NAAA UAS Safety Concerns and Recommendations

NAAA is concerned that the widespread use of UAS without proper safe integration, will result in conditions ripe for low-level aviation accidents.

UAS present a hazard to low-level pilots similar to that presented by birds and other low-level obstacles such as other aircraft and towers. According to a joint report by the FAA and the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (USDA-APHIS), between 1990 and 2012 over 131,000 wildlife strikes occurred with civil aircraft, 97 percent of which were the result of collisions with birds, with 25 producing fatalities. Accident records maintained by NAAA, as taken from NTSB accident reports, show there were 10 collisions between aircraft, in which at least one of the aircraft was an ag aircraft during the last 10 years (2004-2013) and since 2004 there have been 12 accidents between ag aircraft and towers—a number of which were unmarked, resulting in 7 fatalities. 
NAAA is urging members to report any near-misses or impacts to the FAA and NAAA to ensure safety information is properly documented to the FAA.
In 2012 Professor Todd Humphreys of the University of Texas at Austin was able to successfully hack a UAS signal utilizing simple off the shelf components. By utilizing this signal “spoofing” technique, Humphreys was able to gain complete control of the aircraft and change its route. This experiment, along with others shows that the relatively simple ability to hack a UAS signal presents not only a safety concern, but also a national security concern as these aircraft can be rerouted to cause damage to structures, along with manned aircraft.
A fundamental safety principle is the ability to see and avoid obstructions and other aircraft in the airspace in which they operate. While this principal is the backbone of safety for our industry and all air traffic operating under visual flight rules (VFR), it can only be utilized effectively when other aircraft do their part in avoiding collisions and making their whereabouts known. Requiring UAS to be identified and well-marked visually will considerably increase the likelihood that a manned aircraft will avoid a collision with a UAS.
In brief, NAAA believes that the following safety precautions would significantly reduce the likelihood of UAS collisions with manned aircraft, and is advocating these positions to the FAA and Congress:·        
  • UAS should be equipped with visible strobe lighting
  • UAS pilots should be required to have a commercial pilot certificate in order to demonstrate proper knowledge of the National Airspace System (NAS), and their responsibilities flying as a commercial pilot; as well as a Class 2 medical certificate
  • UAS pilots should have an equally qualified non-flying observer to ensure the UAS operation remains clear of manned operations
  • UAS should be certified airworthy by the FAA prior to having permission to fly in the NAS
  • UAS should be painted in readily distinguishable colors, such as aviation orange and white, to increase visibility
  • NOTAMs should be filed 48 – 72 hours prior to UAS flights (required under granted Sec. 333 exemptions)
  • UAS should be required to be registered with the FAA and have a “N – Number” as required by manned aircraft under Part 45 (required under granted 333 exemptions)on an indestructible and unmovable plate attached to the sUAS.
  • UAS should be required to land immediately if the observer or operator see a manned aircraft within two miles of the UAS
  • The training and licensing of UAS operators who intend to spray chemicals should be equally as stringent as that for aerial application pilots in terms of obtaining commercial pesticide licenses; ensuring compliance with state regulations, 14 CFR Part 137 regulations, and EPA regulations
  • Commercial UAS operators should also be required to carry liability insurance and ensure their UAS is properly maintained
It is also vital that commercial aircraft, manned and unmanned, receive airworthiness certification by the FAA to ensure they can safely operate in the NAS without posing a hazard to persons or property. ADS-B Out equipage, strobe lighting, and marking, as previously discussed, ensures the aircraft is noticeable and visible to manned aircraft, law enforcement, the public and other UAS.

Continue to UAS Background 

Updated October 2015 

This document is intended for NAAA members’ review only. It is not intended for publication. NAAA requests that should any party desire to publish, distribute or quote any part of this document that they first seek the permission of the Association.