clearing the applicators of all wrongdoing.

Represented by attorney John Wright, applicators could have saved themselves a lot of time and money by simply paying a $1,000 fine. However, the cases brought against them were clearly a witch-hunt by the Colorado Attorney General’s office.

Prosecutors claimed the applicators did things that were scientifically impossible, such as drifting upwind and having two products mixed in the aircraft (lamda-cyhalothrin and chlorpyrifos) somehow unmix in the air before drifting.

Even more egregious, one case was from 2012 and the other two from 2014. Claims were filed against the applicators at the time and evidence was collected, but the applicators did not know this until years later, long after they could collect meaningful evidence on behalf of themselves. Thankfully meticulous record keeping aided in the claims being dismissed. As a result of this, legislation is being considered in Colorado to ensure applicators are informed of claims against them in a timely manner.

The judges in the decision cited the applicator’s professionalism, specifically noting participation in Operation S.A.F.E. Fly-ins.

John Wright, the attorney who represented the three applicators, is contracted with NAAA as part of the association’s legal services program for members. Under the agreement, 2020 operator and pilot members are eligible for a legal consultation of up to one hour on federal aviation laws with Mr. Wright. Mr. Write is a commercial pilot based in Broomfield, CO. You can read more about him here.

The timing of this case couldn’t be better as Colorado’s Democratic majority legislature is undertaking efforts to more forcefully regulate pesticides and from a multitude of different government jurisdictions. The decision in this case is an indication that government oversight was clearly excessive and unfair, thereby questioning the need and reasoning to expand government control.

NAAA and NAAREF Board Meetings Feb. 13-15

We look forward to seeing you Feb. 13‒15 at the NAAA and NAAREF Board Meetings. All meetings are open to NAAA members. The Westin Alexandria will host our February board meetings. Click here for a schedule of events.

Westin Old Town Alexandria

Address: 400 Courthouse Square, Alexandria, VA 22314

Rate: $153/night plus tax

Reservations: Book your room online here.

Room Block closed Jan. 13, 2020: Room rates will be higher after block closes and we cannot guarantee rooms after this date.

The Westin Alexandria is a three-block walk from the King Street Metro stop (take either Blue or Yellow Line), which is the second stop south of Ronald Reagan National Airport (DCA). You can view a map of the metro system here.

Get Political at NAAA Spring Board Meeting! Support Candidates Championing Ag Aviation and Visit with Policymakers on Issues of Importance

In addition to the normal committee meetings and planning sessions that take place at NAAA Board of Directors Meetings, the spring board meeting is held every year in the Washington D.C., area, giving attendees an opportunity to speak directly with their legislators and national policymakers. Additionally, NAAA also hosts an annual fundraising breakfast for the NAAA AgAv PAC. Get the most of out of your visit to Washington, D.C., by taking advantage of both these opportunities!

AgAv PAC Breakfast

The annual breakfast will be held on Friday, February 14 from 7:30-8:45 a.m. at the Westin Alexandria, the same hotel as the board meeting. NAAA is excited to have our guest speaker this year be United States Senator Steve Daines (R-MT).

Senator Daines currently serves on several important Senate committees including the Committee on Energy and Natural Resources and the Committee on Appropriations. As such, he plays an important role in aerial application technology research funding and regulatory issues related to the Endangered Species Act.

To RSVP, please respond via email to: ftaylor@agaviation.org with your name or the names of people attending in your party before Friday, February 7.

Tickets for the AgAv PAC breakfast are $100.00 per person. Payments may be made at the event via cash, a personal check, or credit card.

The AgAv PAC was created to help elect candidates who know the critical importance aerial applicators play in the quick, safe and efficient production of food, fiber and biofuel. Please consider a donation to the AgAv PAC as an investment in both your business and the aerial application industry as a whole, as our successes in Washington D.C. directly correlates to monies you save in the field. Our previous victories have saved individual operators thousands in user fees taxes and in curbing unnecessary regulations each year, and collectively saves the industry millions. It has also led to protecting the industry’s safety.

If you are unable to attend the PAC Breakfast but would still like to make a contribution, you can send a personal check to:

AgAv PAC

1440 Duke Street

Alexandria, VA 22314

Meet with your Legislators!

To meet with your legislators to solicit their support on issues that are important to the agricultural aviation industry, you may call the Capitol Switchboard at 202-224-3121 and ask to be connected to their offices. If you are uncertain who your Representatives and/or Senators are, you may identify them at www.house.gov and www.senate.gov, respectively. NAAA staff are also available to make congressional appointments for you; simply email us or call (202-546-5722) for assistance. Please provide your business and residential addresses as that will be requested from congressional offices.

Meeting with members of Congress and/or congressional staff is extremely effective in conveying the importance of the issues affecting our industry. NAAA will make available issue briefs summarizing the issues most important to NAAA shortly. If you are unsure of what issues your legislators have the most influence over, NAAA staff are also available to help you make the most of your meetings by strategizing with you on what issues are best to talk about in each meeting.

If you know there will be other people from our ag aviation delegation having meetings around the same time as you, we highly recommend you consider combining groups. By having more ag aviation industry individuals attend these meetings, it sends a signal to your legislators that our industry is highly engaged on these issues. If you are unsure who else from our ag aviation delegation plans to have meetings but want to welcome more people to your group, email us and also be sure to provide us your meeting schedule for the day. Additionally, if you would like to join a group, email Frank with your business and residential addresses and he will let you know if any groups are available to join.

Winter 2020 Issue of Agricultural Aviation Now Online!

The latest issue of Agricultural Aviation magazine is now online in two different formats: a Replica format for desktop reading and a Mobile-optimized format for easy reading on your phone. This first issue of the new decade includes a message from 2020 NAAA Darin Pluhar, 2020 NAAA officer profiles, a recap of the 2019 ag aviation economy, a summary of the 2019 Ag Aviation Expo in Orlando, Profiles of NAAA award winners, and much more!

Click below to jump directly to some of the stories in this issue:

How to get the Most from your Digital Edition

Contents button: The Contents button hides or displays the table of contents. Scroll through it to jump to the articles that interest you the most.

Reading/Page View: Smartphone readers, this feature is for you! Click on the Page View and Reading View (or Text) buttons to toggle between replica and mobile-optimized versions of an article.

Share: Click the Share button to share articles with friends and associates on Facebook, Twitter, and via email.

Improved Search: NAAA's digital edition now features additional search functionality. In Page View and Reading View, search will display two options: an easy-to-use search within the issue, and an option for a more in-depth search of all issues.

You can also access Agricultural Aviation's library of back issues by clicking the Issue Library button.

Don’t PAASS Up Safety and Have and Accident: Attend the 2019-2020 PAASS Program

The 2019-2020 PAAAS Program is ready to help you and the agricultural aviation industry improve safety, application accuracy and professionalism. The following four modules will be given at state and regional agricultural aviation association meetings this fall and winter. Check the NAAA calendar and make sure you plan on attending. The core mission of PAASS is to reduce both ag aviation accidents and drift incidents, and PAASS has proven successful at this task. Accidents have been reduced by 23% since PAASS began. Studies conducted by the American Association of Pest Control Officials show a reduction in drift claims of nearly 26 percent since PAASS started. Many state departments of agriculture offer CEUs for PAASS attendance and many insurance providers offer discounts to PAASS attendees.

Agricultural Aviation’s Airfield Watch

For this year’s Airfield Watch module, an operator will describe a break-in that occurred at his facility. He will review how the perpetrators attempted to gain access to his buildings and equipment in an attempt to steal fuel. He also describes what he’s done since the incident in order to better secure his operation. This has included increasing the security lighting with motion detectors around the buildings with plans to install security cameras at the facility. It is critical to protect agricultural aviation operations from a variety of threats, including vandalism, theft, and the unlikely possibility of terrorist activity.

Human Factors in Agricultural Aviation – “Controlled Flight Into Terrain Accidents”

Controlled Flight Into Terrain, or CFIT, accidents continue to be a concern for agricultural aviation. Over the last 10 years, CFIT accidents have accounted for 29% of all agricultural aviation accidents. During this same time period, 49% of fatal Part 137 accidents have been CFIT accidents. In 2018, a staggering 75% of fatal accidents involved CFIT. CFIT accidents include collisions with the ground, wires, towers, and trees. Participants will hear from several pilots about their CFIT accidents and factors that led to the accident. These included failure to properly scout a field, allowing the pressures of running an operation to cause distraction, and trying to sometimes impress an employer or someone else but perhaps taking on additional risk. CFIT accidents obviously present a dangerous threat to pilots but can also cause harm to the environment as well with the accident potentially resulting in a pesticide spill. Participants will have the opportunity to discuss how to scout fields for obstacles and maintain vigilance throughout the application in order to avoid a CFIT accident.

Environmental Professionalism – “Operation S.A.F.E. Prep Work and Boom Update”

Operation S.A.F.E. fly-in clinics offer aerial applicators the opportunity to have their aircraft’s spray pattern and droplet size evaluated by a trained professional. Many S.A.F.E. fly-ins are quite busy, with multiple aircraft participating. In order to get the most out of attending a fly-in, it is important to prepare your aircraft ahead of time. The Environmental Professionalism module will discuss aircraft preparation, including checking for leaks and aligning nozzles, whether participating in an Operation S.A.F.E. or analyzing your system yourself. The module will also provide an update on using a shortened boom to reduce drift and the impact of belly nozzles on spray pattern quality.

Hangar AG Flying – “Accident Review, Landing with a Load, and other Topics”

This module will include an analysis of ag accidents that occurred during the 2019 application season. Studying these accidents enables attendees to learn from other pilots’ experiences and increase flying safety. A segment on how to land with a load will review how to accomplish this task as well as how to train for it. Also covered will be an update on FieldWatch and discussion on the risks of pesticides.