ber 12, 20

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NAAA Comments Opposing UAAS Exemption from Filing NOTAMs 

This week, NAAA submitted comments on a petition for exemption from an uncrewed aerial application system (UAAS) operator, seeking relief from the requirement to file Notice to Air Missions (NOTAMs) prior to each operation. 

The petitioner, in justifying their request, stated that the NOTAM filing requirement will cause them to miss out on spontaneous work and profits. The supporting documentation for the petition was locked and marked confidential, thus providing NAAA and the public no transparency on how they plan to mitigate the increased risk associated with the proposed relief. 

NAAA expressed concern that removing the NOTAM filing requirement will remove one of the few remaining layers of safety in place to prevent a mid-air collision with a crewed Part 137 aircraft. It would mean that pilots will have to rely more heavily on remote pilots to uphold their duty to see and avoid crewed aircraft. 

Further, NAAA cited the iterative lowering of the bar for entry to UAAS operations as discussed in last week’s eNewsletter. The takeaway from that article is that the UAAS certification process, in its current state, can be easily misused, certifying individuals with little knowledge of, and vested interest in, conducting safe airspace operations.  

Finally, the petitioner stated that the requested relief should be granted, in part, on “significant cost savings achieved by transitioning from traditional manned aerial resources to UASs.” While no evidence was publicly provided to support this claim, NAAA expressed concern that this statement was put forth as a core justification for a reduction in safety. 

You can view NAAA’s comments here. 

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FAA Seeks to Ensure UAAS Operators Understand Regulatory Obligations 

The FAA has updated their Part 137 uncrewed aerial application systems (UAAS) webpage with a highlighted header which reads: 

“The FAA has become aware of exemption holders conducting commercial agricultural operations in a manner noncompliant with the conditions and limitations of their exemption. Therefore, the FAA is implementing operational validations to ensure that each exemption holder fully understands their obligations to conduct operations in accordance with their exemption, the required Part 137 certificate, their ATO-issued COA, and all pertinent sections of 14 CFR. This includes basic requirements such as obtaining a Remote Pilot Certificate and registering their UAS. 
  
The FAA has begun to send requests for information (RFI) seeking basic operational information. Without this information, the FAA will not move forward with a decision letter and will close your petition request for failure to respond to the RFI.” 

This new requirement for prospective Part 137 UAS operators to submit Basic Operational Information includes the following: 

  1. The applicant’s full legal name and address. (Not a PO Box) 
  1. The Chief Supervisor of Operations. The “Chief Supervisor of Operations” is the point of contact for the petitioner that will be able to answer any potential FAA questions regarding the applicant’s operations in a timely manner. 
  1. What is the contact information for the Chief Supervisor of Operations to include a phone number and an email address? Please provide the Chief Supervisor of Operations’ address if different from the applicant’s address.  (Not a PO Box)  
  1. Who will be the pilot in command (PIC) for the proposed UAS operations? Please provide the name and pilot certificate number for your PIC (for example “1234567”).  
  1. What aircraft do you intend to operate under this exemption? Please provide each aircraft’s make, model, and N-number (for example “N123UA”) as well as the name of the owner of each aircraft you intend to operate under this exemption.  
    * For extension or amendment requests only: 
  1. What is your 137 Certificate number (for any extension requests)? (for example “123A456B”) 

This change, while acknowledging widespread non-compliant UAAS operations, does not seem to address the core issue of a lack of understanding. NAAA has fielded numerous calls and questions regarding UAAS operators who simply do not understand the federal regulations they are subject to, nor the conditions and limitations in their exemption which they must adhere to when conducting operations. 

NAAA appreciates FAA collecting this information, however, more needs to be done to seriously address the issue, including more enforcement . Over the past several years, FAA, due to congressional pressure, has iteratively lowered the bar for entry to UAAS operations. The requirement of a commercial pilot certificate has been removed. The requirement for demonstrating Part 137 Knowledge and Skills has been removed. The requirement for a medical certificate has been removed. The requirement for FSDOs to routinely inspect UAAS operations (as they do crewed Part 137 operations) has been removed. The end result is a certification process which can be easily misused, certifying individuals with little knowledge of, and vested interest in, conducting safe airspace operations. 

More education on this front is sorely needed, and there has been progress. FAASTeam has hosted a series of safety and professionalism webinars for UAAS operators over the past several months, with a focus on improving understanding of exemptions, COAs and general professional operating guidelines. NAAA will continue to support these and other education and outreach efforts regarding Part 137 operations. 

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NAAA Joins National Aviation Community Mourning Last Week’s Loss of Commercial and Military Crew and Passengers and to Emphasize the Safety of the U.S. Aviation System

NAAA joined commercial airlines, general aviation and other national aviation organizations in issuing a statement to the public mourning the tragic loss of the passengers and crews of Flight 5342, PAT 25 and Med Jets Flight 056 last week in our nation’s capital area.  The public statement also expressed the organization’s commitment to further improving aviation safety while emphasizing the quality of the current U.S. aviation system.  The statement stated, ““Aviation remains the safest mode of transportation in the world. Nearly 50,000 flights take off and land safely each day in the U.S., and our National Airspace System remains the gold standard of safety.”  To read the letter click here.

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Update Your Information for 2025 Membership Directory

To guarantee accurate inclusion in the 2025 NAAA Membership Directory, please make any corrections to your membership listing by February 7.

Have you moved or changed employers since you renewed your NAAA membership? Allied companies, have you reviewed your company description lately? Log into your account to ensure your listing in the 2025 NAAA Membership Directory is correct by February 7.

You can provide your information by:

  • Calling the NAAA office at (202) 546-5722.
  • Updating your information online at https://agaviation.org/. Log in your username and password, click My Account, and update your information under My Profile on the left-hand box.
  • Emailing your changes to information@agaviation.org.

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Superseding AD Proposed for R44 Flex Plates and Clutch Yokes 

The FAA has proposed to supersede Airworthiness Directive (AD) 2024-19-11, which applies to all Robinson R44 and R44 II helicopters. NAAA previously reported on AD 2024-19-11 in March 2024. 

The proposed superseding AD will retain all requirements of the original AD and update the alternative action to repetitively inspect a yoke that has reached the specified threshold instead of replacing it. It also adds the option to use Bonderite stripper S-ST 5251 instead of Cee-Bee stripper A-292, since the later could be difficult for some operators to obtain. 

Comments are due March 17, 2025. You can find the proposed superseding AD here. 

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Start 2025 Strong—Renew Your NAAA Membership Today!

Thank you for your support as a 2024 member of NAAA. We request your continued support by renewing your NAAA membership for 2025 today. 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. Several of NAAA’s accomplishments this year, on your behalf and to ensure your success, include:

  • NAAA is now offering health and life insurance options for members. More details available here.
  • Due to NAAA’s advocacy, the FAA just issued a proposed rule to mark and log into a central database, meteorological towers between 50 and 200 feet.
  • Also due to NAAA’s advocacy, the DOT’s FMCSA, has issued a proposed rule allowing states to waive the HazMat requirement for Class A CDL holders hauling no more than 1,000 gallons of aviation-grade jet fuel for agricultural aircraft operations, thereby increasing the supply of available drivers to ag aviation operations.
  • After years of effort, the EPA finally accepted NAAA’s recommendations to improve the accuracy of the models used to estimate the amount of drift from aerial applications. This will result in mitigating aerial buffers and preserving aerial use language on pesticide labels.
  • NAAA worked with the FAA to secure the use of radio frequency 122.925 for radio communications between agricultural aircraft to safely operate.
  • NAAA successfully advocated that the enacted FAA Reauthorization Bill require FAA to ensure airspace safety for crewed aircraft as part of its soon-to-be-released policy for uncrewed aircraft to operate beyond visual line of sight (BVLOS).
  • Since 2017, NAAA has submitted over 300 comments to the EPA to keep aerial application use language on pesticide labels.
  • NAAA and NAAREF have grown the C-PAASS certification learning center to include online learning for aerial applicators who want to augment their professionalism and be recognized and rewarded by their insurance providers, pesticide manufacturers, regulators, and customers. Learn more at https://education.agaviation.org/

In 2025, you will continue to receive ongoing benefits such as discounts for attending or exhibiting at the Ag Aviation Expo, connect with members through the print and online NAAA Membership Directory and receive Association publications, eNewsletters, social media briefings and substantive web content at AgAviation.org. Log into your account on our website to pay your 2025 NAAA membership invoice. Details at AgAviation.org/membership.

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.

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In Case You Missed Last Week’s NAAA eNewsletter

Click here for the January 30, 2025 eNewsletter to read:

  • FAA Seeks to Ensure UAAS Operators Understand Regulatory Obligations 
  • NAAA Operator Member, Karen Allen, Featured in Season Premiere of YouTube Channel, Field Trips
  • Congratulations to Cindy Schreiber-Beck, North Dakota Aviation Hall of Fame’s 50th Inductee
  • FAA Safety Team Webinar Reported on Advanced Flight Operations and Utilizing the Federal Docket
  • Bell 47 Helicopter Featured in the Latest Simple Flying Magazine
  • Save the Date for the Ag Aviation Expo Taking Place Nov. 17-19, 2025 in Reno, Nevada
  • February 20-22, 2025, NAAA Committee & Board Meetings in Montreal, Quebec, Canada: Room Block Deadline Today!
  • Update Your Information for 2025 Membership Directory
  • Kickstart 2025 by Renewing Your NAAA Membership

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