NAAA Comments Opposing UAAS Exemption from Filing NOTAMs

This week, NAAA submitted comments on a petition for exemption from an uncrewed aerial application system (UAAS) operator, seeking relief from the requirement to file Notice to Air Missions (NOTAMs) prior to each operation. 

The petitioner, in justifying their request, stated that the NOTAM filing requirement will cause them to miss out on spontaneous work and profits. The supporting documentation for the petition was locked and marked confidential, thus providing NAAA and the public no transparency on how they plan to mitigate the increased risk associated with the proposed relief. 

NAAA expressed concern that removing the NOTAM filing requirement will remove one of the few remaining layers of safety in place to prevent a mid-air collision with a crewed Part 137 aircraft. It would mean that pilots will have to rely more heavily on remote pilots to uphold their duty to see and avoid crewed aircraft. 

Further, NAAA cited the iterative lowering of the bar for entry to UAAS operations as discussed in last week’s eNewsletter. The takeaway from that article is that the UAAS certification process, in its current state, can be easily misused, certifying individuals with little knowledge of, and vested interest in, conducting safe airspace operations.  

Finally, the petitioner stated that the requested relief should be granted, in part, on “significant cost savings achieved by transitioning from traditional manned aerial resources to UASs.” While no evidence was publicly provided to support this claim, NAAA expressed concern that this statement was put forth as a core justification for a reduction in safety. 

You can view NAAA’s comments here.