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EPA Accepts NAAA’s Recommendations to Improve Accuracy of Aerial Drift Model

After years of effort, the EPA has finally accepted NAAA’s recommendations to improve the accuracy of the models used to estimate the amount of drift from aerial applications. Until the recently released Insecticide Strategy (IS) (see article below), EPA had used the Tier 1 model in AgDRIFT, which had many erroneous and outdated assumptions, including the typical droplet size used, aircraft type reflecting the industry, weather conditions during the application, and boom drop.

This resulted in unrealistic aerial drift estimates, which in turn were used in environmental and human health risk assessments. The result has been decades of pesticide registration risk assessments and decisions that have overstated the risk aerial application presents to our environment and fellow citizens. In the IS, EPA used the Tier 3 model in AgDRIFT and most of NAAA’s suggested assumptions for the variables within the model. NAAA submitted a letter to EPA in June of 2020 outlining recommended changes in the assumptions that should be used in the Tier 3 AgDRIFT model. Prior to that letter, NAAA has included the recommendations on numerous comments to EPA.

EPA changed the default aircraft from an AT-401 to an AT-802 with a corresponding increase in swath width and decrease in the number of passes. The default droplet size was increased to medium, and the atmospheric stability was set to a level that rules out the presence of an inversion. EPA also changed the height at which wind speed is measured to reflect smokers and onboard meteorological measurement systems and increased the upwind swath displacement to reflect what is actually practiced in the industry.

There were two assumptions EPA did not agree with completely on with NAAA – surface roughness and standard boom drop. While EPA did not agree with the values proposed by NAAA, they did not disagree with the logic behind our recommendations. NAAA will conduct additional data collection and analysis to better support our positions in a future follow up letter to EPA on these two variables.

With EPA’s change to the Tier 3 model, the estimated drift from aerial applications has been substantially reduced. This will make it far easier for pesticide registrants to label their products for aerial applications, ensuring ag aviation industry’s customers can continue to rely on the aerial application of products to protect their crops.

This is a major example of what NAAA does for the aerial application industry—ensuring the availability of pesticides without unnecessary or burdensome restrictions.  It takes resources to accomplish this.  It takes membership so if you don’t currently belong to NAAA please click here to join.
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EPA’s Endangered Species Insecticide Strategy Ensures Aerial Applications of Insecticides Can Continue Thanks to NAAA’s Efforts

Earlier this week NAAA commented on EPA’s Insecticide Strategy (IS), a key part of EPA’s endangered species workplan. Lawsuits by numerous environmental activist groups forced EPA to act on bringing the pesticide registration and registration review process into compliance with the Endangered Species Act (ESA). Earlier efforts from EPA include the ESA work plan update, the vulnerable species pilot project (VSPP), and the ESA herbicide strategy (HS).

The IS is intended to protect ESA listed invertebrate species as well as those endangered species who rely on insects for their survival. The IS will be used in registration and registration review ESA risk assessments and decisions. The good news for aerial applicators is that, similar to the HS, there is absolutely no mention of a ban on aerial applications to protect ESA listed species.

For each pesticide and listed species group a risk level will be calculated, and then a downwind buffer zone distance between 0 and 320 feet will be assigned based on the level of risk. If the wind is blowing away from a protected area, then no buffer zone is required. Buffer distances can be reduced by using a larger droplet size, reducing application rate, applying in relative humidity greater than 60%, presence of a windbreak, and applying to a small field. The IS will utilize the Bulletins Live! Two website to show where pesticide use limitation areas (PULA) are located and the bulletins that contain the buffer zone distances.

NAAA commented on the IS, supporting the use of wind-directional buffers and methods to reduce them. NAAA expressed concerns on the overall complexity detailed in the IS and the potential to have more areas protected then is necessary to protect ESA listed species. NAAA also stressed the importance of making sure the process for aerial applicators to use the BLT system is as efficient as possible and easy to interpret. To read NAAA’s full comments, click here.
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NAAA Promotes Aerial Application Cover Crop Seeding Services in The Scoop Magazine

NAAA has actively promoted the benefits of aerial application services to farmers, ag retailers, and crop consultants across the United States through various advertising campaigns and articles in Farm Journal publications. In its August/September 2024 issue, The Scoop magazine published NAAA’s fourth and final article for 2024, titled “Aerial Applicators’ Role in Conservation Through Cover Crops.”

Early this year and late this summer, NAAA significantly focused on external communications through widely circulated Farm Journal publications. This included contributing a column to The Scoop’s publication in four separate issues, promoting aerial application services, their benefits, and guiding readers on how to locate NAAA Member Operators through the Find an Aerial Applicator database. The Scoop magazine is read by 20,000 farmers, ag retailers and crop consultants throughout the U.S.

Below are links to the 2024 articles published in The Scoop magazine and The Daily Scoop eNewsletter.

NAAA’s history of promoting aerial application services through national ads in agricultural trade media dates back to 2017. Last year, advertisements were placed in AgWeb, The Daily Scoop, and the CropLife E-Newsletter. 
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Pre-Register for the Ag Aviation Expo to Avoid Long Lines Onsite

We urge you to pre-register before Oct. 18 for the 2024 Ag Aviation Expo, which saves you $75 per person. Pre-registration helps us to have accurate food, beverage and seating counts at our events. In addition to attendee registration, there are still booth sales available for the NAAA Expo in Fort Worth, Nov. 18-21! You’ll hear from Kevin Humphreys, Australian war veteran, PTSD and mental health ambassador, at the Monday Kickoff Breakfast. Tuesday’s General Session features an aerial drift mock trial conducted by Anderson & Riddle, and you’ll hear from Noah Parr, Director of the Farm Labor Contractor Department for USA Farm Labor, on the ins and outs of the H2A program, which is hiring foreign workers.

If you want to grow your business, find a job or sell a product or service in the aerial application industry, the 2024 Ag Aviation Expo is the place for you! Our expo has everything from a world-class trade show floor featuring aircraft and helicopters to education sessions, expert speakers and many networking opportunities!  Convention room, board, travel and conference fees may also qualify as a tax-deductible business expense.

Getting to Fort Worth
Downtown Fort Worth is only 17.5 miles from the fourth-busiest airport in the world, Dallas-Fort Worth (DFW) International Airport, the best gateway into the Americas. With 149 direct domestic connections, you can reach any major city in the U.S. in less than four hours. If you want to fly your own aircraft Fort Worth Meacham International Airport is 5.6 miles to the convention center.

As you search your airfare options into Fort Worth for the Ag Aviation Expo, visit NAAA’s Transportation Discount webpage and explore tickets on Delta and United Airlines.

Driving
If you’d like to fly into another airport and drive to Fort Worth, below are driving times from several airports:

  • Dallas Love Field (DAL): 32.5 miles
  • Oklahoma City – Will Rogers World Airport (OKC): 200 miles
  • Austin-Bergstrom International Airport (AUS): 195 miles

Low-Time Pilot Registration
If you are an ag pilot with less than five years of experience or are interested in becoming an ag pilot, we are offering a special price to attend the NAAA Ag Aviation Expo for pilots like you. Further details are available here.

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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Operation SAFE Analyst Training Back on For Late October 2024

Shortly after a previously scheduled Operation S.A.F.E. Analyst Training for 2024 was canceled, renewed interest led to the scheduling of a new training. Here are the details:

Dates: October 28-November 1, 2024
Location: Lonoke, AR
Pre-register: Email your name, address, email, phone, and organization to Dennis Gardisser at dgardisser@icloud.com

You can read the full training brochure here. It has hotel information, registration fees, and a detailed course syllabus. 

This training is open to anyone seeking to become an Operation S.A.F.E. Analyst or Technician; no previous experience required. 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. Learn more about Operation S.A.F.E.
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The FAA has adopted a new airworthiness directive (AD) for some Airbus AS350 and AS355 Helicopters. This AD was prompted by reports of debonding on the leading edge protection of certain part-numbered main rotor blades (MRBs). 

The European Union Aviation Safety Agency issued EASA AD 2022-0246 in December 2022 to address this unsafe condition, which, if not detected and corrected, could lead to significant unbalance of the main rotor, a high level of vibration, failure of the main rotor, failure of the main gearbox, and subsequent loss of control of the helicopter. 

This AD requires accomplishing actions specified in the EASA AD, namely repetitive tap inspections of affected MRBs and repair or replacement as necessary in accordance with Airbus Helicopter Alert Service Bulletin (ASB) AS350-05.01.07 or AS355-05.00.91 as applicable. 

This AD (2024-15-08) is effective October 15, 2024 and can be viewed here.  
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In Case You Missed Last Week’s NAAA eNewsletter

Click here for the September 19, 2024 eNewsletter to read:

  • NAAA Works to Ensure EPA Retains Aerial Applications of Malathion
  • Gary Jerger Profiled in Local News for 50 Years of Service
  • Louisiana AAA’s Kim Brown Elected Fellow by American Association of Pesticide Safety Educators!
  • Thank You, NAAA Ag Aviation Expo Sponsors! Attendees, Register Today!
  • NAAA & NAAREF Board Meetings Oct. 10-12, in Chattanooga, TN

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