NAAA Comments on UAAS Petition to Operate From Moving Vehicle

Last week, NAAA submitted comments on a petition from L&M Road Services LLC to amend their exemption to allow commercial Part 137 uncrewed aerial application system (UAAS) operations from a moving vehicle. While not explicit in the petition, NAAA’s interpretation of the intended operations is that of roadside right-of-way pesticide applications. 

In an earlier request for information to the petitioner, FAA raised a multitude of concerns with operating UAAS from a moving vehicle. NAAA echoed several of these concerns through a lens of risk mitigation to crewed aerial application operations. With a dynamic operating environment, there is an increased risk to loss of visual line of sight (VLOS) when traveling through areas with trees, buildings and other obstacles. NAAA pointed out that the intended operations profile would abut numerous fields and other areas commonly trafficked by crewed aerial application aircraft. 

Citing data from NASA’s Aviation Safety Reporting System (ASRS) and NAAA’s 2025 End of Season Operator Survey, the association expressed concern that, while the proposed UAAS operations would introduce crewed aerial applicators to additional exposure to the hazard of a midair collision with UAAS, no additional risk mitigations were proposed. Further, NAAA pointed to the reliance of pilots on identifying UAAS support trucks/trailers during reconnaissance to be aware of the presence of UAAS in the vicinity. As UAAS are nearly impossible to see in-flight, the proposed operations from a moving vehicle would eliminate this mechanism and further hinder the ability for crewed aircraft to avoid collisions with UAAS. 

The remainder of the petition made several unfounded claims disparaging crewed aerial application operations. NAAA felt compelled to address these claims accordingly. You can read NAAA’s comments on this petition for the full details.