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Table of Contents
- NAAA Fights for Aerial Applications of Dicamba on Dicamba Tolerant Crops
- MAHA Health Strategy Report Lowers Volume About Pesticide Concerns
- GRASSROOTS ALERT: FAA Proposed Part 108 – Drones Given Right of Way Over Manned Aircraft – Your Comments Needed
- NAAA Operator Member Liam Zahm Interviewed by Farm Progress on the Future of Hybrid Aerial Application Operations
- Boost Your Safety Skills Around Wires and Proper Aircraft Maneuvering; Sign Up for NAAA’s Ag Aviation Safety Training Day Set for Nov. 15 at the Ag Aviation Expo
- FAA Releases Airworthiness Concern Sheet for Fuel Additives in H80/M601 Engines
- AD Issued for MD Helicopters 369 and 500 Tail Rotor Pedal Support Brackets
NAAA Fights for Aerial Applications of Dicamba on Dicamba Tolerant Crops
Last week NAAA submitted comments to the EPA opposing the prohibition of aerial applications of three low-volatility formulations of dicamba on dicamba tolerant (DT) soybean and cotton varieties. The saga of DT crops began in 2016 when EPA first registered the newer low volatility dicamba products for over-the-top applications on DT crops. Since then, registration of these products for use on DT crops has been terminated twice by court action, the last time in early 2024. One thing that has been consistent in the registration history of DT crops is that aerial application has been prohibited since the very beginning.
The latest action by EPA and the three registrants with formulations for DT crops – Bayer, BASF, and Syngenta – came in late July of 2025, when EPA proposed to once again register the uses of dicamba on DT cotton and soybean. As in all prior registrations, this proposal prohibited aerial applications. Based on success NAAA has had working with EPA on recent Endangered Species Act strategies, NAAA decided to submit comments to EPA opposing the aerial ban.
NAAA’s comments, which can be read here, focused on two main points. The first dealt with the speed of aerial applications over all other types of applications, and why this speed is critical for making both successful and safe dicamba applications on DT crops. The labels for the three dicamba products are very restrictive regarding wind speed, temperature, and inversions. NAAA pointed out that these restrictions severely limit the application hours available to a grower if they are forced to only use ground application. In many cases they risk ineffective weed control and the further spread of herbicide resistant weeds.
The second point was proposed requirements for making aerial applications of dicamba on DT crops. These included a larger droplet size, a boom length restricted to 50% of the wingspan or rotor diameter, and a 400-foot downwind buffer for protection of sensitive areas. NAAA used AgDRIFT to point out that these suggested aerial requirements result in estimated drift just slightly greater than the estimated drift from ground rigs. The success of NAAA’s request is uncertain; what is certain is that growers and the environment always benefit when fast and timely pesticide applications are available from ag aircraft.
MAHA Health Strategy Report Lowers Volume About Pesticide Concerns
The Make America Healthy Again Commission (MAHA), a presidential advisory body focused on childhood chronic diseases in the U.S., released its health strategy report earlier this week lowering the volume about health effects of certain pesticides compared to its health assessment report released in May. The MAHA spring report was an assessment of health conditions and stated that the U.S. needs more government (non-industry funded) pesticide studies and mentioned some chemicals by name, including pesticides such as atrazine and glyphosate. The report highlighted concerns with industry lobbying and the industry’s ability to fund biased research. Many of the claims made in the assessment were correlative in nature rather than causative, or were tangential, equivocal, or seriously antiquated.
The Make Our Children Healthy Again Strategy report released Tuesday was like a draft version that was circulated in mid-August. It calls for evaluating the health effects of pesticides but takes no immediate steps to curb the use of glyphosate. It recognized that pesticides are important tools for farmers to grow healthy, affordable, and abundant food and acknowledged how EPA’s transparent, science and risk-based regulatory system is key to a safe and sustainable food supply. Much work was done by the agricultural industry to educate the MAHA Commission between the release of its spring assessment report to its strategy report just released. NAAA was heavily involved in this education process, including actively participating in field day education events and White House meetings over the summer, including direct discussions with President Trump’s agricultural advisors and with Calley Means, senior adviser to HHS Secretary Robert F. Kennedy Jr., and MAHA initiative advocate.
GRASSROOTS ALERT: FAA Proposed Part 108 – Drones Given Right of Way Over Manned Aircraft – Your Comments Needed
The FAA has recently released its proposed Part 108 which would enable routine beyond visual line of sight (BVLOS) operations for unmanned aircraft systems (UAS) operating below 400 FT AGL. If adopted into a final rule as written, this would severely compromise the safety of manned aerial application operations. You can review the full Notice of Proposed Rulemaking (NPRM) and/or FAA’s Fact Sheet, but NAAA has read it cover to cover and there are two headline takeaways:
- UAS Have Right-of-Way. Part 91 would be amended to give Part 108 UAS right-of-way over all other aircraft unless that other aircraft is broadcasting ADS-B or electronic conspicuity (EC). EC is a yet to be approved/standardized anonymous type of ADS-B to be available at an unknown date as a portable or installed unit.
- Shielded Areas. Part 108 would establish shielded areas wherein UAS do not have to yield right-of-way to any aircraft, regardless of ADS-B or EC. These shielded areas are defined as areas where no manned aircraft are expected to operate, including areas within 50 feet of powerlines and substations, railroad tracks, bridges and pipelines. FAA contends that there is only a “remote possibility” of an agricultural aircraft operating in a shielded area, and thereby a low collision risk with a UAS operating there.
If this sounds alarming to you, you are not alone and your voice is needed now. The FAA is seeking public comment on this NPRM through October 6, 2025. NAAA will be submitting comments – you can view NAAA’s Draft Comments to get a feel for how the association is responding. However, what is truly needed now is your individual, unique comments emphasizing your personal experiences to inform FAA of the extreme danger posed by the proposed shielded areas. This could be as short as a paragraph or as long as you find necessary. NAAA urges you to include the following in your comments:
- Scope of Your Operation. Specify geographical area, acres treated, crops treated, number of farmer customers, etc. Add any specific data that demonstrates further societal/economic value of your operation.
- Your Operations in Shielded Areas. Explain and quantify the regularity with which you fly in the proposed shielded areas (i.e. within 50 feet of powerlines and railroad tracks). Estimate the number of times you fly within 50 feet of a wire per day during the application season (considering each individual pass over/under/along wires). Estimate by how many feet you regularly clear a wire when descending into or climbing out of a field.
- Your Difficulty in Spotting Drones. Explain how the unique challenges of ag aviation, including low-altitude obstacle avoidance and focus on the application itself, make it impractical to be on the lookout for drones in shielded areas.
There is a LOT more to this NPRM than just shielded areas, but NAAA finds this issue to be of paramount concern to the lives of aerial applicators. Please consider commenting – the only way to effect change is for aerial application pilots and operators to comment in great numbers with fact-based arguments. You can submit your comments here, either by directly entering text or uploading a document. Be sure to reference Docket Number: FAA-2025-1908 in your comments.
Please do not copy and paste NAAA’s Comments – FAA gives credibility to thoughtful, original comments and assigns less weight to duplicative form letters. Use your own words and experiences to inform FAA of the realities of manned aerial application and make them understand the impact that these new regulations would have on your safety as a pilot and/or on the safety of your pilots as an operator.
NAAA is working diligently with other government agencies, industry associations and coalitions to also comment in representation of the aerial application industry’s real concerns with this NPRM. By educating and leveraging influential voices ranging from agricultural commodity groups and agencies to general aviation organizations and transportation safety agencies, NAAA will ensure that the safety concerns of manned aerial application are heard.
NAAA Operator Member Liam Zahm Interviewed by Farm Progress on the Future of Hybrid Aerial Application Operations
NAAA operator member Liam Zahm, of Zahm’s Aerial Enterprises in Marne, Michigan, was recently interviewed by Farm Progress on his perspective of applying chemicals with manned and unmanned equipment. At just 25 years old, he brings a young perspective on new technologies entering the industry.
Zahm sprays with a 1977 Grumman Ag Cat and a DJI T40 drone. In the article, Zahm discusses performance metrics, application efficiency, safety, economic factors, as well as the pros and cons of the aircraft and drone for aerial applications. Like many other ag pilots who operate hybrid equipment, Zahm agrees that drones are a tool to use in smaller fields and for certain other application conditions.
Zahm also touches on who should and shouldn’t operate a drone. “The industry suffers from knowledge gaps – often amateurs teaching amateurs without consulting experienced agricultural aviation professionals,” he says.
Zahm is also the latest generation of a fourth-generation farming family of 2,000 acres of corn, soybeans and wheat while raising 200 head of beef at K&H Grain, alongside his father and uncle. Zahm participated in the NAAA/Syngenta Leadership Training Program in February 2025. Read the Farm Progress article here. The publication is distributed to over 80,000 farmers in North America.
Boost Your Safety Skills Around Wires and Proper Aircraft Maneuvering; Sign Up for NAAA’s Ag Aviation Safety Training Day Set for Nov. 15 at the Ag Aviation Expo
Saturday, November 15, is a day dedicated to safety courses for ag pilots before kicking off the Ag Aviation Expo. Learn the essential skills needed to safely operate an aircraft in an environment of wires and obstructions and how to turn an ag plane safely.
After three years of popularity, NAAA and NAAREF are bringing back the Flying in the Wire and Obstruction Environment, acclaimed by professional aircraft operators worldwide and will be the first session. The Tylor Johnson Legacy Foundation and the Johnson Family are graciously sponsoring the registration fees of each operator and pilot attending this year’s course.
The course will begin at 8 a.m. on Nov. 15 and will be taught by aviation safety experts from Utilities/Aviation Specialists Inc., a unique group of aviation safety practitioners who provide safety auditing, specialized training, installation of safety management systems and technical aviation consulting. They provide mission-specific expertise in specialized applications that require skill sets above those found in most routine transport operations. Both fixed-wing and helicopter pilots will benefit from this course. It gives low-altitude aviators the essential skills needed to safely operate an aircraft in wire and obstruction environments. Learn how to identify signs of wires, why ag aviators hit wires they already knew were there, and how to avoid obstructions going forward. In 2024, there were a total of 11 wire strike ag aviation accidents, two of those accidents were fatal.
The second course, beginning at 1:15 p.m., will feature Fran de Kock of Battlefords Airspray in Canada, teaching the Turning an Ag Airplane Safely Course, which will cover in detail how to safely turn a fixed-wing ag aircraft. The class is intended for all ag pilots regardless of their experience level. It will review the basics of an ag turn, how to properly train to make safe ag turns and how to make ag turns in different conditions. The risks of a turning accident and how to manage those risks will also be thoroughly covered.
NAAA and NAAREF thank the Johnson Family and the Tylor Johnson Legacy Foundation for providing funding for ag pilots to attend this essential training. Tylor Johnson was a third-generation aerial applicator whose life was cut short after his airplane struck a guy wire. It was a harsh reminder of the dangers aerial applicators face daily. In the wake of this tragedy, the Tylor Johnson Legacy Foundation was established to honor Tylor’s memory, advocate for increased safety measures that protect other pilots, and continue his legacy of care and commitment to the community.
These two courses may very well save your life; don’t miss this day dedicated to two important topics. Lunch will be provided to pre-registered participants. While registration fees are waived for the courses due to these generous sponsorships, advance registration is still required at AgAviation.org/ag-aviation-expo/registration/. If you do not pre-register, we may not have a seat or lunch for you. Sponsored by Tylor Johnson Legacy Foundation, Old Republic Aerospace & AssuredPartners Aerospace.
FAA Releases Airworthiness Concern Sheet for Fuel Additives in H80/M601 Engines
The FAA has released an Airworthiness Concern Sheet (ACS) for certain GE Aviation Czech (GEAC), formerly Walter Engines, models including the H80 and M601D-11. This ACS is a request for information to operators of aircraft with these engines installed, specifically on use of lubricity improver additives (LIA) in fuel.
Earlier this year, the European Union Aviation Safety Agency (EASA) published EASA AD 2025-0022. This AD identified the above referenced engine models Fuel Control Units (FCU) as having the potential to have delayed or no response to power level inputs due to fuel deposits in the FCU internal valves which increases friction on mating surfaces. This can result in Loss of Power Control (LOPC) events and unscheduled removal of the FCU for maintenance. The EASA AD mandates (in its jurisdiction) compliance with GEAC Service Bulletin SB-000469 Revision 1, dated March 2024, requiring the application of LIA to the aircraft fuel tanks every 100 flight hours to avoid potential LOPC and improve FCU reliability.
While FAA currently has no such requirement for use of LIA, it is seeking information from operators of these engines, including:
- Information on the US fleet of affected engines/aircraft, such as number of engines, current operators and N-registered aircraft.
- Availability of LIA to include types and concentrations.
- Whether sufficient information is available at fueling stations to accurately dose LIA for on-wing fueling operations.
- Whether the GEAC SB is being followed, and if so, whether there has been any adverse effects or problems from following the SB, such as corrosion in affected FCUs.
- If the GEAC SB has not been followed, have there been any issues regarding FCUs, such as LOPC.
If you would like to provide information to FAA regarding this issue, see the ACS for full details and contact information.
An ACS is neither regulatory nor mandatory. It requests feedback from the aviation industry on a voluntary basis and is intended to increase communications between the FAA and the aviation industry so that input from industry can be used to inform FAA’s analysis of the safety issue. For this ACS, FAA has not yet decided if a corrective action will be necessary or what it might be, but it could involve an Airworthiness Directive (AD) or a Special Airworthiness Information Bulletin (SAIB). The FAA’s final determination will depend in part on the information received in response to this ACS.
AD Issued for MD Helicopters 369 and 500 Tail Rotor Pedal Support Brackets
The FAA has issued a new Airworthiness Directive (AD 2025-17-11) for certain MD Helicopters Model 369 and 500 helicopters. The AD was prompted by multiple reports of cracked magnesium tail rotor (T/R) pedal support brackets.
This AD requires repetitive inspections of:
- Magnesium cast T/R pedal support brackets (P/Ns 369A7505-7, 369A7505-8, 369A705-14, 369A7505-15); and
- Aluminum cast T/R pedal support brackets (P/N 369N2640-1, 369N2640-2)
These repetitive inspections must occur according to the following time-in-service (TIS):
- Within 25 hours TIS of AD effectivity, and thereafter at intervals not to exceed 100 hours TIS, conduct a visual inspection using a 10X power magnification glass, mirror and flashlight for cracks and corrosion; and
- Within 50 hours TIS of AD effectivity, and thereafter at intervals not to exceed 300 hours TIS, conduct an eddy current, dye penetrant or fluorescent penetrant inspection for cracks.
If cracks or corrosion are found in any inspection, the pedal support bracket must be replaced with an aluminum cast pedal support bracket. That replacement bracket will still be subject to the repetitive inspections of this AD. In addition, this AD prohibits installation of any affected magnesium cast pedal support bracket on any helicopter.
This AD is effective October 10, 2025.
In Case You Missed Last Week’s NAAA eNewsletter
Click here for the September 4, 2025 eNewsletter to read:
- GRASSROOTS ALERT: Your Comments to FAA are Urgently Needed to Oppose Requiring Manned Aircraft Provide Drones Right of Way
- In PBS Interview NAAA Member Neil Wicke Highlights Complementary Role of Manned Aircraft and Drones in Agriculture
- Registration Open for 2025 NAAA Ag Aviation Expo in Reno
- 2026 NAAA Membership Renewal Now Open
- Superseding AD Proposed for AStar Vertical Fin Spar
- AD Issued for Hiller UH-12E Main Rotor Driveshaft