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NAAA Secures Further Benefits for Aerial Applicators in EPA’s Final Insecticide Strategy

The insecticide strategy is the latest document from EPA focused on protecting endangered species and critical habitat covered by the Endangered Species Act (ESA). It follows the herbicide strategy, released in August of 2024. The herbicide strategy focused on protecting endangered species, primarily plants, from herbicide applications. The insecticide strategy has a similar goal – protecting endangered invertebrates, and in some cases other endangered species that rely on them, from potential harm caused by insecticide applications.

The proposed insecticide strategy, released in September of 2024, was mostly favorable for aerial applications. All proposed buffers were downwind only, meaning no buffer zone is needed if the wind is blowing away from a protected area. In addition, EPA finally acknowledged that the Tier 3 AgDRIFT model with more modern assumptions is more accurate for estimating drift from aerial applications. 

In March of this year EPA released the final insecticide strategy, which had even more victories for the aerial application industry. Based on comments from NAAA, EPA reduced the maximum possible downwind buffer distance for aerial applications from 500 feet to 400 feet. In addition, also based on comments from NAAA, EPA approved boom shutoffs to 50% of wingspan or rotor diameter as a mitigation option to reduce the distance of downwind buffer zones for aerial applications. Use of a 50% boom will reduce the required distance of a downwind buffer by 65% in winds less than 10 mph, and by 50% for winds 10 to 15 mph.

Finally, EPA increased the percentage that downwind buffer zones that can be reduced by using larger droplet sizes, once again based on comments submitted by NAAA. The reduction in buffer distance with the use of a coarse droplet spectrum increased from a 20% buffer zone reduction to a 40% reduction; the buffer reduction for a very coarse droplet spectrum increased from a 40% reduction to a 60% reduction. Since all mitigation measures are cumulative, use of a very coarse droplet size and a 50% boom shutoff in winds from 10 to 15 mph would mean the downwind buffer zone would be completely eliminated. 

Protecting the aerial application of pesticides from overly restrictive regulations is but one of many benefits provided by NAAA.

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Executive Orders Pushing FAA for Expedited BVLOS Rulemaking 

On June 6th, the White House issued the Executive Order (EO) Unleashing American Drone Dominance, which is aimed at accelerating the safe integration of uncrewed aircraft systems (UAS) into the National Airspace System through rulemaking that enables routine advanced operations. In addition, this EO stresses to all agencies to prioritize integration of UAS manufactured in the United States over those made abroad. 

This EO specifically directs the FAA to issue a proposed rule enabling routine beyond visual line of sight (BVLOS) operations for UAS for commercial and public safety purposes by July 6th, with a final rule to be published by February 1, 2026. It also directs the FAA to establish clear metrics for assessing the performance and safety of BVLOS operations by July 6th. In short, it appears that BVLOS rulemaking (expected as the new 14 CFR Part 108) is imminent and based on communications with partner industries it is expected that the period for public comment will be as short as 30 days. NAAA is monitoring the situation closely and will provide its membership with draft comments as early as practicable so that they may be used to aid members by submitting their own comments. This will occur in the middle of the busy season for many in the industry, but it will be critical to demonstrate the safety implications of this rulemaking to FAA. 

Another concerning mandate to FAA in this EO is the direction to initiate the deployment of artificial intelligence (AI) tools to assist in and expedite the review of UAS waver applications under Part 107. 

Also on June 6th, the White House issued the EO Restoring American Airspace Sovereignty, which focuses on unlawful use of UAS and counter-UAS measures. This EO paves the way for State, local, tribal and territorial (SLTT) agencies to receive grants for purchasing equipment or services for the detection, tracking or identification of drone signals. It also directs FAA to provide automated real-time access to personal identifying information associated with UAS Remote ID signals to appropriate executive departments/agencies and SLTT agencies for the purpose of enforcing applicable Federal or State law. 

While the specifics of how this will all shake out is unclear, what is clear is that the political foot is on the accelerator for advancing integration of UAS into the National Airspace System. As always, NAAA will stay abreast of any rulemaking activities ensuing from these EOs and will respond in the interests of the aerial application industry. 

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FAA Assessing Suppression of Private Aircraft Owner/Operator Info – NAAA Seeks Expansion to Part 137 

Following a statutory mandate in the FAA Reauthorization Act of 2024 (49 U.S.C. §44114), the FAA is seeking implementation of a procedure which, upon request of a private aircraft owner or operator, the personally identifiable information (PII) of such an individual will be withheld from broad dissemination or display, including on publicly available FAA websites. This PII to be removed will include the mailing/registration address, email, telephone number(s) and name(s) of aircraft owners/operators. 

In April, FAA issued a request for public comments on this matter, including a question on whether any additional aircraft registration data should be removed from FAA websites. While not explicit in the Proposed Rule, the impetus for this appears to be public use of ADS-B data which is readily coupled to FAA-provided aircraft owner/operator PII. 

Last week, NAAA provided comments in support of this rulemaking, with a targeted appeal to expand this suppression of aircraft owner/operator PII to Part 137 operators. 

While voluntary ADS-B adoption amongst aerial applicators is growing, many cite the concern that the data will be used against them as the primary barrier to adoption. This is not unfounded. The combination of being extremely visible while performing work for which some sector of the public harbors animosity has resulted in aerial applicators becoming, quite literally targets for individual frustrations. In NAAA’s comments, it is pointed out that aerial applicators have been fired upon on enough occasions for the association to develop a Checklist of Pilots Subjected to Discharge of a Firearm Targeting an Ag Aircraft.  

As precedent for suppressing Part 137 owner/operator PII, NAAA cites uncrewed aerial application systems (UAAS) which, prohibited from ADS-B Out, must adhere to Part 89 Remote ID regulations. Remote ID broadcasts a serial number or session ID of the aircraft, but FAA prevents public correlation of this information with the aircraft owner/operator by not listing this on any of their websites. This effectively shields UAAS owners/operators from being tracked by the public. NAAA reasons that crewed aerial application owners/operators, many of whom want to equip with ADS-B solely to avoid collisions with drones, should be afforded this same level of PII protection by the FAA. 

NAAA’s comments were echoed and supported by NAAA Allied Member uAvionix, a manufacturer of safety-critical avionics systems for both crewed and uncrewed aircraft. In uAvionix comments to FAA, they reiterate that “privacy and safety are not mutually exclusive. The ability to broadcast an aircraft’s location for situational awareness does not require the public disclosure of the owner or operator’s identity.” Thanks to uAvionix for their support in this matter.  

You can view NAAA’s full comments here. 

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NAAA Battles for Aerial Applications of New Insecticide—Isocycloseram—on All Crops and in All States

NAAA submitted comments this week on a proposal to register isocycloseram, a new insecticide with a novel mode of action. NAAA first became involved with the registration of isocycloseram late in 2024, when the registrant, Syngenta, reached out for NAAA’s assistance. During the registration process between Syngenta and EPA, EPA had indicated they intended to ban aerial application of isocycloseram for all crops except for cotton, and even then, only in specific locations. NAAA submitted a letter to EPA on behalf of Syngenta to support their efforts to get aerial application on the label for all crops.

The proposed registration approval for isocycloseram, released in May, was an improvement over the initial ban proposed by EPA, but still severely and unfairly restricts aerial applications. EPA proposed to approve aerial applications of isocycloseram for only corn, soybean, potatoes, and cotton. However, for corn and soybean, aerial applications would only be allowed in a limited number of states. To make matters worse, the top producing corn and soybean states were not on the list, meaning aerial applications of isocycloseram would not be allowed on corn and soybean in the states where they would likely be needed the most. For corn, aerial application of isocycloseram would only be allowed in CO, KS, NE, OK, and TX; for soybean, aerial applications would only be allowed in AL, AR, GA, LA, MS, MO, NC, OK, SC, TN, and TX.

As an additional setback, EPA proposed buffer zones for aerial applications next to aquatic areas that were not wind-directional. This would result in the areas being completely off limits for aerial applications of isocycloseram. This goes against numerous registration review decisions and EPA’s endangered species strategies, which all recognize drift only moves downwind and buffer zones are only needed when the wind is blowing towards the sensitive area. Furthermore, because the registration for isocycloseram began before EPA changed its policy to use the Tier 3 AgDRIFT model, the risk assessments for isocycloseram were conducted using the inaccurate Tier 1 AgDRIFT model.

NAAA comments on isocycloseram focused on pointing out how important aerial application is for corn and soybean production in many states beyond the limited list from EPA. NAAA also questioned why drift mitigations from the recently released insecticide strategy, and used for the proposed registration of isocycloseram, would be sufficient for protecting endangered species in some states but not in others. And NAAA once again pointed out that drift cannot move upwind, so using a permanent buffer zone to protect aquatic areas offers no additional protection than a wind directional buffer zone. NAAA also pointed out that EPA should re-conduct their ecological risk assessments using the Tier 3 AgDRIFT model.

NAAA will continue to follow the registration process for isocycloseram and fight for aerial application to be allowed on all crops and in all states.

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Decades of Dedication: FAA Recognizes NAAA Member Jim Bartholomew

Pictured (L to R): John Bartholomew (son), Jim and Dorie Bartholomew, and Mike Bartholomew (son)

Last week NAAA Member Jim Bartholomew, the long-time manager of Iowa’s Storm Lake Municipal Airport, was honored by the Federal Aviation Administration (FAA) with the Wright Brothers Master Pilot Award.  The award recognizes pilots with over five decades of safe flight operations and dedication to aviation excellence. His wife, Dorie, was also given the Wright Brothers Master Pilot spouse recognition award, which is a recognition that a pilot’s long career in aviation often requires significant dedication and support from their spouse. The pin she received is similar in design to the one awarded to the pilot. Bartholomew also received the Charles Taylor Master Mechanic Award, a lifetime achievement honor awarded to certified mechanics with more than 50 years of exemplary service. Receiving both awards is an extraordinary accomplishment. Bartholomew is now one of only about a dozen individuals in the U.S. to earn both honors.

Bartholomew has been a cornerstone of the local aviation community in his hometown, Storm Lake, Iowa. His leadership and technical expertise have made a lasting impact on the Storm Lake Municipal Airport and the broader ag aviation industry. Bartholomew’s dual recognition by the FAA is a testament not only to his technical skill and dedication, but also to a lifelong passion for flight and service to the aviation community.

Congratulations to Jim Bartholomew on this extraordinary milestone and a lifetime devoted to aviation.

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NAAA Ag Aviation Expo Hotel Room Block Open

The NAAA hotel room block is now open for the 2025 Ag Aviation Expo at the Atlantis in Reno, Nov. 17-19. The Atlantis has undergone extensive renovations in all sleeping rooms and several restaurants in the hotel.

All events will take place at the Atlantis or Reno-Sparks Convention Center, which are connected via a skywalk.

Attendees need to stay in the NAAA room block. We get the best hotel room rates for our attendees, and if the NAAA hotel block is not filled, we cannot offer great rates for future years!

As you plan your Reno trip, please note that two safety sessions will take place on Saturday, Nov. 15. The sessions will be the Flying in the Wire & Obstruction Environment Course and Turning an Ag Airplane Safely Course, taught by Fran de Kock. Additional details and times of each session will be available soon.

Atlantis Hotel Reservations
3800 S. Virginia Street, Reno, Nevada 89502
Hotel Phone: (775) 825-4700

The Atlantis resort fee is waived for attendees and exhibitors who book in the NAAA room block ($40 savings per night).

  • Reservations: Book your room online here or call (800) 723-6500 and identify National Agricultural Aviation Association Convention for the discounted room rate. The Atlantis charges a one-room night fee per room booked to hold the room(s). A refund is provided if the room is cancelled 48 hours or prior to the arrival date.
  • Rate: $139/night
  • Room block deadline: October 30, 2025

NOTE: No one from (or on behalf of) the hotel or NAAA will contact you to book a hotel room. NAAA recommends that you make your own hotel reservations using the information that we provide to you. Do not book a room with any company that calls you directly. You may also receive spam emails to purchase lists from NAAA; this is spam and NAAA does not solicit selling lists of attendees/visitors.

Details for the 2025 Ag Aviation Expo

  • Dates: Nov. 17-19 (Flying in the Wire and Obstruction Environment and Turning an Ag Airplane Safely Courses will take place Nov. 15)
  • NAAA Hotel Room Block: Open
  • Exhibit Booth Sales: Aircraft and large booth space now open. 10×10 and 10×20 booth sales open July 10 at 12 p.m. ET. Contact Lindsay Barber for large booth space.
  • Attendee Registration Open: July
  • Never been to Reno? Learn more here.
  • Flying Into Reno: Reno-Tahoe International Airport (RNO) has eleven airlines providing more than 120 daily departures and arrivals.
  • Flying your own aircraft: Visit www.renoairport.com/general-aviation/. NAAA recommends Stellar Aviation FBO, and we’ll have more details about specials as we approach the expo dates.

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NAAA Comments on Petition for Fixed-Wing Drone BVLOS Part 137 Operations 

Last week, NAAA submitted comments on a petition from Pyka Inc. (Pyka) to amend their operational exemption for the Pyka Pelican uncrewed aerial application system (UAAS). The Pelican is unique as a fixed-wing aircraft with a 38-foot wingspan, 80 MPH working speed and 1,320-pound gross weight. The petition seeks amended relief from 14 CFR to:  

  1. Conduct UAAS operations beyond visual line-of-sight (BVLOS) of the pilot-in-command (PIC) while employing a dedicated visual observer (VO) who will maintain VLOS with the UAAS and surrounding airspace for the duration of each operation; and 
  2. Operate closer than 500 feet to non-participating persons, vehicles and structures to treat the entirety of a field, including edges which border roads. 

NAAA’s comments were primarily directed toward the proposed “BVLOS with a VO” operations, highlighting concerns for the safety of crewed aerial application operations occurring in adjacent fields: 

The risk profile for the Pelican is very different from other UAAS which can takeoff, operate and land while remaining over controlled-access property. The Pelican must take off and land from an adjacent area, make transient flights to and from the application site and conduct turn-around maneuvers outside the field boundary between each swath. It is also significantly larger and faster than other UAAS, while being less maneuverable. 

Regarding the operational footprint with time spent in airspace outside the application site, NAAA pointed out that the larger footprint (in both area and altitude) presents a much greater likelihood of encounter with a crewed agricultural aircraft than would be presented by a vertical takeoff and landing (VTOL) UAAS, particularly during busy periods of the growing season. This hazard, coupled with the significantly higher working speed of the Pelican, makes it imperative that the PIC be able to rapidly identify airspace conflicts and give way to crewed aircraft. The proposed employment of a VO who will communicate the conflict and relay the appropriate mitigation instructions to the PIC will introduce a delay and disconnect for which NAAA finds additional risk mitigation necessary. Ultimately, NAAA maintains that BVLOS operations of any type should require the use of a detect and avoid (DAA) system which is certificated or verified by FAA as effective against both cooperative (ADS-B out equipped) and non-cooperative crewed agricultural aircraft operations. 

NAAA expressed concern, separate from the VO’s ability to monitor the surrounding airspace, that the PIC/VO will be adequately positioned to fulfill the §137.37 obligation to not create a hazard to persons or property on the surface. This ability to see persons on the surface is also critical in complying with the EPA’s Application Exclusion Zone (AEZ) Rule.  

NAAA also commented in contingent support of the requested relief to operate closer than 500 feet to non-participating persons, vehicles and structures in alignment with §137.49. The contingency would be that FAA mitigate the increased risk borne from the UAAS having to make turns farther into the airspace over adjacent fields and should also reflect demonstrated ability to comply with the AEZ Rule. 

You can view NAAA’s comments here. 

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FAA Updates Guidance on Part 137 Certification Process 

The FAA has released internal guidance, Notice 8900.735, which updates its process for considering applications for certification under Part 137 (amongst others). FAA certification offices will use the updated process described in this notice to conclude the certification process if an applicant does not meet applicable requirements for certification. Note that this does not apply to uncrewed-only operations. 

The applicant and FAA must first establish a Schedule of Events (SOE) for the certification process, agreeing on a timeline. If at any point the applicant fails to meet the agreed-upon timeframes contained in the SOE, or any of the below circumstances are identified by FAA at the time they are necessary for certification to continue, the application may be withdrawn: 

  • The applicant has not provided the personnel necessary to complete the certification process due to, for example, a delay in hiring personnel, a delay in assignment of personnel, or an inability to retain personnel. 
  • The applicant does not have the aircraft or equipment necessary. 
  • The applicant does not have the facilities necessary. 
  • The applicant fails to respond to requests within the timeframe communicated by the certification office, provides a late and/or inadequate response, or submits documentation that does not meet the applicable 14 CFR certification requirements. 

The FAA will provide applicants 15 calendar days to respond to notices of corrective action needed. If no response is received within that timeframe, the application may be considered withdrawn. 

If an applicant has demonstrated that they are unable or unwilling to resolve or take appropriate courses of action on regulatory requirements, an application may be referred for formal denial. This can be appealed at the applicant’s discretion.  

This change in FAA policy is another move to address the backlog of applicants on the nationwide Certification Services Oversight Process (CSOP) list. Once an application is either withdrawn or denied, FAA certification offices will move on to the next application on the CSOP list. It is therefore more important than ever for those seeking a Part 137 certificate to submit a complete initial application and maintain close, timely contact with their Flight Standards Office throughout the certification process. Be sure to check out NAAA’s Guide to Starting a Part 137 Operation for more information. 

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Superseding AD Issued for R44 Flex Plates and Clutch Yokes 

The FAA has issued a new airworthiness directive (AD 2025-11-07) for Robinson R44 and R44 II helicopters, superseding AD 2024-19-11 which required visually inspecting a certain flex plate assembly and certain clutch shaft forward yokes, including each flex plate bolt, and depending on the results, taking corrective actions. This new AD requires the actions of the previous AD but clarifies that the alternative inspections are repetitive and adds a particular paint remover option to use when performing those alternative inspections. 

You can find this AD here; it is effective July 11, 2025. 

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AD Issued for AStar Cargo Swing Frame 

The FAA has issued a new airworthiness directive (AD 2025-10-01) for Airbus Helicopters Model AS350B2, AS350B3 and EC130B4 helicopters. This AD was prompted by reports of broken cargo swing frames and the determination to change an existing repetitive inspection threshold. 

The European Union Aviation Safety Agency issued EASA AD 2023-0107 dated May 26, 2023 (corrected June 2, 2023) after finding that the interval for repetitive inspections of the swing cargo installation, currently defined in operating hours in the applicable aircraft maintenance manual, must instead be based on sling cycles. 

FAA’s AD directs compliance with the EASA AD, except that the procedures must be accomplished by persons authorized under 14 CFR 43.3 and the only corrective action approved is to replace the cargo swing frame if an identified defect is found. 

You can view the AD here; it is effective July 11, 2025. 

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In Case You Missed Last Week’s NAAA eNewsletter

Click here for the June 5, 2025 eNewsletter to read:

  • NAAA Press Release Highlights Success of Aerial Fungicide Applications on Late-Season Corn
  • NAAA Urges Department of Commerce to Leave Aircraft Engines and Related Parts Free of Tariffs
  • Second Annual Tylor Johnson Golf Tournament Raises Funds for Pilot Safety
  • Ag Aviation Expo Sponsorships Available: Boost Your Company’s Brand!
  • AD Issued for AStar/TwinStar
  • 2026 NAAA/Syngenta Leadership Training Program Applications Accepted Until July 18, 2025

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