NAAA Comments on Endangered Species Evaluations to Protect Aerial Applications of Triazine Herbicides
Earlier this week, NAAA submitted comments to the Environmental Protection Agency (EPA) on the biological evaluations for the reregistration of two triazine herbicides: atrazine and propazine. The EPA is required by FIFRA to review the registrations for all crop protection products every 15 years. As part of the reregistration process, the Endangered Species Act (ESA) requires that EPA work with the Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS) to evaluate the potential risks each pesticide represents to threatened and endangered species and their designated habitat. To accomplish this mandate, the EPA conducts a biological evaluation for each pesticide being evaluated during reregistration.
How these biological evaluations should be conducted has been a longstanding source of debate among the various parties interested in the matter. An interim method that was developed in 2015 was used for the evaluations of chlorpyrifos, diazinon and malathion. Based on feedback from those, the EPA released a revised method for conducting the evaluations in March of 2020. This revised method was used for atrazine and propazine.
Similar to human health and ecological risk assessments, the EPA once again used the Tier 1 model in AgDRIFT to estimate drift from aerial applications. NAAA referred the EPA to a letter submitted to the EPA’s Office of Pesticide Programs in June of 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. For atrazine, NAAA also commented that all buffer zones need to be based on the wind direction, as spray drift only moves downwind, not upwind.
In March NAAA will be commenting on the biological evaluation for glyphosate. NAAA will continue to monitor the pesticide registration review process to make sure aerial applications remain on pesticide labels.
NAAHOF Accepting Nominations for NAA 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 2022. Nominations to be considered for induction into NAAHOF in 2022 are due by Sept. 1, 2021. The 2022 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
For more information, please contact Brian Rau at (701) 486-3414 or medinaflying@aol.com.
Membership Grace Period Ends Monday, Feb. 15
Thank you for your support as a 2020 member! If you have not yet renewed, your membership grace period ends on Feb. 15. Do we have your support for 2021?
You can renew online today or call 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.
Your membership will help us continue to fight and win important issues such as:
- NAAA petitioned to extend expiration dates for flight medical, commercial pesticide applicator, and numerous other needed licenses to conduct aerial application services during the COVID-19 pandemic. We also ensured your aerial application business and job is ESSENTIAL during COVID-19 and was not affected by the quarantine shutdowns. Check out our COVID-19 Resources webpage.
- NAAA protects the industry from unfair user fees and taxes.
- NAAA has successfully pushed for tower marking requirements.
- NAAA has protected manned pilots’ safety as drones are integrated into the national airspace.
- NAAA ensures crop protection products remain available for aerial use without unnecessary and burdensome restrictions. NAAA has commented on over 200 active ingredient registrations with the EPA since 2017.
One of our largest projects this year is protecting and advancing the needs of the industry by improving the public’s perception of the aerial application industry and capitalizing on the 100th Anniversary of agricultural aviation this year. We are already working on many projects related to the 100th celebration, including a website, history book, documentary and public promotional events.
We’d like to remind you of just a few new offerings NAAA has recently released such as:
- NAAA is offering complimentary time for legal services on Federal Transportation Laws to Operator and Pilot Members.
- 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.
- Discounts on 2021 Ag Aviation Expo attendance, Dec. 6-9, and recruitment rewards.
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 the EPA keeps a healthy inventory of crop protection products for aerial use without undue restrictions. Your membership helps us better represent your interests; renew your membership today!
NAAA & NAAREF Board Meetings Begin Today
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, as well as Committee Chairs/Co-Chairs are invited to attend the board meeting in person; appointees will participate virtually.
Meetings are open to all NAAA members virtually (limited availability). If you would like to attend virtually, please email Lindsay Barber for further details.
The Hilton Old Town Alexandria will host our February board meetings for NAAA and NAAREF Board, as well as Committee Chairs/Co-Chairs. Click here for a schedule of events (all meetings will take place in ET).
Hilton Old Town Alexandria
- Address: 1767 King Street, Alexandria, VA 22314
- Reservations: If you need a room reservation, please email your arrival and departure date to Lindsay Barber.
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.
FAA’s 2019 General Aviation Survey Results Reveal Important Ag Aviation Statistics
The results from the 2019 FAA General Aviation and Part 135 Activity Survey (GA Survey) have been released. Ag aviators flew a total of 873,552 hours in 2019, down slightly from 2018 during which ag aviation registered 902,885 flight hours. A total of 3,120 ag aircraft were used in 2019, which was again a slight decline from the 3,335 ag aircraft used in 2018. The average hours flown per aircraft, however, increased from 271 hours per aircraft in 2018 to 280 hours per aircraft in 2019.
There were 60 ag aviation accidents, including six fatal accidents, in 2019. The overall ag aviation accident rate in 2019 was 6.87 accidents per 100,000 ag hours flown. The 2019 fatal ag aviation accident rate was 0.69 fatal ag aviation accidents per 100,000 flown. The 2019 accident rate for the remainder of general aviation (excluding part 135) was lower than ag aviation’s rate at 5.43 accidents per 100,000 hours flown. General aviation’s 2019 fatal accident rate was 1.02 fatal accidents per 100,000 hours flown, which is higher than ag aviation’s fatal accident rate.
The PAASS Program continues to play a significant role in reducing ag aviation accidents. The average ag aviation accident rate in the six-year period before PAASS began was 9.64 accidents per 100,000 hours flown. That rate has dropped to an average of 7.2 accidents per 100,000 hours flown, a 25.3% reduction, during the first 20 years of the PAASS Program, 1999 to 2019. The average accident rate from 1999 to 2010 was 7.56 accidents per 100,000 hours flown, a 21.6% reduction from pre-PAASS rates. For the period of 2012 to 2019 (there was no GA survey data for 2011), the average accident rate was 6.67 accidents per 100,000 hours flown. This is a 30.8% reduction in ag aviation accidents compared to pre-PAASS accident rates. This proves that not only is PAASS working to reduce ag aviation accidents, but that it continues to improve on accident reduction as it progresses. As an additional note, not all ag pilots attend the PAASS Program annually. Of the approximately 3,400 ag pilots in the U.S. only 1,593 attended the 2019-2020 PAASS Program.
In 2019 fixed-wing aircraft represented 78.3% of the ag aircraft used and the other 21.7% were rotor-wing aircraft. The total hours flown by aircraft type showed a different percentage breakdown, with fixed-wing aircraft accounting for 82.5% of the ag aviation hours flown and rotor-wing aircraft accounting for 17.5% of ag aviation hours. For engine type, including both fixed and rotor-wing aircraft, piston engines were used in 28.3% of ag aircraft in 2019 and represented 17.5% of the total ag aviation hours flown. Turbine engines were used in 71.7% of ag aircraft and accounted for 82.5% of the 2019 ag aviation flight hours.
The invitation to participate in the 2020 GA survey will be coming out soon. The GA Survey is the only source of information on the general aviation fleet, the number of hours flown and the ways people use general aviation aircraft. Please help our industry and aviation in general by providing accurate information to the FAA when it comes time to participate in the 2020 GA Survey.
FAA Decides not to Extend COVID-related SFAR 118 Airman Certificate Extensions Again
NAAA has been notified that the Federal Aviation Administration (FAA) has chosen not to further extend SFAR 118. The FAA first issued this special regulation in April of 2020 to provide relief to airmen and other certificate holders who were having trouble completing recurrency training and recertification requirements due to the COVID-19 pandemic. The pandemic made it difficult to meet required biennial flight reviews, medical exams, instrument currency and other regulation-required deadlines.
The original SFAR 118 and the two extensions added additional months to an airman’s expiring certifications. The final extension expired in January. Starting in February, any certifications or recurrency requirements coming due will need to be completed in the normal pre-pandemic timeframe.
NAAA was one of the organizations instrumental in getting the first relief for airman approved and the two extensions after that. Last month NAAA signed on to a letter with six other associations urging the FAA to grant the third extension. The FAA has left open the possibility of regulatory relief in the future but did not determine it was needed at this time.
Biden Promptly Signs Executive Orders Addressing the Environment, Wages and Health
On Jan. 20, President Biden signed an executive order rejoining the Paris Climate Agreement. He also signed an order requiring the review of Trump administration rules titled “Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis.” The order was accompanied by a fact sheet that lists specific regulations that will be subject to the review, including:
- “Pesticides; Agricultural Worker Protection Standard; Revision of the Application Exclusion Zone Requirements,” 85 Fed. Reg. 68760 (Oct. 30, 2020).
- “The Navigable Waters Protection Rule: Definition of ‘Waters of the United States,’” 85 Fed. Reg. 22250 (April 21, 2020).
- “Chlorpyrifos; Final Order Denying Objections to March 2017 Petition Denial Order,” 84 Fed. Reg. 35555 (July 24, 2019).
- “Endangered and Threatened Wildlife and Plants; 12-Month Finding for the Monarch Butterfly,” 85 Fed. Reg. 81813 (Dec. 17, 2020).
NAAA, along with the Small Business Administration, first commented to the EPA about these concerns as reported in the September 5, 2014 NAAA eNewsletter. Last November, the EPA updated the policy stating the AEZ does not extend across the property boundaries of the grower’s (target) field. If conditions favor an applicator to treat a crop due to wind direction and other factors moving away from persons outside of a grower’s property but within 25 feet for ground or 100 feet for aerial, a safe application may still be made. It is important to note that an applicator is still responsible to not allow contact to people of the applied product per the pesticide label and Worker Protection requirements.
“The Navigable Waters Protection Rule: Definition of ‘Waters of the United States’” has been an ongoing back and forth between administrations. The Obama administration rewrote the Clean Water Act’s definition of a Waters of the U.S. (WOTUS) in 2015. On April 21, 2020, the Trump administration’s EPA and the Army Corps of Engineers published their final rule rescinding the 2015 Obama-era rule and then issued a replacement rule that became effective on June 22, 2020. The definition still needs to survive judicial review that is likely to make its way to the U.S. Supreme Court. NAAA supported the Trump administration, which clarified the definition and removed areas defined as WOTUS even though they may have been longtime dry river beds.
There are also a host of rules relating to endangered species or their habitat designations subject to the review, but nothing specific to the pesticide consultation process.
President Biden’s chief of staff, Ron Klain, also issued a memo freezing all pending rule changes proposed by the Trump administration.
In addition, the new president signed an order raising the minimum wage to $15 for the federal workforce. Under the order and an accompanying Department of Labor notice, federal contractors are also required to pay a $15 per hour minimum wage and provide emergency paid leave.
Finally, the president signed a slew of executive orders aimed at addressing the coronavirus pandemic, including an order on “Protecting Worker Health and Safety,” which directs the Occupational Safety and Health Administration (OSHA) to update COVID-19 safety recommendations for businesses within the next two weeks and review its enforcement efforts. The order also requires OSHA to consider whether any temporary emergency standards on COVID-19, including with respect to masks in the workplace, are necessary, and if so, to issue the new standards by March 15.