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FAASTeam Releases Notice to Ag Aviators in Response to High Number of Fatal Ag Accidents

The FAA Safety Team (FAASTeam) released a notice to agricultural aircraft operations last week in response to the high number of fatal accidents that occurred in June. The notice contains a list of suggested actions to improve safety for ag aircraft. The notice is timely as July is the industry’s busiest month, and unfortunately also the month with the most accidents. The notice ends by suggesting additional resources for ag pilot to get more information, listing NAAA as one of those options.

No matter how busy you get for the rest of the season, don’t let anything compromise your safety or cause you to ignore your personal minimums. For more safety information, please check out some of NAAA’s resources:

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NAAA Submits Comments to EPA to Protect Aerial Applications for Two Pesticides

Last week NAAA submitted comments to the EPA on amended proposed interim decisions (PID) for the pesticide active ingredients captan and ziram. The amended PID for ziram proposed to ban all conventional uses, keeping only antimicrobials uses. The reason for the proposed ban was human health risks to both bystanders from drift and occupational risks to mixers and loaders and pilots. NAAA’s comments addressed the drift concern by reminding EPA that their current drift model dramatically overestimates the amount of drift from aerial applications. To address the risks to pilots and mixers and loaders NAAA suggested daily acreage and rate limits when making aerial applications of ziram.

The amended PID for captan proposed to ban aerial applications of all the dry formulations, allowing only liquid formulations to be used for aerial applications. The concern driving the proposed ban is inhalation risks for mixers and loaders. As alternative to the ban, NAAA proposed requiring a PF50 respirator when mixing and loading dry formulations as well as a daily limit on the number of acres a mixer and loader can load for in support of aerial applications. The amended PID for captan did increase the maximum wind speed limit allowed for aerial applications from 10 to 15 mph based on NAAA’s prior comments on the original PID.

Click here to read the comments on the ziram PID and here to read the comments on captan. The are several more pesticide registration review activities NAAA will be commenting on in the coming months to continue to ensure aerial applications.
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UAS “Advanced Operations” Exemptions: The New Normal

In March, FAA granted a precedent-setting exemption to Hylio, a U.S.-based agricultural uncrewed aircraft system (UAS) manufacturer. For any §44807 Approved UAS, this exemption granted relief to operate up to three UAS simultaneously under one operator, during night, and without visual observers (VOs), within visual line of sight (VLOS) of the pilot in command (PIC).

NAAA commented on the petition for this exemption with specific concerns for the safety of crewed agricultural aviation operations sharing this airspace. However, in their decision, FAA stated that safety would not adversely be affected by permitting these operations.

Since this exemption was granted, there have been over 200 petitions filed by UAS operators seeking the same regulatory relief to conduct these “advanced operations” (swarming, night and without-VO operations). These petitions specifically cite the above Hylio exemption as precedent and request the FAA to issue a “summary grant” of their own exemption. Many of those 200 petitioners have already received their exemption using this tactic.

For those unfamiliar, when an individual petitions the FAA for an exemption to the Code of Federal Regulations (CFR), the public is typically given an opportunity to comment on it. FAA is required to read and consider these comments in formulating their decision on the extent to which they will grant the requested relief from the CFR. However, if FAA deems a petition materially similar to a previously granted exemption, they may issue a summary grant without notice or opportunity for public comment.

The issuance of a summary grant is how the vast majority of UAS operators receive their exemption(s); they simply cite previous precedent-setting exemptions as evidence that they should receive the same. These boilerplate exemption petitions are often filed by an attorney representing the operator.

Aside from the practice of using precedent-setting exemptions to issue summary grants for de-facto rulemaking, NAAA has serious concerns about these operators’ understanding of their own exemptions. There is widespread evidence that many are unaware of, or simply non-compliant with, the specific conditions and limitations stated in their exemption. The common view of an exemption as a mere paperwork hurdle compromises safety for everyone, but for those sitting in the seat of an ag aircraft it really is life and death.

Another perspective of interest will be State pesticide control officials. With one operator responsible for multiple UAS simultaneously spraying one or more fields, this would seem to represent a novel risk profile from the environmental point of view. Whether any State pesticide authorities take a stance on this, or are even aware, remains to be seen, but what is certain is that they already have their hands full dealing with this (relatively) new mode of application.
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Fatal Ag Training Accident Claims the Life of Alberto Lozano Alvidrez

The members and staff of NAAA extend their sympathies and condolences to the family and friends of Alberto Lozano Alvidrez. He was fatally injured on June 25, 2024, while on an ag aviation training flight. Alberto was born on May 5, 1996, and was 28 years old at the time of his passing.

Alberto was born in Juarez, Chihuahua, Mexico and was living in Las Cruces NM. His visitation was on held on June 29 at the Terrazas Funeral Chapel in Deming, NM. His full obituary can be read here. Please keep his loved ones in your prayers as they mourn his death.
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Operation S.A.F.E. Analyst Training – October 2024 – Cleveland, MS

Advanced Turbine Training, LLC and Delta State University will be hosting an Operation S.A.F.E. Analyst training course Oct. 1-4, 2024 in Cleveland, MS at the Cleveland Municipal Airport (KRNV). WRK of Arkansas and WRK of Oklahoma will co-conduct the course, which will include two packed days of classroom instruction followed by a student-led pattern testing clinic at KRNV.

This training is open to anyone seeking to become an Operation S.A.F.E. Analyst or Technician; no previous experience required. In addition, it will serve as a great refresher for current/past Analysts seeking renewal.

There is high demand for trained Analysts across the US and abroad. Whether you would like to start pattern testing your own operation’s aircraft or use your skills to consult with other operators, becoming a NAAREF-recognized Operation S.A.F.E. Analyst can be a valuable professional investment.

If you have a particularly astute individual in your ground crew, maybe an aspiring ag pilot, consider this as an avenue of opportunity. This training will provide them with knowledge and skills which they can bring back to your operation.

View the Course Brochure/Syllabus. The course cost is $3,000 if registered before August 23, 2024. To register, or direct questions about the course, contact either:

George Moore: +1 (281) 732-4254 or Dennis R. Gardisser: +1 (501) 676-1762
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NAAA Hires Amy May as Manager of Communications & Meetings

NAAA is excited to announce the hiring of longtime NAAA member Amy May as NAAA’s Manager of Communications & Meetings. Amy brings 20+ years of experience in communications and organization in her years of work as a social work coordinator, office manager and client account manager. In addition, she has served on various NAAA and Support committees for several years. Amy’s husband is NAAA Operator member, Tom May of Flying M Applicators Inc. in Holdrege, Neb. Amy will use her experience to help in NAAA’s communications activities and assist with planning the Ag Aviation Expo and board meetings. She will be working with Lindsay Barber, NAAA’s Director of Communications & Meetings.

Amy is a graduate of the University of Nebraska and lives with Tom and their two sons in Holdrege, Neb. Please help us in welcoming Amy to the NAAA staff.
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Booth Sales Begin Today at 12 p.m. ET for the 2024 Ag Aviation Expo

Join us for the 2024 Ag Aviation Expo in Fort Worth, Texas, Nov. 18-21. Booth Sales for 10×10 and 10×20 space begin today. Exhibiting is a great way to boost your brand visibility and get your company name in front of an expected 1,500+ attendees. Please review pricing and the booth purchase directions here.

In addition to attending the NAAA Ag Aviation Expo, Fort Worth is full of great restaurants, bars, fun activities, and Texas hospitality! You can visit the Historic Stockyards for the world’s only twice-daily cattle drive, stop by Billy Bob’s, the world’s largest honkey tonk, or shop and dine in the 35-block Sundance Square entertainment district. The Fort Worth Aviation Museum is also a must-see.

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 today
  • 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.

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AD Proposed for Lycoming Connecting Rod Bushings

The FAA has proposed adopting a new airworthiness directive (AD) for all Lycoming engines that have certain connecting rod assemblies installed. This proposed AD was prompted by several reports of connecting rod failures, which resulted in uncontained engine failure and in-flight shutdowns (IFSDs).

In 2017, FAA issued AD 2017-16-11, which required an inspection of connecting rods and replacement of affected connecting rod small end bushings per Lycoming Mandatory Service Bulletin (MSB) 632B dated August 4, 2017.

Since issuing the previous AD, a manufacturer investigation determined that affected connecting rod small end bushings may be installed on additional populations of Lycoming engines. The manufacturer also determined that degradation of the connecting rod small end bushings is detectable during oil change inspections. This condition, if not corrected, could result in connecting rod failure with consequent uncontained engine failure, total engine power loss, IFSD, and possible loss of the aircraft.

This proposed AD would require repetitive oil inspections for bronze metal particulates and, if found, additional inspections of the connecting rod bushings for damage, proper fit, movement, and wear, and replacement if necessary. As terminating action to the connecting rod bushing inspections, this proposed AD would require replacement of the connecting rod bushings with parts eligible for installation. 

You can view this proposed AD here. Comments are due August 12, 2024.
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AD Proposed for R44 Belt Tension Clutch Actuator Brackets

The FAA has proposed to adopt a new airworthiness directive (AD) for Robinson R44 helicopters with serial numbers (S/Ns) up to 2480 inclusive and 30001 through 30022 inclusive, and R44 II helicopters with S/Ns up to 14089 inclusive.

This AD was prompted by several reports of failed clutch actuators and failed rivets attaching the belt tension clutch actuator brackets to the fan scroll housing. This AD is proposed to detect and address loose and missing brackets and rivets. This unsafe condition, if not addressed, could result in detachment of the bracket, causing failure of the clutch actuator assembly, loss of main and tail rotor drive, and subsequent loss of control of the helicopter.

This AD would require, within the lesser of 300 hours time-in-service or 12 months after the effective date: (1) inspection of each A185 bracket for looseness and fretting, (2) inspection of the fan scroll housing fiberglass adjacent to the bracket rivets for delamination, (3) inspection for correctly sized rivets and (4) application of torque stripes to each rivet.

See R44 SL-61B (Dated 16 March 2023) for inspection and corrective action procedures.

Comments on this proposed AD are due August 12, 2024.
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In Case You Missed Last Week’s NAAA eNewsletter

Click here for the July 3, 2024 eNewsletter to read:

  • NAAA Visits with Global Agri-Chemical Manufacturer Valent Promoting Ag Aviation
  • Supreme Court Overturns Chevron Doctrine Likely Leading to More Challenges to Federal Agency Regulations
  • Aerial Application Industry Mourns Loss of Scott Wayne Rainey
  • July is Ag Aviation’s Busiest Month for Hours and Accidents, Brush Up on Your Fly Safe Messages

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