GRASSROOTS ALERT: Your Comments to FAA are Urgently Needed to Promote Traffic Deconfliction, Anonymity and an Aerial Applicators’ Right of Way in FAA’s Reopening of the Comment Period for UAS BVLOS, Specifically to Gather Information on ADS-B/EC

The FAA’s 14-day reopening of its proposed rule allowing unmanned aircraft systems (UAS) to operate beyond visual line of sight of the UAS operator closes on February 11, 2026. The purpose of reopening the rule is for the agency to gather more information on the feasibility of using electronic conspicuity (EC) devices as a safety mechanism to deconflict collisions between crewed and uncrewed aircraft. EC acts as a more portable, less expensive, reduced-range ADS-B device that also provides anonymity to its user.  

Details on the comment period may be found by clicking here. NAAA has developed these draft comments supporting the use of EC as a more portable, less costly, anonymous tool to help in air-to-air traffic deconfliction.  NAAA is also emphasizing in its comments that use of these devices only works to avoid traffic deconfliction if all aircraft—manned and unmanned—are using this technology in the low-altitude airspace, including in shielded areas, and if the unmanned aircraft gives right of way to the manned aircraft. NAAA suggests agricultural aviation operators also comment to the FAA on the new comment period.

The FAA determined to open the comment period again after a series of meetings earlier this month with manned and unmanned organizations, including NAAA, where the FAA stated it heard “general support for ADS-B or alternate EC devices, though opinions on specific requirements varied…Some industry representatives raised concerns about the practicality of ADS-B for all environments, particularly at low altitudes and in complex operating conditions.” Click here for more about the January 6, 2026 meeting.

To comment on the rule, click here, then click comment and follow the prompts to either directly write comments or upload them. Please reference: Docket Number: FAA-2025-1908 in your comments. Again, a draft of NAAA’s comments may be found by clicking here.

Follow the NAAA format in drafting your own comments, such as using your own personal or company letterhead. PLEASE DO NOT COPY AND PASTE NAAA’s COMMENTS VERBATIM AND USE THEM AS YOUR OWN! Regulatory agencies give credibility to thoughtful, original comments and assign less to no weight to duplicative form letters. When drafting your comments, please emphasize the following points:

  • Personalize your comments and elaborate on the geographical area in which you treat crops aerially, including acres treated, crops treated, number of farmer customers, value you contribute to agricultural production and public health protection, etc. in your local area (see pages 1-2 of NAAA’s comments on the scope, value and importance of the aerial application industry).
  • Comment directly on the questions listed and emphasize how an EC system used for traffic deconfliction, due to its cost and anonymity would be a better option so to avoid issues such as bogus litigation and other unnecessary litigious situations you may have encountered.
  • See response to question number 7 and the point that being detected is predicated on all UAS being properly equipped to detect manned aircraft in all low-altitude airspace environments, including shielded areas.

If you have questions while working on your response, please reach out to NAAA for assistance.