January 18, 2024
NAAA eNewsletter

NAAA Submits Comments to EPA on Agency’s Third Proposed NPDES PGP

Last week NAAA submitted comments on the EPA’s proposed reissuance of a five-year National Pollutant Discharge Elimination System (NPDES) Pesticide General Permit (PGP) that covers pesticide applications over aquatic areas. This is the third five-year reissuance of the EPA’s NPDES-PGP. The first was issued in 2016, five years after the initial PGP went into effect in 2011. The second was issued in 2021; the current proposal is for 2026.
 
The vast majority of the proposed 2026 PGP was identical to the 2021 version. Accordingly, NAAA’s comments were similar to earlier comments and touched on the redundancy of the PGP, considering that all pesticides, including those for aquatic sites, already undergo a registration and then a registration review process to verify their safety to the environment when used according to label directions. NAAA commented again that the definition of water of the U.S. (WOTUS) continues to be an ongoing issue that can lead to confusion for both the regulated and the regulators.
 
One key change in the proposed 2026 PGP is the addition of Fish and Wildlife Service (FWS) areas of concern for endangered species. Earlier PGPs had only included National Marine Fishery Services (NMFS) endangered species resources of concern. NAAA did not object to this addition, but did point out that Endangered Species Act (ESA) requirements on the PGP are yet another redundancy considering EPA recent spate of efforts to address ESA issues in pesticide registration and review processes.
 
NAAA also expressed concerns about updated site monitoring and record keeping requirements, some of which fall on the applicator. NAAA pointed out these requirements have the potential to be overly burdensome to aerial application operations, many of which are small businesses. To view NAAA’s comments, click here.
 

U.S. Wind Turbine Database Available: Another Resource to Track Wind Turbines

The U.S. Wind Turbine Database is a resource that provides the location of land-based and offshore wind turbines. View the database here. The database currently includes data on 73,352 turbines covering 44 states. Wind turbine records are collected and compiled from various public and private sources, including from the Federal Aviation Administration (FAA), and they are digitized or position-verified from aerial imagery and quality checked before being added to this database. 
 
The creation of this database was jointly funded by the U.S. Department of Energy (DOE) Wind Energy Technologies Office (WETO) via the Lawrence Berkeley National Laboratory, the U.S. Geological Survey (USGS) Energy Resources Program, and the American Clean Power Association (formerly known as the American Wind Energy Association (AWEA).
 
NAAA is concerned about the placement of wind turbines on arable farmland that make it difficult and dangerous if not impossible to treat cropland in and around the vicinity of the wind towers. The presence of wind turbines can restrict and, in many cases, eliminate the option of aerial application. NAAA encourages anyone considering leasing their wind rights to think seriously about the potential upsides and downsides to farmers and aerial applicators before signing an agreement. View the wind turbine section of the NAAA website, including Learn Before You Lease advertisements and information on the proof of distance needed for an ag aircraft to turn safely from wind turbines and other tower-like obstructions. The information may be used by operators and state associations when dealing with wind farm and tower companies claiming that their obstructions do not hamper aerial application activities to crops.
 

Book Published Unveiling the Origins of Delta Air Lines & the Company’s Beginnings in Aerial Application

James John Hoogerwerf, former Delta Boeing 767 captain and aviation historian, has published a book titled Speed, Safety, and Comfort: The Origins of Delta Air Lines, where he traces the evolution and growth of Delta Air Lines. NAAA shared photos and information with Hoogerwerf about Huff-Daland Dusters Inc., the forerunner to Delta Air Lines, which was the first known aerial application business established. Huff-Daland Dusters completed the first commercial dusting of crops with its own specially built aircraft, the Puffer. 
 
Huff-Daland Dusters rebranded as Delta Air Service in 1928 to focus more on providing transport of passengers and air mail. The following year Delta, began flying its first passengers from Monroe, LA, eventually establishing routes across the southeastern U.S. Hoogerwerf’s book details the history of Delta’s beginnings and the company’s contribution to agriculture, southern industrialization, and the development of commercial aviation in the U.S. You can purchase Speed, Safety, and Comfort: The Origins of Delta Air Lines at any major retailer, including Amazon. 
 
In addition, purchase copies of the aerial application industry’s 100th anniversary book Agriculture’s Air Force: 100 Years of Aerial Application, not just for yourself but also for your local library and school libraries. 
 

Renew Your 2024 Membership Today

 

It's time to renew your membership for 2024! We urgently request your continued support by renewing your NAAA membership for 2024. While you have been busy aiding farmers to produce a safe, affordable, and abundant supply of food, fiber, and bioenergy, NAAA has been busy making sure low altitude airspace is safe for your aerial application business to operate, as well as ensuring that you have the pesticide products you need to do your job. 

 

This year, NAAA is focusing on external communications to farmers in largely circulated ag publications touting  the benefits of aerial application and hiring ag pilots to handle spraying work. NAAA will be contributing articles and ads throughout 2024 in Farm Journal’s publications promoting aerial application services and how their readers can directly search the location of your aerial application business to a potential circulation of 150,000 ag retailer, crop consultants and farmers throughout the U.S.! Sign up for a free issue of The Daily Scoop here and subscribe to The Scoop magazine here. 

 

Several of NAAA’s services conducted on your behalf, include: 

  • The second year of C-PAASS, our professional certification program for aerial applicators that take additional steps to augment their professionalism through education and testing, positioning themselves to be recognized and rewarded by their insurance providers, pesticide manufacturers, and customers. Learn more at https://education.agaviation.org/. 
  • Submitting no fewer than 270 comments since 2017 to the EPA to keep aerial applications on pesticide labels enabling you to keep a deep inventory of pesticide tools without unnecessary and burdensome restrictions.
  • Development of a health care insurance policy in 2024 for NAAA members to purchase for their families and employees at competitive rates.

Supporting NAAA as a member helps provide NAAA with more resources so that we can in turn provide you with more and more membership assets. Continued benefits in 2024 to members include legal consultation on federal aviation laws, discounts for attending or exhibiting at the Ag Aviation Expo, staying connected to members through the print and online NAAA Membership Directory and receiving NAAA publications and eNewsletters, social media briefings and substantive web content at AgAviation.org. 

 

Please make it a priority to renew your NAAA membership---the payoff far exceeds what you will spend in dues in the form of effective advocacy that reduces regulation and taxes affecting your aerial application business and trade association membership dues are tax deductible. If you prefer to pay over the phone, please call (202) 546-5722.

 

Update Your Information for 2024 Membership Directory

Please provide any corrections to your membership listing by Feb. 8 to guarantee accurate inclusion in the 2024 NAAA Membership Directory.
 
Have you moved or changed employers since you renewed your NAAA membership? Allied companies, have you reviewed your company description lately? Ensure your listing in the 2024 NAAA Membership Directory is correct 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 https://members.agaviation.org/. Log in using your username and password and update your information under My Profile.
  • Emailing your changes to information@agaviation.org.
  • Calling the NAAA office at (202) 546-5722.
  • Responding to the email that you will receive in a couple of weeks.
Please provide any corrections by Feb. 8 to guarantee accurate inclusion in the 2024 NAAA Membership Directory!

NAAA & NAAREF Board Meetings Feb. 15-17 in Alexandria, VA

The February 2024 NAAA & NAAREF Board and Committee meetings will take place Feb. 15-17 in Alexandria, Virginia. Click here to view a schedule.
 
All meetings are open to NAAA members. If you are not a board or committee member but are interested in attending, please contact Lindsay Barber for more details.
 
Hotel Details
Hilton Old Town Alexandria
1767 King Street
Alexandria, VA 22314
 
The Hilton Old Town is located directly next to the King Street Metro stop (take either the Blue or Yellow Line), which is the second stop south of Reagan National Airport (DCA). You can view a map of the metro system here.
 
Rate: $159/night + taxes
Cutoff Date: Jan. 23, 2024
Reservations: Click here to book online or call 1-800-HILTONS and refer to NAAA Board Meeting. If you have issues, please do not book outside the block. Contact Lauren Henretty with your arrival and departure dates.
 
Please note: All board books will now be provided electronically. Board and Committee members will receive a link and directions to download the electronic board book approximately one week before the meetings. The board book can be downloaded to your computer or tablet, or you can print your committee items.

NAAA Article Published on American Society of Association Executives (ASAE) Website

NAAA and the agricultural aviation industry are still receiving accolades for the positive public relations received on the 100th anniversary campaign and celebration of the aerial application industry in 2021. Recently, the American Society of Association Executives (ASAE) contacted Lindsay Barber, NAAA’s director of communications & marketing, to share NAAA’s association’s experience in planning an industry milestone event with a small association staff. The article was published Jan. 9, 2024 on the resources section of the ASAE website and Barber shared NAAA’s experiences such as beginning the planning process as early as possible, utilizing member volunteers, maintaining open communication amongst all parties involved in projects and outsourcing to trusted professionals. Read the article here.
 
NAAA is a member of ASAE, which is a membership organization representing the association and non-profit industry. Its membership includes more than 40,000 association executives, representing 7,400 organizations, worldwide. 
 

Don’t PAASS Up Safety Education – Attend the 2023-2024 PAASS Program, Collect CEU’s, Qualify for C-PAASS and Fly Safe

There are still several opportunities to attend the 2023-2024 PAASS Program this winter. Find a program at www.agaviation.org/calendar/ or contact your state/regional association. The PAASS Program covers the latest in aviation safety, environmental stewardship, and best security practices. Some states offer CEUs for PAASS Program attendance which goes towards renewing your commercial pesticide license. In addition, PAASS attendance is required to be a certified professional aerial application safety steward (C-PAASS) which may qualify one for insurance discounts amongst a number of other benefits. Most important, the program saves lives — ag aviation accident rates and drift incidents have decreased by nearly 26% since PAASS hit the stage.
 
The 2023-2024 PAASS program begins with a review of agricultural aviation accidents from the 2023 season. It also includes a discussion of accident trends seen over the 10-year period from 2013 to 2022. Studying agricultural aviation accident trends allows participants to better understand the causes of accidents, information they can use to prevent similar accidents from occurring at their operations.
 
For the human factors segment, PAASS takes on the subjects of stall spin accidents and overly aggressive flying. Participants will hear from a variety of sources, some with advice on how to safely turn an aircraft and others with a cautionary tale of what can go wrong when an ag pilot turns too aggressively. Fran de Kock of Battlefords Airspray in Canada provides both classroom and in-cockpit instruction on how to turn an agricultural aircraft safely, training to learn how an aircraft feels as it approaches a stall, and why agricultural aviation is not aerobatics. 
 
Segments from an updated version of the Turn Smart video from Air Tractor will display the four left-turning tendencies that impact a fixed-wing aircraft in a turn and how they can lead to a stall in an unsafe turn. A survivor of a stall spin accident will provide a glimpse of how severe the consequences can be when an aircraft is turned aggressively in an effort to get more work done.
 
Also featured in the 2023-2024 PAASS Program will be a review of the wire strike avoidance material covered in the human factors segment from the 2022-2023 program. Wire strike accidents continue to be the leading cause of ag aviation accidents. For this reason, a shortened version of last year’s material will remind PAASS audience members about vision science and why it is often difficult, if not impossible, to see the actual wires during an application.
 
PAASS  goes back to the basics in environmental professionalism – discussing the importance of spray droplet size and boom length. Using larger spray droplets and reducing the length of the boom are both proven techniques for reducing drift. The program uses graphics based on the AGDISP spray drift model to visualize how various droplet sizes move once they are released from the aircraft and how the release point along the length of the boom further impacts their movement.
 
To reinforce the importance of security at ag aviation operations, the program provides details on an incident where a perpetrator attempted to steal an agricultural aircraft. By learning about this incident, operators and pilots can better assess their own security measures to prevent criminals from stealing or damaging equipment and contaminating fuel and agri-chemicals. The victim of the attempted theft has a background in law enforcement which provides a unique and helpful perspective on the incident and security.
 
PAASS provides an update on FieldWatch, which has seen a dramatic increase in usage since its creation. It allows aerial applicators to locate sensitive fields and bees with their geography. An example of how ADS-B helped clear charges from the FAA for an aerial applicator. 
 

Your GPS Data May Save a Life

As the Federal Aviation Administration (FAA) marches in lockstep with some corporate interests in the uncrewed aircraft systems (UAS) space, it is becoming clear that green lighting and expanding UAS beyond visual line of site (BVLOS) operations may be being prioritized over safety. 
 
First proposed in the 2022 BVLOS ARC Report, and later put out for public comment in 2023, the FAA is considering designating “shielded” areas wherein UAS would have the right-of-way over crewed aircraft. These areas are defined as the airspace within 100 feet vertically or laterally of an obstacle or critical infrastructure, such as power lines. According to the ARC Report this is based on “the limited likelihood of crewed aircraft operations in [these] areas.”
 
The current reality is that some of these UAS interests (think BNSF Railway, Google, Amazon), and in some cases the FAA, do not have a solid understanding of where and how we operate. It falls now to us, as an industry, to inform future rulemaking of the unique nature of aerial application operations. Using a data-driven approach, we can demonstrate our utilization of the low-altitude airspace and expose the safety threat presented by UAS not giving the right-of-way to crewed aircraft within it.
 
To this end, NAAA has a longstanding partnership with Mississippi State University (MSU) to collect GPS data logs donated by its members. Since the project’s inception in 2017, the data collected and analysis performed by MSU has fueled NAAA’s efforts in representing the safety interests of aerial applicators to regulators.
 
If you have donated logs in the past, Thank You. 
 
If you have logs which you have not yet donated, please consider it. The data you provide can help shape policy on a national level and save lives. As a reminder, any data you submit is stripped of any personally identifiable information prior to inclusion in the larger dataset.
 
There are two options to submit your logs to MSU:
  1. Request a secure upload link for data uploads.  Email Madison Dixon, Associate Director, MSU Agricultural Autonomy Institute 

  2. Mail a flash drive or other storage device to the address below (The device will be immediately mailed back once data is received if a return address is provided):
Mail To: Attn: Madison Dixon
MSU Agricultural Autonomy Institute
Pace Seed Technology Building
Mailstop #9812
650 Stone Blvd.
Mississippi State, MS 39762