January 21, 2021
NAAA eNewsletter

Leaded Aviation Fuel Emissions Report Released by National Academy of Sciences

The National Academy of Sciences recently released the report “Options for Reducing Lead Emissions from Piston-Engine Aircraft.” The report encourages multiple strategies to reduce lead emissions from small aircraft. While acknowledging the difficulties with finding a suitable fuel alternative, the report finds that a non-leaded aviation fuel is still the ideal solution. In the meantime, the report recommends mitigating strategies: 1) The highest lead contamination occurs at the airport, with people working at the airport at the greatest risk. Locate runup areas and test areas away from workers as much as possible. Educate airport workers on the danger of lead emissions. 2) The industry should switch the standard fuel to 100 VLL (very low lead), which has 20% less lead. According to the National Academy of Sciences, 100 VLL would satisfy every aircraft currently operating on 100LL—the minimum lead content is the same, the maximum lead content is lowered, and it would require tighter blending tolerances.


Still active is the Piston Aviation Fuels Initiative (PAFI), a joint government and industry initiative created to develop a path forward for identifying, evaluating and deploying the most promising unleaded replacements for 100 low lead aviation gasoline. Development and prescreening testing are taking place at both private and public testing facilities across the country. The FAA’s William J. Hughes Technical Center is providing engine-testing services through cooperative research and development agreements (CRADA) with the individual fuel companies. While COVID-19 has delayed the completion of the prescreening tests, the tentative schedule is to restart formal PAFI testing in 2021.


The FAA General Aviation (GA) and Part 135 Activity Survey for 2018 indicates 3.59% of the total GA hours flown were in the aerial application, agriculture category (4.03% average in the previous five annual surveys). Approximately 0.68% of the total GA hours flown were in piston-powered agricultural aircraft. Of the total aerial application hours flown, 19% were flown in piston-powered aircraft.

A relevant portion of the ag aviation industry still uses piston engines and, as such, is largely dependent on avgas. NAAA continues to promote funding of research and development of a non-leaded aviation gasoline. While NAAA supports efforts to reduce lead emissions, the association urges proceeding cautiously to ensure the eventual replacement protects the safety, efficiency and livelihood of agricultural aviation.

Top 10 Agricultural Aviation Magazine Articles of 2020

From a touching account about the loss of her husband from the widow of an ag pilot to a look at the pros and cons of ADS-B tracking technology to an update on the state of the ag aviation insurance market, here are the top 10 digital articles from Agricultural Aviation’s 2020 issues based on the most viewed articles at AgAviationMagazine.org and the Agricultural Aviation Magazine App in 2020.

  1. A Crop Duster’s Wife, Always – Spring 2020
    A year after her husband’s death, celebrating his life brings a young widow and mother comfort and joy

  2. Above and Beyond: It’s the Jordan Way! –Winter 2020
    Shane Root, on 2019 Outstanding Service Award recipient Terry Jordan

  3. A Review of 2019 Part 137 Agricultural Aviation Accidents – Winter 2020
    NAAA breaks down 2019’s Part 137 accidents in the hopes of preventing future pilot breakdowns

  4. Flipping Through the Calendar’s Pages – Winter 2020
    NAAA CEO Andrew Moore reviews 2019 and examines trends to forecast the future

  5. Be Careful What You Reveal – Spring 2020
    Darrin Pluhar’s Spring President’s Message

  6. ADS-B Tracking Technology: Are You In or Out? – Spring 2020
    Surveilling how ADS-B fits into new and early adopters’ agricultural aviation operations

  7. Paying It Forward – Winter 2020
    Darrin Pluhar’s Winter President’s Message

  8. Ag Aviation Insurance Market Update – Spring 2020
    Rising premiums and more restrictive underwriting—what’s up with that? Tim Bonnell Jr. takes stock of the ag aviation insurance market

  9. Politics or Science: Will Roundup be Rounded Up or Redeemed? – Winter 2020
    For almost two years glyphosate has been inundated by a slew of misleading headlines, uninformed political criticism and misplaced jury decisions

  10. A Back-to-the-Basics Guide to Understanding Droplet Size Production – Spring 2020
    A look at general trends in droplet sizes produced based on nozzle type, nozzle orifice size, nozzle orientation or deflection setting, spray pressure and airspeed 

Get the Free Agricultural Aviation App

If you haven’t installed the free Agricultural Aviation Magazine App on your smartphone or tablet, you are missing out on a great way to tap into a library’s worth of Agricultural Aviation issues in the palm of your hand. Download the Agricultural Aviation Magazine App and see how easy and enjoyable it is to use. The app is compatible with all Apple, Google and Amazon mobile devices and can be downloaded from their respective app stores by searching “Agricultural Aviation Magazine.” Enable push notifications to be alerted when new digital editions are published and to receive occasional notifications about pertinent articles.

AgAviationMagazine.org

All online editions of Agricultural Aviation, starting with the Fall 2016 issue, are available in two reading formats: Replica and Mobile-optimized. Use the buttons on the navigation bar to get the most from your digital edition.

  • TOC button: The “hamburger” icon, or TOC tab, 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 email or share articles with friends and associates on Facebook, Twitter, LinkedIn, Pinterest and Tumblr.
  •  Issue Library: Access Agricultural Aviation’s back issues by clicking the Issue Library button (or bookcase icon) from a web edition or the Library button in the app.

Give the Gift of Agricultural Aviation

Want to go a step further? As NAAA marks the agricultural aviation industry’s 100th anniversary in 2021, spread the gospel of the industry to your farmer-customers by giving them a gift subscription to Agricultural Aviation, the official publication of NAAA! NAAA members automatically get a complimentary Agricultural Aviation subscription with their membership, but additional subscriptions may be purchased for employees, customers, suppliers and local schools.

Limited Attendance for NAAA and NAAREF Board Meetings Feb. 11-13 Due to Hotel Restrictions

The NAAA and NAAREF Board Meetings Feb. 11-13 are limited in attendance due to the state of Virginia’s social distancing regulations at the hotel. As such, the NAAA and NAAREF Board and Committee Chairs/Co-Chairs are invited to attend the board meeting in person; appointees will only be allowed to participate virtually. Information on how to access the meetings virtually will be forthcoming.

The Hilton Old Town Alexandria will host our February board meetings for NAAA and NAAREF Board and Committee Chairs/Co-Chairs. Click here for a schedule of events (all meetings will take place in ET).

Meetings are open to all NAAA members virtually; if you would like to attend virtually, please email Lindsay Barber for further details.

Hilton Old Town Alexandria

  • Address: 1767 King Street, Alexandria, VA 22314
  • Rate: $153/night plus tax
  • Reservations: Book your room here.
  • Room Block Closes: Jan. 19, 2021, at 5 p.m. ET. Room rates will be higher after block closes and we cannot guarantee rooms after this date.

The Hilton Old Town Alexandria is located directly next to 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.

Update Your Information for 2021 Membership Directory

Have you moved or changed employers since you renewed your 2021 NAAA membership? Allied companies, have you reviewed your company description lately? Ensure your listing in the 2021 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 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 in January.
  • Emailing your changes to information@agaviation.org.
  • Faxing your changes to (202) 546-5726.
  • Calling the NAAA office at (202) 546-5722.
We must have your updated information by Jan. 20 to guarantee accurate inclusion in the 2021 NAAA Membership Directory!

Renew Your NAAA Membership for the Centennial Year of Aerial Application

The 2021 NAAA membership year is underway. Your 2020 NAAA membership has expired; if you have not already done so, please renew online or by calling the office at (202) 546-5722. 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 would like to remind you of just a few new offerings NAAA has recently released, such as:

  • Ensuring your aerial application business and job is ESSENTIAL during COVID-19 and extending license expirations due to quarantine shutdowns. Check out our COVID-19 Resources webpage. 
  • Offering legal services on Federal Transpiration Laws to Operator and Pilot Members.
  • Receive the 2019 NAAA Operator and Pilot Survey Report which is chock-full of key statistics providing a healthy status of the U.S. aerial application industry. 
  • Don’t forget to take advantage of financial incentives such as NAAA’s Recruitment Rewards Program.
  • Our NAAA Membership Directory is your one-stop shop where you can find professional members that might be looking for help or offering help and a plethora of qualified 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.

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 gotten a chance to review all our accomplishments this past year in the 2020 NAAA Membership Directory, you can download our Annual Report.

 

We appreciate your membership as it will help us continue to fight and win to keep aerial application as an essential service during the current global pandemic and on important issues like unfair user fees and taxes; requiring tower marking requirements; and ensure the safe integration of drones into the national airspace; and advocating that EPA keeps a healthy inventory of crop protection products for aerial use without unnecessary restrictions. Your membership helps us better represent your interests.

NAAA Leads Pesticide Use Coalition to Save Many Crops’ Dependence on Effective Use of Paraquat

Last week, NAAA submitted comments to the Environmental Protection Agency (EPA) to argue against aerial restrictions in the agency’s proposed interim decision for paraquat. The proposed interim decision recommended banning all aerial applications of paraquat except for desiccating cotton.

 

The EPA is required by the Federal Insecticide Fungicide and Rodenticide Act (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 reregistration of a product because the biological evaluations and pollinator protection assessments still need to be completed for most products. The proposed aerial ban was based on faulty drift modeling and a failure to require combining personal protection measures for pesticide handlers. The multiple-use restriction was proposed with the erroneous belief that the aerial application of paraquat is not critical to any part of U.S. agriculture besides cotton production.

NAAA’s comments referenced and included letters of support and data from several state agricultural aviation associations: Arkansas Agricultural Aviation Association, California Agricultural Aircraft Association, Louisiana Agricultural Aviation Association, Mississippi Agricultural Aviation Association, Association of Montana Aerial Applicators and North Dakota Agricultural Aviation Association. Letters of support were also received and included with NAAA’s comments from the Arkansas Agricultural Consultants Association, University of Arkansas System Division of Agriculture, Southern Ag Consulting and the National Alliance of Independent Crop Consultants.

In addition to NAAA’s comments, NAAA authored and submitted a letter written on behalf of grower groups whose members rely on the aerial application of paraquat. These comments highlighted some of the main points from NAAA’s comments and noted all the crops that depend on aerial applications of paraquat, including soybean, sunflower, potato, rice, wheat, corn and dry bean crops. The letter was signed by the Council of Producers and Distributors of Agrotechnology, National Association of Wheat Growers, National Cotton Council, National Sunflower Association, Washington Friends of Farms & Forests, USA Rice and the Association of Washington Aerial Applicators.

NAAA’s comments addressed and questioned, once again, the EPA’s use of the Tier 1 model in AgDRIFT to estimate drift from aerial applications. This model uses many inaccurate assumptions and substantially overestimates the risk of drift associated with modern aerial applications. These faulty assumptions include a smaller than commonly used droplet size, a swath displacement shorter than industry standards, a slight inversion present during the application despite being prohibited on the label, wind speed measured at a height appropriate for ground applications instead of aerial applications and modeling the application to bare ground instead of a standing crop. NAAA referred the EPA to a letter submitted to the EPA’s Office of Pesticide Programs in June 2020 for a detailed analysis of all the Tier 1 model’s inaccuracies and how to use the Tier 3 AgDRIFT model to improve the accuracy of aerial drift estimates.


NAAA also commented on the EPA’s risks of concern related to pesticide handlers. The proposed interim decision for paraquat noted there were inhalation risks to mixers and loaders (based on EPA models). These risks were higher for aerial applications because of the high number of acres that can be treated daily using agricultural aircraft. NAAA proposed requiring both a closed loading system and an elastomeric half facepiece cartridge respirator when mixing and loading paraquat for aerial applications. The EPA recommended this same combination on the recent proposed interim decision for triphenyltin hydroxide (TPTH), which NAAA referenced. NAAA also proposed banning flaggers for aerial applications of paraquat, which according to its industry surveys are no longer used by the industry.

After addressing these concerns, NAAA’s comments turned to the EPA’s assertion that aerial application only accounts for 3% of the total acres to which paraquat is applied. NAAA used data and letters from the associations listed above and data from the California Department of Pesticide Regulation provided by CAAA to refute this, proving that aerial application of paraquat is critical for, among other things, desiccation of soybeans and control of herbicide-resistant weeds, particularly in the southern U.S.

The full comments NAAA submitted in defense of the safety and importance of aerial applications of paraquat can be read here. NAAA will be commenting on numerous registration review documents in 2021, including a proposed interim decision for chlorpyrifos and endangered species assessments for glyphosate. NAAA remains committed to ensuring your operation has access to the products your customers demand be applied aerially.

National Air and Space Museum Greenlights Installation of Dusty Crophopper Ag Plane

Dusty Crophopper was immortalized on the big screen in the Disney animated films Planes and Planes: Fire & Rescue. Now America’s favorite ag plane is going to be immortalized at the Smithsonian Institution’s National Air and Space Museum’s Udvar-Hazy Center. NAAA received the official confirmation from the National Air and Space Museum’s general aviation curator Jan. 13.


The aircraft is a Dusty Crophopper-adorned Air Tractor AT-301/400A owned by Rusty Lindeman of Rusty’s Flying Service in Texas (pictured above). Lindeman agreed to donate the aircraft and Disney signed off on it if the National Air and Space Museum would be willing to accept it. NAAA brokered the arrangement between Lindeman, the National Air and Space Museum and Disney Enterprises to add the Dusty Crophopper character likeness aircraft to the museum’s collection of ag aircraft on display at the Udvar-Hazy Center.

In an email informing NAAA and Lindeman of the good news, Dorothy Cochrane, the general aviation curator, stated, “The suitability of the Air Tractor was recognized from the start, it just required internal determination of display or storage capability.”

It is no longer a matter of if but when Dusty Crophopper will be installed in the museum. Three-fourths of the air and space craft at the National Air and Space Museum on the Mall in Washington have been temporarily relocated to the Udvar-Hazy Center in Chantilly, Virginia, while the D.C. location undergoes renovations. In addition, both museums have been closed to the public during the pandemic. It is possible Lindeman’s aircraft could be in place for the National Air and Space Museum’s innovations day at the Udvar-Hazy Center in June, but whether the event takes place will be based on federal and Smithsonian guidelines for reopening the museums and reviving on-site public programming.

NAAA is hopeful that the Dusty Crophopper aircraft can be on display starting on or near the 100th anniversary of the first application by a propelled aircraft on Aug. 3, 2021.

NAAA Closes Out 2020 and Begins 2021 Comments to EPA to Protect Pesticide Products for Aerial Application

On Dec. 22, NAAA submitted comments to the Environmental Protection Agency (EPA) on the final pesticide registration review documents for 2020. The first of the 2021 registration review comments were submitted on Jan. 4. The EPA is required by the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) to review the registrations for all crop protection products every 15 years. The comments submitted on Dec. 22 dealt with risk assessments that the EPA conducts for each active ingredient being reviewed. The comments submitted on Jan. 4 were on proposed interim decisions, which are being used by the EPA instead of a full reregistration of a product because the biological evaluations and pollinator protection assessments still need to be completed for most products.

The risk assessments are the “first round” of documents written by the EPA during the pesticide registration review process. They rely heavily on models to assess the risks the pesticides pose to the environment and human health. The human health risk assessments model the risks to consumers, bystanders and pesticide handlers. The proposed interim decisions are the last phase of the review process. They use the risk assessments as basis for deciding whether a product should be reregistered and what restrictions should be placed on how it is used. While risk assessments may find a risk of concern related to aerial applications of a product, it is the proposed interim decision that might place restrictions on the use of aerial applications.

The proposed interim decisions NAAA commented on were for lambda-cyhalothrin and gamma-cyhalothrin, methomyl, myclobutanil, naphthalene acetic acid, salts, ester, acetamide, and triphenyltin hydroxide (TPTH). The decisions for lambda-cyhalothrin and gamma-cyhalothrin found risks of concern to mixers and loaders for aerial applications and proposed banning the aerial application of gamma-cyhalothrin to high-acreage field crops, which NAAA opposed citing the importance of aerial application for treating these crops. NAAA suggested the use of both a closed loading system and an elastomeric half facepiece cartridge respirator to reduce the risk to mixers and loaders. The proposed interim decision also recommended a buffer zone near aquatic sites, which NAAA indicated needs to be wind direction-based, as drift cannot move upwind. NAAA also opposed a maximum wind speed of 10 mph and proposed 15 mph instead, citing numerous labels and interim decisions that allow aerial application in winds speeds up to 15 mph.

In comments on the proposed interim decisions for methomyl, NAAA made the same arguments in favor of wind direction-based buffer zones and against a 10 mph wind speed restriction. The label statements proposed by the EPA in the interim decisions for myclobutanil and naphthalene acetic acid, salts, ester and acetamide were acceptable, so NAAA commented as such. The proposed interim decision for triphenyltin hydroxide (TPTH) recommended requiring the use of both a closed loading system and an elastomeric half facepiece cartridge respirator for mixers and loaders of aerial applications; NAAA agreed with this requirement. NAAA also argued in favor of wind direction-based buffer zones and against a 10 mph wind speed restriction for TPTH.

The risk assessments NAAA submitted comments for on Jan. 4 were for difenoconazole, fenbuconazole, mesotrione, pyrasulfotole, tembotrione, thiram, tolfenpyrad, topramezone and ziram. All of the risk assessments were done using the Tier 1 model in AgDRIFT to estimate drift from aerial applications. This model uses many inaccurate assumptions and substantially overestimates the risk of drift associated with modern aerial applications. These faulty assumptions include a smaller than commonly used droplet size, a swath displacement shorter than industry standards, a slight inversion present during the application despite being prohibited on the label, wind speed measured at a height appropriate for ground applications instead of aerial applications and modeling the application to bare ground instead of a standing crop. NAAA referred the EPA to a letter submitted to the EPA’s Office of Pesticide Programs in June 2020 for a detailed analysis of all the inaccuracies of the Tier 1 model and how to use the Tier 3 AgDRIFT model to improve the accuracy of aerial drift estimates. A few of the risk assessments did examine the use of larger spray droplets in order to reduce drift. NAAA supported this concept but pointed out droplet size is only one variable in the AgDRIFT model and that the EPA needs to address all of NAAA’s concerns with Tier 1, not just droplet size.


NAAA will be commenting on EPA registration review documents throughout 2021 and into 2022. NAAA commented on pesticide registration review documents for 77 pesticide active ingredients in 2020 and expects to comment on a minimum of 50 in 2021, including paraquat, glyphosate and chlorpyrifos.

This work reiterates the importance of supporting NAAA’s efforts through your membership. Your operation depends on products labeled for aerial application, and you depend on NAAA for ensuring you have access to those products.

FAA Drone Remote Identification Rule Finalized; Operations Over People and at Night Allowed

The Federal Aviation Administration (FAA) 14 CFR Part 89 final rule on the remote identification (RID) of unmanned aircraft systems (UAS) is expected to be published in the Federal Register this month. The rule goes into effect the same time as a rule that amends 14 CFR Part 107 to allow operations of UAS over people and at night.


Remote Identification is hailed as the next incremental step toward further integration of UAS in the National Airspace System. It has been further described as a digital license plate and will be helpful to law enforcement and regulators. There have been situations where unmanned aircraft were not operated legally; however, no enforcement action was taken because it could not be determined with certainty who was operating the UAS or where it was operating. The new rule requires drones to be equipped with technology that will determine a drone’s location and the time it is operating in specific locations. NAAA has been active in advocating drones half a pound or greater be tracked and identified long before the FAA issued its proposed rule in the spring of 2020. You can read those NAAA comments here and the corresponding March 2020 eNewsletter article here.


NAAA has also been pushing for the FAA to require drone sense-and-avoid technology and ADS-B technology to better ensure the safety of manned aircraft from drones; however, that is not a use that will be required as a result of this rule. Under this RID rule, drones will be required to broadcast a signal that includes, among other information, the UAS’s ID serial number, latitude/longitude, altitude, velocity, emergency status and time mark. The identification of the owner/operator of the serial-numbered UAS will only be available to law enforcement and regulatory agencies.

The specific frequency band of the broadcast signal is not specified other than it must be compatible with personal wireless devices such as tablets or phones using Wi-Fi or Bluetooth. The signal strength is required to be optimized to allow reception by as many devices as possible. With only a few exceptions, RID is required for all drones over 0.55 pounds operating outside of an enclosed structure. This is a requirement that NAAA has promoted and was successful in obtaining.

Included in this rule is a prohibition against most UAS using ADS-B Out. This is to prevent the ADS-B system from becoming overwhelmed. NAAA continues to encourage UAS to incorporate ADS-B In, which would enhance safety by informing the UAS operator when an ADS-B out equipped manned aircraft is in the area and obligate them to give the right of way to the manned aircraft as required by Part 107. Newly manufactured unmanned aircraft must meet the requirements of this rule beginning 18 months after publication of the rule in the Federal Register. The operational compliance date for previously manufactured and newly manufactured unmanned aircraft is 30 months after publication.

UAS Operations over People will be allowed by the amendment to 14 CFR 107. The operations have to fit into one of four categories. Each category has different requirements and risk mitigations. The mitigations range from weight limitations to rotating parts being covered to the requirement for a Part 21 airworthiness certificate. Most categories require RID. To read the full mitigation requirements and categories, click here.


UAS Operations at Night are also allowed, which was previously prohibited by Part 107. To qualify for night operations, The UAS must have strobe type anti-collision lighting that is visible for at least 3 miles. The remote pilot operating the UAS is required to have an updated knowledge test to ensure familiarity with the risks and appropriate mitigations for nighttime operations. To read more about UAS operations at night, click here.


NAAA commented on the over-people and at-night rule in March of 2019 when it was first proposed. You can view those comments here. NAAA comments were specifically mentioned in the FAA’s final rule:

NAAA voiced concern about pilot difficulty of spotting a small, unmanned aircraft while the pilot is operating at a very low altitude in what is already a high task load environment. They pointed to a 2015 test conducted by the Colorado Agricultural Aviation Association, which determined that it was difficult for pilots who conduct agricultural aviation operations to detect and track a small, unmanned aircraft at the same time as maneuvering their aircraft for agricultural operations. Pilots operating manned aircraft at low altitudes would experience difficulty in identifying small, unmanned aircraft operating at night, but as discussed previously, numerous mitigations exist to decrease the likelihood of a midair collision.
While the FAA did not completely agree with all of NAAA’s comments, they were definitely taken into consideration.

NAAA continues to work on UAS issues stressing safety to manned aircraft by advocating for technology that will eventually evolve into a traffic management system directing UAS away from manned aircraft. Currently, ADS-B is the only available electronic technology for traffic deconfliction. NAAA encourages manned aircraft to install ADS-B In and Out and for UAS to have ADS-B In. In 2020 the leading drone manufacturer—DJI—started installing ADS-B receivers in all of its UAS. NAAA also pushes for UAS to have high-visibility paint schemes and strobe lighting for both day and night operations.

NAAA Comments to FAA on Companies Using Drones Requesting Exemptions from Aviation Safety Regulations

Earlier this month, NAAA submitted formal comments to the Federal Aviation Administration (FAA) opposing requests from BNSF Railway and Phoenix Air Unmanned for relief from aviation safety regulation requirements under 14 CFR Parts 91 and 61.

BNSF Railway is requesting relief from parts 61.113 (private pilot privileges), 91.7 (Airworthiness), 91.113 (Right of Way), 91.119 (Minimum safe altitudes), 91.121 (altimeter settings), 91.151 (minimum fuel requirements), 91.405 (Maintenance required), 91.407 (maintenance return to service), 91.409 (Annual Inspection) and 91.417 (maintenance records). BNSF’s request for relief states that unmanned aircraft systems (UAS) less than 55 pounds at takeoff would be used for Beyond Visual Line of Sight (BVLOS) operations. NAAA submitted comments opposing the requested relief, documenting the lack of proven technology that would safely allow BVLOS operations to operate and not interfere in the low altitudes that manned agricultural aircraft operate. NAAA also reiterated that UAS must give manned aircraft the right of way as required if this UAS was operated under Part 107—FAA regulations specific to UAS under 55 pounds. Also of concern in the requested relief and opposed by NAAA was a request to allow a single remote pilot in command (RPIC) located remotely to operate up to five unmanned aircraft simultaneously. This indicates an overreliance on computer software for BVLOS, again, without any proven safety technology.


Phoenix Air Unmanned is requesting relief from parts 61.113 (private pilot privileges), 91.7 (Airworthiness), 91.113 (Right of Way), 91.119 (Minimum safe altitudes), 91.121 (altimeter settings), 91.151 (minimum fuel requirements), 91.405 (Maintenance required), 91.407 (maintenance return to service), 91.409 (Annual Inspection) and 91.417 (maintenance records). In the Phoenix Air Unmanned request, the company does not give specifics of whether its intended operation is within line of sight or beyond line of sight, but it does state that the maximum takeoff weight of its UAS is up to 192 pounds. This is a weight that falls above the weight allowed under Part 107. Since specifics of the intended operations were not included in the request, NAAA submitted comments similar to the BNSF comments while stressing the damage that a heavier UAS would do in a collision.


NAAA is aware of the functions that might be accomplished by UAS. At the same time, protecting the safety of current and future users of the national air space is mandatory. Allowing UAS operations without adequate sense-and-avoid technology is a danger to not only low-altitude manned aircraft but all manned aircraft.

NAAA Signs on to GA Industry Letter Requesting a Third Extension to FAR Relief

Last week, NAAA signed on to a letter with six other aviation associations requesting a third extension to SFAR 118. This special regulation provided relief to affected pilots, aircraft owners and operators to safely continue their important role to the U.S. and worldwide economy during the COVID-19 pandemic. SFAR 118 was first issued at the end of April 2020. It has been extended twice since then, with the most recent extension expiring at the end of January.

Each of the extensions covered slightly different provisions of the FARs for different amounts of time. The last extension expiring this month provides a two-month grace period added to medical certification and pilot flight reviews. It is important to note that the extensions were not cumulative. Certifications still expire, but either two or three months after the original expiration date.

An industry survey NAAA conducted in September 2020 showed that 10% of our members still had trouble getting their medical exam due to the pandemic.



The Federal Motor Carrier Safety Administration’s regulatory relief expired Dec. 31, 2020. This agency has not indicated yet if it intends to provide further extensions.

NAAA was one of the first entities to push for regulatory relief and ensured that agricultural aviation was considered an essential service since the COVID-19 pandemic and shutdown effects last March. This “essential” designation has kept the industry working and will continue to be beneficial as the vaccination stage begins now in 2021.

 

Pilots are allowed to take either the Moderna or Pfizer-BioNtech vaccine with no effect to their medical certificate as long as they do not fly for 48 hours after the dose. As an essential service, ag aviation pilots, operators and other workers should have access to the vaccine after frontline health care workers and vulnerable populations are vaccinated. Different states treat this differently. Click here to find a link to your state’s plan.

Looking for Ways to Market Your Business and the Ag Aviation Industry? Give the Gift of Agricultural Aviation

As NAAA marks the agricultural aviation industry’s 100th anniversary in 2021, spread the gospel of the industry to your farmer-customers by giving them a gift subscription to Agricultural Aviation, the official publication of the National Agricultural Aviation Association! The 2021 magazine issues will cover the aerial application industry’s history over the past century—plus, many articles focus on the professionalism and efficacy of aerial application, which your farmer-customers will be interested in learning or relearning about. A gift subscription is a great way to promote not just your business but the industry as a whole. Maybe you will even inspire someone to look at the industry as a possible new career!


Agricultural Aviation provides current information relevant to aerial application industry trends and regulations, scientific research and technology, as well as NAAA services and government relations efforts pertaining to the agricultural aviation industry.


Agricultural Aviation is published four times per year during each season: Winter, Spring, Summer and Fall. NAAA members automatically receive a complimentary Agricultural Aviation subscription with their membership, but additional subscriptions may be purchased for employees, customers, suppliers, local schools, etc., using this subscription form.


Agricultural Aviation is also available digitally online and via the Agricultural Aviation Magazine App.

Ag Aviation's Centennial Year Kicks Off with New Trailer

One hundred years ago, on Aug. 3, 1921, an aerial crop dusting experiment spawned the birth of the agricultural aviation industry. To kick off NAAA’s yearlong centennial celebration, watch this short video on the industry's legacy after a century of agricultural aviation!

 

NAAA Presidents Appear on Business of Ag Podcast

NAAA’s 2020 and 2021 presidents discussed the past, present and future of aerial application on Damian Mason’s Business of Agriculture Podcast. Darren Pluhar and Mark Kimmel, the ’20 and ’21 presidents, taped the Dec. 28 episode on the trade show floor of the 2020 Ag Aviation Expo, shortly after Mason spoke at the expo’s Kickoff Breakfast. Topics covered in the episode include the future of aerial application via manned and unmanned aircraft, the impact of consolidation, regulations, cropping changes and the evolution of agriculture as seen from the cockpit. Watch the informative episode below or listen to it on SoundCloud.

 

 

The Business of Agriculture Podcast covers the business of food, fuel and fiber through interviews with industry professionals and commentary from the podcast’s host.