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NAAA Submits Comments to EPA on Agency’s Third Proposed NPDES PGP

Last week NAAA submitted comments on the EPA’s proposed reissuance of a five-year National Pollutant Discharge Elimination System (NPDES) Pesticide General Permit (PGP) that covers pesticide applications over aquatic areas. This is the third five-year reissuance of the EPA’s NPDES-PGP. The first was issued in 2016, five years after the initial PGP went into effect in 2011. The second was issued in 2021; the current proposal is for 2026.

The vast majority of the proposed 2026 PGP was identical to the 2021 version. Accordingly, NAAA’s comments were similar to earlier comments and touched on the redundancy of the PGP, considering that all pesticides, including those for aquatic sites, already undergo a registration and then a registration review process to verify their safety to the environment when used according to label directions. NAAA commented again that the definition of water of the U.S. (WOTUS) continues to be an ongoing issue that can lead to confusion for both the regulated and the regulators.

One key change in the proposed 2026 PGP is the addition of Fish and Wildlife Service (FWS) areas of concern for endangered species. Earlier PGPs had only included National Marine Fishery Services (NMFS) endangered species resources of concern. NAAA did not object to this addition, but did point out that Endangered Species Act (ESA) requirements on the PGP are yet another redundancy considering EPA recent spate of efforts to address ESA issues in pesticide registration and review processes.

NAAA also expressed concerns about updated site monitoring and record keeping requirements, some of which fall on the applicator. NAAA pointed out these requirements have the potential to be overly burdensome to aerial application operations, many of which are small businesses. To view NAAA’s comments, click here.
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U.S. Wind Turbine Database Available: Another Resource to Track Wind Turbines

The U.S. Wind Turbine Database is a resource that provides the location of land-based and offshore wind turbines. View the database here. The database currently includes data on 73,352 turbines covering 44 states. Wind turbine records are collected and compiled from various public and private sources, including from the Federal Aviation Administration (FAA), and they are digitized or position-verified from aerial imagery and quality checked before being added to this database.

The creation of this database was jointly funded by the U.S. Department of Energy (DOE) Wind Energy Technologies Office (WETO) via the Lawrence Berkeley National Laboratory, the U.S. Geological Survey (USGS) Energy Resources Program, and the American Clean Power Association (formerly known as the American Wind Energy Association (AWEA).

NAAA is concerned about the placement of wind turbines on arable farmland that make it difficult and dangerous if not impossible to treat cropland in and around the vicinity of the wind towers. The presence of wind turbines can restrict and, in many cases, eliminate the option of aerial application. NAAA encourages anyone considering leasing their wind rights to think seriously about the potential upsides and downsides to farmers and aerial applicators before signing an agreement. View the wind turbine section of the NAAA website, including Learn Before You Lease advertisements and information on the proof of distance needed for an ag aircraft to turn safely from wind turbines and other tower-like obstructions. The information may be used by operators and state associations when dealing with wind farm and tower companies claiming that their obstructions do not hamper aerial application activities to crops. 
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Book Published Unveiling the Origins of Delta Air Lines & the Company’s Beginnings in Aerial Application

James John Hoogerwerf, former Delta Boeing 767 captain and aviation historian, has published a book titled Speed, Safety, and Comfort: The Origins of Delta Air Lines, where he traces the evolution and growth of Delta Air Lines. NAAA shared photos and information with Hoogerwerf about Huff-Daland Dusters Inc., the forerunner to Delta Air Lines, which was the first known aerial application business established. Huff-Daland Dusters completed the first commercial dusting of crops with its own specially built aircraft, the Puffer.

Huff-Daland Dusters rebranded as Delta Air Service in 1928 to focus more on providing transport of passengers and air mail. The following year Delta, began flying its first passengers from Monroe, LA, eventually establishing routes across the southeastern U.S. Hoogerwerf’s book details the history of Delta’s beginnings and the company’s contribution to agriculture, southern industrialization, and the development of commercial aviation in the U.S. You can purchase Speed, Safety, and Comfort: The Origins of Delta Air Lines at any major retailer, including Amazon.

In addition, purchase copies of the aerial application industry’s 100th anniversary book Agriculture’s Air Force: 100 Years of Aerial Application, not just for yourself but also for your local library and school libraries.
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Renew Your 2024 Membership Today; Grace Period Ends Feb. 15

If you have not renewed your NAAA membership for 2024, the grace period ends on Feb. 15! We urgently request your continued support by renewing your NAAA membership for 2024. While you have been busy aiding farmers to produce a safe, affordable, and abundant supply of food, fiber, and bioenergy, NAAA has been busy making sure low-altitude airspace is safe for your aerial application business to operate, as well as ensuring that you have the pesticide products you need to do your job. 

This year, NAAA is focusing on external communications to farmers in largely circulated ag publications touting the benefits of aerial application and hiring ag pilots to handle spraying work. NAAA is contributing articles and ads throughout 2024 in Farm Journal’s publications promoting aerial application services and how their readers can directly search the location of your aerial application business to a potential circulation of 150,000 ag retailer, crop consultants and farmers throughout the U.S.! Read our first article here. Sign up for a free issue of The Daily Scoop here and subscribe to The Scoop magazine here

Several of NAAA’s services conducted on your behalf, include: 

  • The second year of C-PAASS, our professional certification program for aerial applicators that take additional steps to augment their professionalism through education and testing, positioning themselves to be recognized and rewarded by their insurance providers, pesticide manufacturers, and customers. Learn more at https://education.agaviation.org/
  • Submitting no fewer than 270 comments since 2017 to the EPA to keep aerial applications on pesticide labels enabling you to keep a deep inventory of pesticide tools without unnecessary and burdensome restrictions.
  • Development of a health care insurance policy in 2024 for NAAA members to purchase for their families and employees at competitive rates.

Supporting NAAA as a member helps provide NAAA with more resources so that we can in turn provide you with more and more membership assets. Continued benefits in 2024 to members include legal consultation on federal aviation laws, discounts for attending or exhibiting at the Ag Aviation Expo, staying connected to members through the print and online NAAA Membership Directory and receiving NAAA publications and eNewsletters, social media briefings and substantive web content at AgAviation.org

Please make it a priority to renew your NAAA membership—the payoff far exceeds what you will spend in dues in the form of effective advocacy that reduces regulation and taxes affecting your aerial application business and trade association membership dues are tax deductible. If you prefer to pay over the phone, please call (202) 546-5722.
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NAAA & NAAREF Board Meetings Feb. 15-17 in Alexandria, VA

The February 2024 NAAA & NAAREF Board and Committee meetings will take place next week, Feb. 15-17 in Alexandria, Virginia. Click here to view a schedule.

All meetings are open to NAAA members. If you are not a board or committee member but are interested in attending, please contact Lindsay Barber for more details.

Hotel Details
Hilton Old Town Alexandria
1767 King Street
Alexandria, VA 22314

The Hilton Old Town is located directly next to the King Street Metro stop (take either the Blue or Yellow Line), which is the second stop south of Reagan National Airport (DCA). If you don’t want to take a cab, Lyft or Uber, you can use the Metro and there is now an app that you can download to pay directly from your smartphone. You can view a map of the metro system here.

The room block is closed. Contact Lauren Henretty with hotel questions.

Board Books: The Board book was provided to board and committee members on Feb. 5. If you did not receive it, please contact Lindsay Barber for a link. 
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Update Your Information for 2024 Membership Directory

The deadline to provide any corrections to your membership listing is today. Please review your listing and provide any changes to guarantee accurate inclusion in the 2024 NAAA Membership Directory.

Have you moved or changed employers since you renewed your NAAA membership? Allied companies, have you reviewed your company description lately? Ensure your listing in the 2024 NAAA Membership Directory is correct by logging into your account. If any information has changed, please let us know right away. 

You can provide your information by:

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