YAMAHA RMAX Aerial Application UAV Approval

The FAA has repeatedly ignored NAAA’s calls for a vigorous UAV-safety regime. One of the more controversial Sec. 333 petitions approved by the FAA was in May of 2015 when the FAA approved the 218-pound Yamaha RMAX for use in aerial application under a petition filed by Yamaha. While the FAA once again ignored NAAA’s call for strobe lighting and ADS-B, as the Agency did in other UAV petitions, NAAA was encouraged that the FAA chose not to exempt the RMAX completely from Part 137 as Yamaha initially requested. The FAA chose instead to cherry pick the sections of Part 137 it was exempting Yamaha from. The exempted sections are:

  •  § 137.19(c) – Exemption from the requirement that a commercial ag operation applying for a Part 137 certificate have the services of a commercial pilot. Like other exemptions the FAA is permitting the exempted UAS operations with only a sport pilot certificate and driver’s license. The petitioner is still required to comply with other Part 137 requirements.
  • § 137.41(c) – Related to the above exemption, allowing sport pilots to operate the RMAX UAS commercially under Part 137.
  • § 137.19(d), 137.31(a) – Requires a Part 137 applicant to have an aircraft with an airworthiness certificate; because the FAA is exempting the RMAX from airworthiness requirements, the agency is exempting them from this section as well.
  • § 137.19(e)(2)(ii), (iii), and (v) – Demonstration of skill of approaches to the working area, flare-outs, and pullups and turnarounds. The pilot must still demonstrate satisfactory swath run procedures. If the operating manual (which is of course confidential) ever changes then Yamaha will need to petition for an amendment to this exemption. Exemption allowance from this provision within Part 337 for a UAV perplexes and is opposed by NAAA because it could compromise safety and application efficacy by not properly demonstrating these skills and serves as a double standard to require them for manned aircraft but not for UAVs.
  • § 137.31(b), § 137.42 – Exemption from the requirement and use of safety belts and harnesses.
  • § 137.33(a) – Exemption from the requirement of carrying a facsimile of the operating certificate on the aircraft, but the operator must have the certificate available at the operating station.
The FAA noted this is the largest UAV they have approved under Section 333 and is well above the weight of what is considered a “small UAV” (55 pounds or less). All Sec. 333 approvals prior to the RMAX focused on small UAVs, as Section 333 approvals were considered a stopgap until the small UAS rule is finalized. FAA however felt that safety data generated by Yamaha warranted the approval of this larger UAV. With the RMAX approval the FAA chose for the first time to permit commercial aerial application without a commercial pilot’s license. However, California state law prohibits anyone without a commercial pilots license from applying crop protection products, so Yamaha only employs UAV operators with a commercial pilot certificate.