Checklist After an Ag Pilot – UAS Encounter
If you or a pilot of yours has a near-miss encounter with a UAV or, worse, is hit by one, undoubtedly one of the main things going through your mind after the initial shock subsides is what to do and who to call to report the encounter. NAAA has prepared a handy checklist of steps to take after a UAV encounter. Follow these steps.
1. Inform Local Law Enforcement
When informing local authorities about the unsafe operation of a UAS, it is important to contact the enforcement body with jurisdiction over the area where the offense occurred. Call them immediately after the incident. Remember, local law enforcement agencies are not aviation experts, so be sure to provide them with ample and accurate information on why the operation was unsafe or illegal.
2. Report It To The FAA National Safety Hotline
After safely landing, you should report the incident by calling the FAA Safety Hotline at 1-800-255-1111 or online at hotline.faa.gov. This contact is a single avenue for anyone from FAA employees to concerned citizens to file a report regarding violations of federal aviation regulations or the safety of the national airspace.
3. Call Your Local Flight Standards Office (FSO)
Your local Flight Standards Office (FSO, formerly called FSDO) consists of aviation officials who should be more intimately familiar with your airspace. Make sure the person taking the report understands you believe a violation of the FARs has occurred. However, due to personnel shortages it might take some time for an investigation to be completed.
4. File A NASA Aviation Safety Report
The primary purpose of a NASA aviation safety report is to collect data related to the national airspace to reduce aviation accidents and incidents. Your confidential and non-punitive report will go directly into the Aviation Safety Reporting System (ASRS), ensuring your experience will be used as data to contribute to aviation safety. The incident information can be recorded on the General Report Form for electronic submission, or the form can be printed for completion and mailing by U.S. mail.
5. Tell Other Pilots
Whether it’s through social media, message boards, email or word of mouth, let other pilots in your area know when and where the UAS was flying. While pilots should always maintain alertness when it comes to avoiding other aircraft and obstacles, highlighting your UAS encounter can help other pilots maintain some extra situational awareness when flying in the area the incident occurred should the UAS operator return to fly in that same area again.
6. Notify Local News Media And Ag Trade Press
Share your encounter and safety concerns with the local media to inform the non-piloting public of these same concerns. Perhaps this will remind some UAS operators of the need for caution around manned aircraft operating at lower altitudes. Notifying ag media about your UAS encounter will help get the story out to the ag community.
7. Inform Your Customers, Ag Retailers And Crop Consultants
A UAV encounter is a teachable moment. Let farmers, ag retailers and crop consultants in the area know about the incident, including when and where it occurred and what the UAS operator should have done as the ag pilot approached the same airspace. If you intend to notify them in writing, include NAAA’s UAS Safety Stuffer with the notice.
8. Contact Your Insurance Agent If …
In the event physical damage is done to your aircraft, contact your insurance agent. The company will ensure repairs are made to the aircraft in accordance with your policy. There is a possibility the insurance company could pursue action against the parties that may be liable for the loss.
In addition to the UAV encounter checklist, NAAA is always available for additional assistance in the event of a UAV encounter with an ag aircraft. Contact NAAA at (202) 546-5722.
Current Regulatory Overview
14 CFR Part 107 allows small (under 55 lb.) UAS to be operated commercially by pilots holding a Remote Pilot Certificate with a Small UAS Rating. Operating limits include a maximum groundspeed of 100 MPH and a maximum altitude of 400 feet AGL (lowered from 500 feet thanks, in part, to NAAA comments). Only visual line of sight (VLOS) operations of a single UAS are permitted, and all UA must yield right-of-way to manned aircraft. FAA may waive some of these rules if an applicant shows the waiver will not endanger the NAS or persons on the ground. Part 107 was amended in 2021 to allow operations over people and at night.
To fly a UAS that exceeds Part 107’s maximum weight, or to get relief from a rule that cannot be waived, an operator may petition for an exemption under 49 U.S.C. §44807. This allows FAA to decide case by case, based on risk, whether a given UAS can operate safely in the NAS. Most petitions are granted as a “summary grant,” using a materially similar prior grant as justification. FAA must publish a petition for public comment only if granting it would set a precedent. NAAA has commented on more than 100 of these petitions, in each case advocating for safety measures to mitigate the midair collision risk of UAS with manned ag aircraft.
In April 2026, FAA published its policy for implementing §927 waivers, a new authority from the 2024 FAA Reauthorization Act. These waivers run parallel to §44807 exemptions; they do not replace them. FAA may use §927 to waive any regulation for a UAS operation, even one not written as waivable. FAA says it will apply the same safety standard as it does for exemptions. However, §927 waivers do not require the petitioner to show a public benefit, do not require public notice of precedent-setting relief, and give the public no chance to comment. FAA will consider a §927 waiver when an operation has minimal impact, is a high-value limited use case, is an emerging use case (tied to Executive Order 14307, Unleashing American Drone Dominance), or raises other timing or safety considerations. The major concern for NAAA is lost transparency: relief that once required public notice and comment may now be granted without any opportunity for affected manned operators to weigh in. At least one pending BVLOS exemption petition (NUAIR, FAA-2025-0414) was withdrawn in July 2026 after the petitioner learned FAA would handle it through a §927 waiver instead.
UAS Collision Risk — Data and Research
Since 2016, NAAA has partnered with Mississippi State University’s (MSU) Raspet Flight Research Laboratory, part of FAA’s ASSURE UAS Center of Excellence, to build a nationally representative dataset of GPS flight logs from manned aerial application operations. NAAA members have donated more than 30,000 flight logs, and they continue to donate. The dataset documents how aerial applicators use the airspace: an average altitude of about 38 feet AGL across passes and turns, over roughly 24 million miles flown each year.
As a response to assertions that UAS could use “linear infrastructure masking” or “shielded areas” to operate freely within, NAAA has worked to demonstrate that this would pose an unmitigated collision risk with aerial application aircraft. In 2023, a University of North Dakota (UND) study combined the MSU logs with a survey of aerial applicators. It documented that manned aerial application aircraft routinely operate in close proximity to obstacles, such as power lines. The FAA-sponsored ASSURE A45 study (September 2024) found that ag aircraft clear power lines by 3 to 6 feet when climbing out and 10 to 15 feet when descending into a field.
Encounter data continues to accumulate. NASA’s Aviation Safety Reporting System (ASRS) issued an Alert Bulletin in September 2024 on the UAS near-midair collision threat in agricultural operations, and logged five such events involving ag pilots in 2024. In NAAA’s end-of-season operator surveys, the share of operators reporting an unsafe UAS encounter has risen steadily: 11% in 2023, 16% in 2024, and 20% in 2025. In February 2026, the Government Accountability Office (GAO) reported that 5 of the 37 NTSB drone investigations since 2006 involved a midair collision with a manned aircraft. GAO recommended that FAA develop specific plans, costs and milestones to make sure drones can communicate with, detect and avoid other aircraft.
Beyond Visual Line of Sight (BVLOS) Operations
While BVLOS operations are currently approved through Part 107 waivers or §44807 exemptions, the proliferation of UAS interests have held FAA’s foot on the accelerator in pursuit of normalizing BVLOS operations; that is to say, codifying regulations for how BVLOS operations can take place without waivers or exemptions.
NAAA’s concerns with BVLOS operations are an extension of its overall UAS concerns. Pilots cannot physically see UAS, UAS are prohibited from being electronically detectable to pilots and a collision with a UAS has a high likelihood to prove fatal for the pilot. Accordingly, NAAA has pushed hard on FAA to recognize this hazard and mitigate the risk.
Key Activities
- 2022: BVLOS ARC. FAA’s UAS BVLOS Aviation Rulemaking Committee (ARC) recommended that BVLOS UAS have right-of-way over aircraft not equipped with ADS-B Out below 500 feet AGL, and over all aircraft in “shielded areas” near obstacles and infrastructure, without having to equip with DAA. Several manned aviation groups voted against the report. NAAA sent letters to the FAA Administrator and the DOT Secretary opposing these recommendations. Separately, NAAA urged FAA to suspend Part 107 BVLOS waivers that rely on observers watching the airspace instead of the drone. FAA declined in January 2023, citing Order 8040.6.
- 2023: BVLOS exemptions and coalition letter. FAA opened four precedent-setting BVLOS exemption petitions and a broader BVLOS proposal for comment, and NAAA opposed all of them. FAA granted the exemptions in September 2023, letting operators use DAA systems instead of visual observers, but it explicitly kept the UA’s duty to give way to manned aircraft. In December 2023, NAAA and seven other general aviation groups responded jointly to FAA’s BVLOS listening session. The letter opposed any new equipage mandate on manned aircraft, insisted that §91.113 right-of-way responsibilities remain unchanged, and called for UAS to carry adequate DAA.
- 2023–2024: FAA Reauthorization. At NAAA’s request, Reps. Bruce Westerman (R-AR) and Rick Crawford (R-AR) secured an amendment directing FAA to “ensure the safety of manned aircraft operating in the national airspace system” in UAS operations. The May 2024 Reauthorization Act (49 U.S.C. §44811) requires the BVLOS rule to provide for the safety of manned aircraft and to “consider the maneuverability and technology limitations of certain aircraft.”
- August 2025: BVLOS NPRM. FAA proposed 14 CFR Part 108 to allow routine BVLOS operations, including aerial application, under permits or certificates. Provisions of greatest concern: (1) Part 108 UA would have right-of-way over any manned aircraft not broadcasting ADS-B Out or electronic conspicuity (EC); (2) within 50 feet of power lines, substations, railroads, bridges and pipelines (“shielded areas”), Part 108 UA would not have to yield to any aircraft; and (3) Part 108 operations would be exempted from the §91.113(b) see-and-avoid requirement. The NPRM did not propose mandating ADS-B for manned aircraft below 500 feet.
- September–October 2025: Grassroots effort and comments. NAAA released draft comments for aerial applicators to adapt and file, and worked to engage commodity groups, federal agencies, general aviation organizations and safety agencies. NAAA’s October 2025 comments used MSU, UND, ASSURE and ASRS data to argue against the right-of-way changes and shielded areas, and called for comprehensive DAA.
- January 2026: FAA leadership roundtable. NAAA’s CEO joined a BVLOS roundtable with FAA Administrator Bryan Bedford and Deputy Administrator Chris Rocheleau. He raised the loss of ADS-B signal at low altitude in hilly and wooded terrain, NAAA’s preference for anonymous EC over ADS-B, and the danger of the shielded-area provisions.
Recent Updates
- BVLOS, reopened comment period. On January 28, 2026, FAA reopened the BVLOS NPRM for 14 days, limited to questions about EC and right-of-way. NAAA circulated draft comments to its members for grassroots use and filed comments on February 11, 2026. The comments supported EC as a portable, lower-cost option that preserves anonymity (for example, through self-assigned addresses) for air-to-air traffic deconfliction. They stressed that EC works only if all low-altitude aircraft participate, including UAS in shielded areas, and if UAS yield to manned aircraft.
- BVLOS, final rule at OIRA. FAA sent the Part 108 final rule to the White House Office of Information and Regulatory Affairs (OIRA) on July 10, 2026. On September 29, 2026, NAAA made its case to OIRA and DOT/FAA rulemaking staff in an Executive Order 12866 meeting. NAAA made two asks: (1) strike the shielded-area right-of-way carve-out (§108.205 and the §108.195(a) exception); and (2) if ADS-B or EC is to carry the DAA burden, require the UA to receive the signal itself, in the air. The proposed rule has no explicit ADS-B In requirement and appears to allow ground-based receiver networks as a means of compliance. OIRA’s standard 90-day review ends around October 8, 2026, and can be extended once by 30 days. Publication is most likely in late 2026.
Other Recent Updates
- UAS enforcement. On January 21, 2026, FAA issued Compliance and Enforcement Bulletin 2026-1 (Order 2150.3C, Change 13), implementing Executive Order 14305. It requires legal enforcement action, not just compliance action, for any UAS operation that endangers the public, violates airspace restrictions or furthers a crime, and it applies to all UAS operations, not only Part 107. On April 17, 2026, FAA launched the Drone Expedited and Targeted Enforcement Response (DETER) program, which offers eligible first-time small UAS violators reduced penalties in exchange for quick settlement. It appears aimed at the volume of UAS enforcement cases the new bulletin produced.
- §927 waivers. FAA published its §927 waiver implementation policy in April 2026 (see “Regulatory Policy” above).
- Annual preseason outreach. On April 23, 2026, NAAA issued its tenth consecutive preseason press release urging UAS operators to yield to manned ag aircraft. It also urged them to equip with strobes, high-visibility markings and ADS-B In, monitor 122.925 MHz, check NAAA’s Find an Aerial Applicator directory, and carry liability insurance. The release was picked up widely by agricultural and aviation media.
- UAS flight restrictions over critical infrastructure. On May 6, 2026, FAA proposed a new 14 CFR Part 74 to let owners of critical infrastructure and certain other fixed sites request UAS flight restrictions. Parts 91, 107, 108, 135 and 137 operations would still be allowed inside these restrictions, with only notice to the site manager and a Remote ID broadcast. NAAA’s comments (August 2026) called for UAS access to be conditioned on comprehensive DAA. They also pointed out the contradiction of protecting critical infrastructure in this rule while the BVLOS proposal lets UAS operate near the same infrastructure with no duty to yield.
- Zipline decision. In May 2026, FAA issued an exemption decision for a petition from Zipline, which NAAA previously commented on. FAA agreed with NAAA that Zipline’s safety reports were not duplicative and kept the reporting requirements. FAA also kept drug and alcohol testing requirements, as ALPA requested. However, it exempted the operator’s remote pilots from the Pilot Records Database, finding they are “not pilots in the traditional sense,” and dropped the Remote Pilot Certificate requirement for visual observers.
- International coalition letter. In June 2026, NAAA joined ag aviation associations from Argentina, Brazil, Canada, Mexico, Paraguay and Uruguay in a letter calling on each country’s regulators to adopt clear, modern and enforceable drone regulations. The letter stressed that low-altitude, high-speed ag aircraft cannot reliably see and avoid drones.