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National Agricultural Aviation Association

NAAA Comments on Part 137 UAS Petition to Remove Medical Certificate Requirements

July 25, 2024

NAAA recently submitted comments on a petition from Veteran Drone Services LLC seeking to allow remote pilots operating multiple UAS weighing greater than 55 pounds used for agricultural operations to hold a driver’s license in lieu of a third-class medical certificate.

The petition cited previously granted exemptions which permitted this relief, however, the exemption which originally set that precedent was for UAS less than 55 pounds (11213) and expired in 2017 and it only permitted use of a driver’s license in lieu of an airman medical certificate when combined with a pilot certificate. The other cited exemption which permitted this for UAS greater than 55 pounds (17790) and that exemption was amended in 2020 to again require an airman medical certificate.

The petitioner’s stated intent of the needed regulatory relief was to overcome the difficulty some veterans have with obtaining a third-class medical certificate due to PTSD or other conditions.

While acknowledging that it should be a shared goal among all Americans to aid veterans in their civilian reintegration and employment, NAAA asserted that it would be improper for FAA to consider this in the disposition of the petition. Put simply, granting this relief would set a precedent from which all future Part 137 UAS Exemptions would follow.

NAAA’s comments in opposition to this petition were succinct: “It is incumbent upon all participants in the [Part 137] airspace to maintain its safety, so that each may rely upon it. Ensuring pilots hold an appropriate FAA medical certificate is one of the pillars that support this trust in NAS safety.”

You can view NAAA’s Comments here.

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  • About
    • About Ag Aviation
      • Industry Facts, Environmental Benefits and FAQs
      • The Industry’s History
      • Ag Aviation Security
    • Board & Officers
    • NAAA Staff
    • NAAA Member Code of Conduct
    • State and Regional Associations
    • NAAA Professional Operating Guidelines
    • Related Entities (Industry Links)
    • Help – Knowledge Base
  • Ag Aviation Expo
    • Expo Details, Info & Overview
    • Schedule
    • Registration
    • Travel and Hotel
    • Exhibiting
    • Sponsors
    • Wire & Obstruction Course
    • Kickoff Breakfast
    • General Session
    • Live and Silent Auctions
    • Awards
  • Career
    • Become an Ag Pilot / Operator
    • Job Board
    • Flight Schools
    • Scholarships
    • Resources
      • NAAA Professional Operating Guidelines (POG)
      • Agricultural Airman Guidelines (AAG)
      • NAAA’s Guide to Starting a Part 137 Operation
      • National Aerial Applicator’s Manual
      • AC 137-1B Certification Process for Agricultural Aircraft Operators
      • 14 CFR Part 137 Regulations
  • Membership
    • Join NAAA / Renew
    • Member Benefits
    • Membership Categories
    • Health Insurance Benefits
  • Education
    • PAASS
    • CAA (formerly C-PAASS)
    • Fly Safe Messages
    • Operation SAFE
    • Online Courses
    • NAAREF & Donors
    • Ag Aviation Accidents
    • Leadership Training Program
    • Scholarships
    • More
  • Communications
    • Agricultural Aviation Magazine
    • NAAA eNewsletters
    • NAAA 365 App
    • Media Relations Kit
    • Media Center
    • NAAA Headlines
    • Industry Surveys
    • 100th Anniversary
    • NAAA’s 50th Anniversary Video
  • Policy
    • Environmental Issues
    • Tax Issues
    • Transportation Issues
    • Towers
    • Uncrewed Aircraft Systems
    • Wind Turbines
    • AgAv PAC
  • Calendar
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  • Find an Aerial Applicator
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