NAAA Actions Regarding UAS

On December 31, 2019, the FAA published its long-awaited proposed rule on the tracking and identification of UAS. All UAS required to register with the FAA must be equipped with some form of tracking and ID, effectively instituting a weight threshold of 0.55 lbs. for both commercial and recreation users. A weight-based threshold is welcome news, as NAAA was one of 10 members of the 2017 Unmanned Aircraft Systems Identification and Tracking Aviation Rulemaking Committee (UAS ID and Tracking ARC) to dissent from the ARC’s final report in part for lacking weight-based requirements.

Exemptions in the rule include amateur-built UAS, UAS of the United States government, and recreational UAS that weigh less than 0.55 pounds. The rule proposes two categories of remote identification: standard remote identification and limited remote identification. Under standard remote identification UAS would be required to transmit information through an internet connection and simultaneously transmit that same information via a radio frequency.  Under limited remote identification UAS “would be required to transmit information through the internet only, with no broadcast requirements; however, the unmanned aircraft would be designed to operate no more than 400 feet from the control station,” according to the proposal. A UAS not equipped with remote ID would only be allowed to fly in "FAA-recognized" areas and would have to stay within visual line of sight.

NAAA will review details of the proposed rule, specifically looking at what UAS are exempt from the rule and how the proposal would work in rural areas where ag aircraft primarily operate. NAAA will submit comments before the comment period ends on March 2, 2020. 

Additionally, NAAA ha been informed by the FAA it is in the premilitary stages of starting a rulemaking process that would to enable agricultural certification for UAS operations without the need for exemptions. This would be done as part of the larger Modernization of Special Airworthiness Certification (MOSAIC) rulemaking project that would enable a wide range of UAV operations beyond what is allowed under part 107 without type certification. A NPRM is tentatively planned for early 2022, with a final rule issued in late 2023. 

 In January of 2020 NAAA wrote a letter to the EPA urging them to begin testing UAVs to evaluate application accuracy and drift potential. These results need to be incorporated into the AgDRIFT model and into the risk assessment process for pesticide registration and re-registration to ensure aerial applications by UAVs can match the same safety standards as manned agricultural aircraft.

Updated January 2020 

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