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NAAA Comments on Part 137 UAS Petition to Remove Medical Certificate Requirements

NAAA recently submitted comments on a petition from Veteran Drone Services LLC seeking to allow remote pilots operating multiple UAS weighing greater than 55 pounds used for agricultural operations to hold a driver’s license in lieu of a third-class medical certificate.

The petition cited previously granted exemptions which permitted this relief, however, the exemption which originally set that precedent was for UAS less than 55 pounds (11213) and expired in 2017 and it only permitted use of a driver’s license in lieu of an airman medical certificate when combined with a pilot certificate. The other cited exemption which permitted this for UAS greater than 55 pounds (17790) and that exemption was amended in 2020 to again require an airman medical certificate.

The petitioner’s stated intent of the needed regulatory relief was to overcome the difficulty some veterans have with obtaining a third-class medical certificate due to PTSD or other conditions.

While acknowledging that it should be a shared goal among all Americans to aid veterans in their civilian reintegration and employment, NAAA asserted that it would be improper for FAA to consider this in the disposition of the petition. Put simply, granting this relief would set a precedent from which all future Part 137 UAS Exemptions would follow.

NAAA’s comments in opposition to this petition were succinct: “It is incumbent upon all participants in the [Part 137] airspace to maintain its safety, so that each may rely upon it. Ensuring pilots hold an appropriate FAA medical certificate is one of the pillars that support this trust in NAS safety.”

You can view NAAA’s Comments here.
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UAS “Advanced Operations” Exemptions: Update

Earlier this month, this eNewsletter published UAS “Advanced Operations” Exemptions: The New Normal, highlighting the new wave of UAS Part 137 exemptions flowing from precedent set in the recently granted Hylio Exemption. Specifically, these “Advanced Operations” permit operation of up to three UAS simultaneously under one operator, during night and without visual observers (VOs), within visual line of sight of the pilot in command.

Since that article was published, NAAA noticed that several recently granted exemptions included provisions for these “Advanced Operations,” even though the petitioner did not request them.

Upon seeking clarification from FAA on this matter, NAAA learned that all new UAS Part 137 exemptions and renewals will include the option to conduct swarming (up to 3), night and no-VO operations. In other words, this is the new normal.

NAAA will continue to take every opportunity to comment on petitions (wherein public notice is issued) which might compromise the safety of crewed Part 137 operators. However, it seems that FAA does not care to solicit comments related to airspace safety from aviation organization’s such as NAAA that has a legitimate concern for agricultural UAS as a collision risk to crewed aircraft.

In a recently granted exemption to Guardian Agriculture, FAA largely discounted NAAA’s concerns of collision risk, stating “aviation is a highly regulated industry and there are processes and procedures in place to reduce the risk of a collision.” They further assert that a UAS is “significantly more visible than birds and high voltage wires.” Their reasoning also cites limiting the area of operation to “low-altitude, low-risk, Class G airspace” and that it is “unlikely that a manned operation will occur over the same field as the UAS operation since the farmer typically pays for the chemicals and is unlikely to pay for a second application on the same day at the same time.”

In another recently granted exemption to American Drone, FAA elected to ignore all public comments, including NAAA’s. While they did post the petition in the Federal Register and received several comments, the exemption was granted without evaluation of the comments by citing the above-mentioned Hylio Exemption.

NAAA remains deeply concerned with the collision risk presented by the growing fleet of agricultural UAS, particularly with the cascade of regulatory relief permitting UAS to be operated with fewer and fewer eyes on them (with swarming and no-VO operations). These operators and the FAA are leaning heavily on high levels of automation to mitigate collision risk, and it is yet unclear how safety will be impacted over time. What is clear, however, is that these risks are viewed much differently from inside the cockpit.
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Air Tractor to Exhibit at 2024 Farm Progress Show

Air Tractor is scheduled to make their debut as an exhibitor at the 2024 Farm Progress Show in Boone, Iowa, with its AT-802A agricultural aircraft. This year Air Tractor is celebrating 50 years since its first delivery.

Courtesy Air Tractor

As the largest, most diversified agriculture information business in North America, Farm Progress prides itself on providing a well-rounded show for farmers to connect and do business with 600+ exhibitors. This year’s Farm Progress Show runs from 8:00 AM – 4:00 PM, Aug. 27-29. The show provides attendees with the opportunity to see the latest equipment, seed, crop chemicals, field demonstrations, livestock handling and equine events, arts and crafts, and more.

While the audience won’t witness the AT-802A flying into the farm show, having it on display will be a superb addition to the show, highlighting the aircraft, the aerial application industry and the industry’s benefits to agriculture. Air Tractor hopes to make more connections with the farming community through its inaugural participation in the Farm Progress Show. Air Tractor’s representation of ag aviation with its versatile agricultural planes is of great importance to the industry.
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Brazilian Ag Aviator Juliana Turchetti Fatally Injured in Firefighting Accident

Juliana Turchetti, 45, was fatally injured in a SEAT firefighting accident on July 10, 2024. The accident occurred near Helena, Montana, while she was fighting the Horse Gulch Fire. Juliana was a native of Brazil who moved to the U.S. in 2018 where she worked as an ag pilot. While flying ag in Illinois, she opened an aviation themed coffee house in Springfield, Illinois. This spring she recently made the transition to SEAT operations and moved out west.

Juliana leaves behind a 17-year-old son and numerous other family members, all of whom live in Brazil. Her remains are being sent back to Brazil for funeral and burial. A memorial for Juliana will be held at the Springfield Carriage Co. in Springfield, Illinois on July 27, 2024, from 4-8 p.m. Donations will be accepted at the memorial for Juliana’s son. In addition, an online fund will also be established at some point – click here to check for details when they become available. The members and staff of NAAA offer their condolences to Juliana’s family and friends. Please keep them in your thoughts and prayers.
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NAAA Ag Aviation Expo Attendee Registration Now Open

We look forward to seeing you at the 2024 NAAA Ag Aviation Expo in Fort Worth, Texas, Nov. 18-21, a new convention destination for the Ag Aviation Expo. Attendee registration is now open for the annual convention. Exhibitors can purchase booth space here.

NAAA’s new registration system will allow you to register and pay for all events at one time. This includes:

  • Ag Aviation Expo registration for yourself, your spouse, children and other employees in your company.
  • Nov. 16 – Flying in the Wire & Obstruction Environment Course
  • Nov. 17 – NAAREF Fundraiser: Bucking for PAASS
  • Nov. 18 – Support Event at Billy Bob’s Texas

Besides great Ag Aviation Expo programming and speakers, you’ll enjoy a gold mine of offerings to eat, drink, and play in a great city. The cowboy way of life meets modern culture in Fort Worth, TX. This urban oasis is home to several entertainment districts (including a walkable downtown), an aviation museum, and the world’s only twice-daily cattle drive in the historic Stockyards. Be sure to visit Billy Bob’s Texas, the world’s largest honky-tonk, featuring live music, line dancing, food, fun, and history.

Whether you’re an industry veteran or a low-time or no-time pilot, the Ag Aviation Expo promises to deliver invaluable insights, the latest technological advancements, and a chance to connect with peers from across the nation and the world. Join us in the heart of Texas for an unforgettable experience that will help you soar to new heights in your ag aviation journey.

Details for the 2024 Ag Aviation Expo

  • Dates: Nov. 18-21, 2024
  • Location: Fort Worth Convention Center and Omni (across the street from Convention Center)
  • Kickoff Breakfast Speaker: Kevin Humphreys, War Veteran, PTSD Counselor, Mental Health Ambassador
  • Schedule of Events: See the current, tentative schedule here
  • NAAA Hotel Room Block: Details here
  • Attendee Registration: Details here
  • Exhibitor Booth Sales Open
  • Sponsorship Opportunities: View the sponsorships opportunities here. We have sponsorships available for all budget sizes. Please email Lindsay Barber if you would like to secure a sponsorship or learn more!
  • Auction Donations: Thank you to Pratt & Whitney Canada for donating a PT6-34AG to this year’s NAAA Live Auction. While we are still several months away from the Ag Aviation Expo, we are already accepting donations for the Live and Silent Auction. The earlier you inform us of your auction donation, the more advertising you will receive on the NAAA website and in NAAA publications. Support the aerial application industry by donating an item today. Contact Amy May for questions or your donation details.
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NAAA Award Nominations due by August 5

Do you have a rising pilot within your ranks? Do you admire certain NAAA members’ outstanding service to the industry or their community? The NAAA awards nomination deadline is August 5. The aerial application industry is filled with exceptional people who go above and beyond the call of duty, often with little fanfare. Make someone’s day or year by nominating them for a 2024 NAAA Award.

NAAA’s online submission form is easy and quick to use; nominate someone in just a few clicks here.

Who will be among this year’s awardees? There are nine NAAA Award categories and one NAAREF Award. Nominations are due Aug. 5.

NAAA Award Categories
Agrinaut Award: Honors an agricultural aircraft operator, operating organization, or allied member company that has made an outstanding contribution in the field of ag aircraft operations. The achievement cited shall have contributed to the “state-of-the-art” for the benefit of the agricultural aircraft industry as a whole.

Allied Industry Individual Award: Recognizes an NAAA member or staff and/or an allied industry individual who has significantly contributed their efforts for the benefit of the allied industry and the aerial application industry. (Presented by the NAAA Allied Industry Committee.)

Delta Air Lines “Puffer” Award: Recognizes an individual who has made an outstanding contribution to the design of agricultural aircraft and/or related equipment.

Evans-Christopher Operation S.A.F.E. Award: Recognizes individuals or entities that have made outstanding contributions to the Operation S.A.F.E. program. (Presented by NAAREF.)

John Robert Horne Memorial Award: Honors a pilot with five or fewer years of experience in the agricultural aviation industry who has an exemplary safety record and has contributed to safety in ag aviation. This award no longer has carryover nominations from year to year; a new nomination must be submitted every year.

Larsen-Miller Community Service Award: Recognizes outstanding contributions by a member to his or her community.

Opal and Bill Binnion Memorial Award: Acknowledges those who contribute to NAAA in its efforts to educate the public about aerial application.

Richard “Dick” Reade Memorial Award: Recognizes outstanding contributions by an allied industry member and their company.

William O. Marsh Safety Award: Recognizes significant achievements in safety, safety education or an outstanding operational safety program.

Zoren and Joan O’Brien Memorial Outstanding Service Award: Awards outstanding service to the commercial agricultural aviation industry or to its association.

The 2024 NAAA Award recipients will be honored at the Excellence in Ag Aviation Banquet on Nov. 20 in Fort Worth, Texas.
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The FAA is adopting a new airworthiness directive (AD) for Bell Model 407 helicopters with serial numbers 54832 through 54931 inclusive, 54933 through 54939 inclusive, and 54942 through 54954 inclusive with a fuel system standpipe assembly (standpipe) part number 407-062-032-103 installed.

Transport Canada AD CF-2023-11 advises that, due to a quality escape, the affected standpipes may have been delivered with sharp edges at the internal weld joints. If not corrected, this condition could lead to fuel quantity system wiring damage, loss of or erratic fuel quantity indication or a potential for fuel tank ignition.

The newly adopted AD requires inspection of the interior of the standpipe as shown in Bell Alert Service Bulletin 407-21-124, and inspection of the fuel quantity harness assembly. Depending on the results of the inspections, corrective actions before further flight may be directed.

AD 2024-10-12 is effective August 22, 2024.
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In Case You Missed Last Week’s NAAA eNewsletter

Click here for the July 18, 2024 eNewsletter to read:

  • House Appropriators Advance 2025 Ag Spending Bill with Supportive Language for USDA Aerial Application Research
  • Mike Hudolin Fatally Injured in Third Ag Mid-Air Collision of 2024
  • Firefighting Pilot Ronald “Van” Patton Lost in Airplane Accident
  • Ron Cline Celebrates Independence Day: Soaring High with the American Flag in His Helicopter
  • AD Proposed for R22/R44 Governor Controller
  • ACRC Ag Container Collection & Recycling Services Update

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