NAAA eNewsletter

March 5, 2020

NAAA eNewsletter

NAAA Submits Comments on UAS Tracking and ID Requirements

This week NAAA submitted comments to the FAA on the agency’s long-awaited proposed rule on the tracking and identification of UAS. With nearly 1.5 million UAS and 155,000 remote pilots registered with the FAA, UAS tracking and ID is widely viewed as the lynchpin for enforcing all other UAS related rules. The proposed rule received over 52,000 comments from various stakeholders.

NAAA’s comments were largely in support of the proposed rule, with a heavy emphasis on supporting the requirement that all UAS weighing over 0.55 lbs. must be subject to tracking and ID requirements. NAAA explained it is extremely difficult for manned aircraft to see UAS, and particularly difficult for agricultural aviators conducting operations 10 feet off the ground at speeds up to 140 mph with high cockpit workloads. Additionally, NAAA explained birds weighing as little as 1 to 2 pounds can severely damage aircraft. Studies have shown UAVs of similar size cause much more damage because they are made of denser materials such as plastic and batteries, while birds are made of feathers, hollow bones, sinew and soft tissue.

A weight-based threshold is welcome news, as NAAA was one of 10 members of the 2017 Unmanned Aircraft Systems Identification and Tracking Aviation Rulemaking Committee (UAS ID and Tracking ARC) to dissent from the ARC’s final report. In a dissenting letter, NAAA explained why lacking a weight-based threshold for compliance with the rules could “greatly undermine the value, benefits and utility of UAS ID and Tracking – not to mention, jeopardize the safety of the airspace and comprehensiveness of any future [unmanned traffic management system].”

A UAS not equipped with remote ID would only be allowed to fly in "FAA-recognized" areas and would have to stay within visual line of sight. NAAA commented it is essential these designated areas are located where there is absolutely no low altitude manned aircraft activity. This includes public and private airports, helipads (including hospitals with helipads) as well as around rural agricultural plots of land where manned ag aircraft typically operate. NAAA wrote appropriate areas include parks near residential neighborhoods or other areas where a manned aircraft would never be authorized.

The proposal would not allow any non-compliant UAS to be manufactured in the U.S. within two years of the effective date of the rule, and within three years all UAS operating in the national airspace would have to meet the rule requirements. NAAA commented that it implementing the rule should occur sooner than the three years FAA plans to begin implementing the tracking and ID rules due to the extreme likelihood of additional accidents between UAS and manned aircraft as the number of UAS flown will markedly increase.

You can read a summery of the proposed tracking and ID requirements here.

Click Image to Enlarge

Image Source: FAA

You can read NAAA’s comments here and also browse the over 52,000 other public comments submitted to the FAA here.

NAAA Submits Comments for Three Triazines

On Monday NAAA submitted comments to the EPA on the proposed interim decisions of three active ingredients in the Triazine family: Atrazine, Propazine, and Simazine. The EPA is required by FIFRA to review the registrations for all crop protection products every 15 years. Interim decisions are being used by the EPA instead of a full re-registration of a product because Endangered Species Act and pollinator protection assessments still need to be completed for most products.

For Atrazine and Propazine, the proposed drift mitigation for aerial applications to be put on the labels containing these active ingredients were largely acceptable. Similar to many recent proposed interim decisions, the label would set the limit on wind speed to 15 mph with the additional requirement for applying in wind speeds of 11 to 15 mph being that the boom length be reduced to a maximum 65 percent of wingspan for fixed wing aircraft and a maximum of 75 percent of rotor diameter for helicopters. For applications at wind speeds of 10 mph or lower, maximum boom length would be 75 percent of wingspan for fixed wing aircraft or 90 percent of rotor diameter for helicopters. Swath displacement will be ½ swath on the downwind edge of the field when winds are 10 mph or less, and ¾ swath on the downwind edge of the field when wind speeds are between 11-15 mph.

For Atrazine, the proposed interim decision recommends restricting aerial applications to only the liquid formulations and prohibiting the aerial application of the dry flowable/water dispersible granule (DF/WDG) and water-soluble packet (WSP) formulations. This proposed restriction seems to be largely based on EPA’s estimate for the high number of acres of crops treated daily with an agricultural aircraft. NAAA pointed out that the EPA should not assume exposure risk will increase simply because more acres are treated. If PPE and engineering controls are being used properly, the risk to the handler should be low no matter how many acres are treated. NAAA also pointed out that while it is possible for an agricultural aircraft to easily treat the number acres used by the EPA in their risk assessments, the reality is that the demand for aerial application of Atrazine to many of the crops on which it is applied is much lower. The NAAA used the results from the 2019 industry survey to back this assertion up by documenting the normal acres treated daily by a single aircraft.

Aerial application of Simazine is currently prohibited, and the proposed interim decision continues that prohibition. In reviewing the proposed interim decisions and risk assessments for all of the Triazines, NAAA could find no reason why aerial application of Simazine should be prohibited but allowed for Atrazine and Propazine. NAAA pointed this out in the comments and requested that this prohibition be reversed.

In 2019, NAAA commented on registration review documents for 72 pesticide active ingredients. Just over two months into 2020, NAAA has already commented on 13 pesticides. NAAA will continue to monitor the pesticide registration review process throughout 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.

James Bradley to Speak at Kickoff Breakfast on Dec. 7

Author of Flags of Our Fathers and FLYBOYS,celebrated historian, inspiring storyteller, and New York Times best-selling author James Bradley will speak at the NAAA Ag Aviation Expo Kickoff Breakfast on Monday, Dec. 7 at the Westin Savannah Harbor. September 2, 2020 marks the 75th Commemoration of the End of World War II; a war that took the lives of over 405,000 U.S. military personnel. It is only fitting that we honor those brave men and women on this hallowed anniversary with James Bradley’s words of tribute to the Greatest Generation. Bradley wrote the World War II book—Flags of Our Fathers—about the battle of Iwo Jima which became a worldwide bestseller and a movie produced by Steven Spielberg and directed by Clint Eastwood. As a noted World War II scholar and expert on the war in the Pacific, Bradley's speech is a moving testament to the men and women who do the "impossible" every day.

Bradley’s other Pacific book, FLYBOYS, tells the stories of how nine American flyers-Navy and Marine pilots sent to bomb Japanese communications towers there were shot down. One of those nine was miraculously rescued by a U.S. Navy submarine. The others were captured by Japanese soldiers on Chichi Jima and held prisoner. Then they disappeared. The one rescued was George H.W. Bush the 43^rd President of the United States.

Today, in 2020, many Americans doubt the country’s ability to come together. Many believe we live in the “Divided States of America.” Bradley takes us back seventy-five years to when men like his father, George H.W. Bush and other heroes of that era epitomized courage, cooperation, sacrifice, and ultimately, victory.

Bradley began his love of history as a boy after reading an article by former president Harry Truman recommending that young readers start with historical biographies as a way to learn about people while absorbing the times of their journey. He’s been stuck on history ever since, which is what led him to write his first book about the unknown story behind the Marines who famously raised the flag on Iwo Jima.

Other spellbinding bestsellers by Bradley include The China Mirage: The Hidden History of American Disaster in Asia; and The Imperial Cruise: A Secret History of Empire and War.

Save the Date for the 2020 Ag Aviation Expo

Dates: Dec. 7-10, 2020
Location: Savannah Convention Center. Some events will also take place at the Westin, which is located directly next to the convention center.
Schedule of Events: Current schedule here. Subject to change.
Hotel: Hotel Details Below
Attendee Registration: Opens July 1
Exhibitor Booth Sales: Large booth sales and Diamond sponsorship booth sales begin in March; this includes aircraft, islands and 10’x30'. 10'x10' and 10'x20' booth sales open on Thursday, July 9. Please email Lindsay if you’d like to be contacted regarding large booth space.
Sponsorship Opportunities: Sponsorships are now available. View the opportunities online. Please email Lindsay if you would like to secure a sponsorship from last year or would like to be contacted about 2020 opportunities! We have sponsorships available for all budget sizes.
Auction Donations: Thank you to Pratt & Whitney Canada for donating a PT6-34AG engine to this year’s NAAA Live Auction. While we’re still several months away from the Ag Aviation Expo, we are already accepting donations for the Live and Silent Auction. The earlier you inform us of your auction donation, the more advertising you’ll receive on the NAAA website and in NAAA publications. Support the aerial application industry by donating an item today. Email Lindsay with your donation details.

Book Your Hotel Room

The 2020 NAAA hotel room block is coordinated through Visit Savannah, which is the Savannah Area Convention & Visitors Bureau Housing office. Please do not call the hotels directly; use the link and/or phone number below to book your room. Rooms are available at the Westin Savannah Harbor (directly next to the convention center), Hyatt Regency Savannah and Savannah Marriott Riverfront hotels (across the river from the convention center and Westin – transportation provided). All room blocks close Nov. 13 at 5 p.m. ET.

Westin Savannah Harbor: $150/night + taxes

Westin Cancellation: For each reservation cancelled after Oct. 30, 2020, a nonrefundable one night room + tax will be charged to the credit card on file. Guests who check out early (prior to the reserved check out date) will be assessed one full night’s room charge + taxes.

Hyatt Regency Savannah: $148/night + taxes
Savannah Marriott Riverfront: $142/night + taxes

All room rates above are single/double occupancy and do not include taxes.

Book your room today by clicking here, call the housing bureau at (912) 644-6465 or email reservations@visitsavannah.com. Please note reservations are taken over the phone Monday through Friday, 9 a.m.–5 p.m. If you cannot call during those hours, please email your reservations details or book your room online here.

Complimentary Transportation & River Taxis

Getting across the river is quick and easy thanks to the free ferry service that will shuttle attendees back and forth throughout the day and evening. The Savannah Belles Ferry provides water transportation from the Hyatt and the Marriott to the convention center and Westin hotel. The trip takes five to 10 minutes, and ferry service will be continual during convention hours; schedule will be available onsite. Free shuttle bus service is also available for those who are not comfortable on the water.

2020 Ag Aviation Expo Hotel Details

Join us for the 2020 Ag Aviation Expo in Savannah, Ga., Dec. 7‒10. Besides the networking, education and fun at the NAAA Ag Aviation Expo, enjoy a city full of great restaurants, nightlife, shopping, attractions and history. The NAAA hotel room block is now open! It is important for attendees to stay in the NAAA room block. We get the best hotel room rates in the heart of the Savannah district. If the NAAA hotel block is not filled, we cannot offer these great rates for future years!

Save the Date for the 2020 Ag Aviation Expo

Dates: Dec. 7-10, 2020
Location: Savannah Convention Center. Some events will also take place at the Westin, which is located directly next to the convention center.
Schedule of Events: Current schedule here. Subject to change.
Hotel: Hotel Details Below
Attendee Registration: Opens July 1
Exhibitor Booth Sales: Large booth sales and Diamond sponsorship booth sales begin in March; this includes aircraft, islands and 10’x30'. 10'x10' and 10'x20' booth sales open on Thursday, July 9. Please email Lindsay if you’d like to be contacted regarding large booth space.
Sponsorship Opportunities: Sponsorships are now available. View the opportunities online. Please email Lindsay if you would like to secure a sponsorship from last year or would like to be contacted about 2020 opportunities! We have sponsorships available for all budget sizes.
Auction Donations: Thank you to Pratt & Whitney Canada for donating a PT6-34AG engine to this year’s NAAA Live Auction. While we’re still several months away from the Ag Aviation Expo, we are already accepting donations for the Live and Silent Auction. The earlier you inform us of your auction donation, the more advertising you’ll receive on the NAAA website and in NAAA publications. Support the aerial application industry by donating an item today. Email Lindsay with your donation details.

Book Your Hotel Room

Westin Savannah Harbor: $150/night + taxes

Westin Cancellation: For each reservation cancelled after Oct. 30, 2020, a nonrefundable one night room + tax will be charged to the credit card on file. Guests who check out early (prior to the reserved check out date) will be assessed one full night’s room charge + taxes.

Hyatt Regency Savannah: $148/night + taxes
Savannah Marriott Riverfront: $142/night + taxes

All room rates above are single/double occupancy and do not include taxes.

Complimentary Transportation & River Taxis

Idaho AAA Advances Bill Providing Fairness to Aerial Applicators Accused of Rule Violations

Last week, the Idaho House of Representatives approved legislation clarifying the potential penalties aerial applicators would face for rule violations. The legislation was unanimously approved by the House Agricultural Affairs Committee and passed by the full House in a 52-12 vote.

David Lehman of the Idaho Agricultural Aviation Association told members of the House Ag Committee applicators accused of violating aerial application rules currently go into Idaho State Department of Agriculture (ISDA) hearings knowing only the maximum penalties. Typically, those maximums serve as a starting point for a negotiation.

Lehman explained House Bill 487 would increase clarity and fairness, and for the first time in about 20 years update the relevant statutes to fit today’s industry.

The bill would eliminate ambiguous language in the statute and require ISDA to write rules related to penalties and restrictions using “a penalty-assessment matrix that clearly defines the penalty based on the level of the violation, the effects of the violation, and whether the violation was made knowingly or unknowingly.” Rules related to restrictions and penalties must also be reviewed and reissued through negotiated rulemaking at least every five years.

Additionally, the bill would eliminate duplicative regulations already covered by federal law, such as aircraft flight patterns, which are under the jurisdiction of the FAA.

“Why would we want an ISDA investigator spending time and money investigating something that the [FAA] Boise Flight Standards District Office could be investigating on the federal dime?” said George Parker, the owner of CropJet Aviation in Gooding, Idaho.

The bill is now waiting for a vote in the Idaho Senate.

NAAA Preps for National Ag Day March 24 with Event on National Mall in D.C.

NAAA is again teaming up with the Association of Equipment Manufacturers (AEM) and several other agribusiness organizations to co-host an event to educate Congress, the USDA and EPA on modern agriculture and sustainability. However, unlike in years past where these events took place on farms just outside Washington, D.C., this year’s event will take place on the National Mall in front of the U.S. Department of Agriculture on March 24 and 25.

As in years past, Helicopter Applicators Inc. (HAI) from Gettysburg, Pa. has once again generously agreed to provide a helicopter for the event. Due to extensive airspace restrictions in Washington D.C. an aerial application demonstration won’t be possible. However, having the event in D.C. during the National Cherry Blossom Festival will allow for potentially thousands of members of the public to learn more about aerial application.

NAAA sends a very special thank you to HAI operator Glenn Martin for again agreeing to provide a helicopter for this event, which will be the fourth time he has done so. NAAA also thanks HAI Director of Safety Joe Stambaugh Jr. and HAI pilot Brock Heffner for their help organizing the event. Their efforts have resulted in aerial demonstrations for hundreds of regulators who would have otherwise never experienced, firsthand, the many benefits provided by the aerial application industry.

A video featuring highlights from last year’s demonstration day, which took place in Newburg, Md., can be viewed here.

Additionally, a flyer for the National Ag Day event can be viewed here.

2019 Demo Day attendees ask questions of Andrew Moore and Joe Stambaugh regarding the Bell OH-58.

Last Chance to Attend the 2019-2020 PAASS Program is March 11 in Indiana

The 2019-2020 PAAAS Program has already taken in place at 20 state and regional meetings. Your last opportunity to attend PAASS is coming up quickly—March 11 from 8 a.m. to 12 p.m. at Turbines Inc. in Terre Haute, Indiana. 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% since PAASS started. Many state departments of agriculture offer CEUs for PAASS attendance and many insurance providers offer discounts to PAASS attendees. The following four modules will be given in Terre Haute.

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.

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.

Want to Win Thousands in Educational Scholarships? Enter Our Support Scholarship Contest!

Attention, higher-education students: Don’t miss out on the opportunity to compete for a combined $3,000 in educational scholarships. The deadline for the 2020 Support Scholarship Essay Contest is Sept. 15. The NAAA Support Committee will award a $2,000 scholarship as top prize and Covington Aircraft Engines has generously agreed to sponsor a $1,000 scholarship.

The theme for this year’s contest is “Why is Agricultural Aviation Important?” The scholarship is not restricted to pursuing a “flying career.” Any educational pursuit beyond high school (at any age) is eligible. The competition is open to all NAAA members and their family members.

Entrants must be a senior in high school or be registered in higher education by the fall semester of 2020. Previous winners are not eligible to compete. Submissions must be an essay of at least 1,500 words or a 5-minute multi-media presentation. Submissions should be sent as an email attachment by Sept. 15 to information@agaviation.org. More information about eligibility requirements, contest guidelines and sample essays from past scholarship recipients are available online here.