nothing

1. Unmanned Aircraft and Ag
Aviation: Safety is the Key
Andrew D. Moore
Executive Director
National Agricultural
Aviation Association

2. Contents
• The Importance of Ag
Aviation
• UAS/UAVs in the News
• UAS Prospects and Potential
Uses
• UAS Rules
• Low-level Manned Aircraft
Hazards
• NAAA UAS Safety Concerns
• UAS Liability Issues
• Conclusion

3. The Importance of Ag Aviation
• 1,350 aerial application businesses
in the US; plus 1,430 additional non-
owner ag pilots.
• 18.75 percent of all crop protection
products applied on commercial
farms are done so aerially.
• 71 million acres of cropland each
year—doesn’t include pasture,
rangeland or urban uses.
• Used for crop protection; to protect
forestry; protect waterways and
ranchland from invasive species;
and control mosquitoes and other
health-threatening pests
• Allows rapid treatment of large,
remote areas; hard to reach areas
and orchards and late stage crops
without causing damage

4. UAVs in the News
Drone operator says he accidentally crashed
device on White House grounds
- The Washington Post 1/26/15
Man vs Drone: Some Pilots Fight Back Against
Robots - Wall Street Journal 1/15/15
FAA rules might allow thousands of
business drones- The Washington Post 2/15/15

5. UAV Prospects
• AUVSI Study
– $13.6 billion economic impact within the first three years of
integration, $82.1 billion between 2015 and 2025
• Lux Research Study
– Ag drones could generate $350 million in revenues by 2025 from an
estimated 330,000 U.S. units.
• Clemson University’s Edisto Research & Education
Center
– A UAV can analyze a 10-acre field in less than 5 minutes, work that
take a person days or weeks to complete
Market and Use Studies

6. Proposed Ag UAS Uses Being Conducted
Now by Manned Aircraft & Satellites
• Crop Sensing
– Crop condition assessment
imaging systems can be
used for pest detection.
– Airborne imaging systems
offer advantages over satellite
due to relatively low cost, high
spatial resolution, easy deploy-
ment and real time availability
of imagery for visual use.
– At 500 ft. a pixel covers 1.4 in.
and 500 ft. x 330 ft. of ground;
at 10,000 ft. a pixel covers 28 in.
and 1.9 mi. x 1.2 mi. of ground.
Nikon camera mounted on the step of an ag
aircraft. A GPS receiver and video monitor
integrated with the camera are mounted in the
cockpit.

7. Proposed Ag UAS Uses Being Conducted
Now by Manned Aircraft & Satellites
• Aerial Imaging
– Software can be used to
perform basic image pro-
cessing and create pre-
scription maps for precision
application.
– 2012 NAAA Survey found
that 21% of ag aviators use
flow control devices for
variable rate application
(precision agriculture).
– UAS are another tool that
can collect these images
and data for precision ag
A color image acquired at 4,000 ft. AGL over a cotton field
infected with cotton root rot using an ag aircraft. On the color
image, healthy cotton plants have a dark green color, whereas
infected plants have a grayish tone similar to bare soil.

8. UAVs Used for Aerial
Application Purposes
• UAVs in Japan
– 90 percent of crop protection
in Japan is performed by
UAVs (4 gallon RMAX
helicopter)
– Average farm size in Japan is
1.5 hectares (3.7 acres),
compared to 441 acres in the
US.
– RMAX hopper 4 gallons vs.
300+ average tank size for a
modern ag aircraft
– RMAX spraying speed 15 mph
vs. 160 mph for a manned ag
aircraft

9. UAV Efficacy and Cost Concerns
• Application efficacy issues with today’s UAVs compared
to larger manned ag aircraft due to downward thrust-to-
weight ratio—the amount of air pushed down to the crop
canopy—from a rotor or fixed wing—is proportional to
the weight of the aircraft that the air is holding up.
• Larger ag aircraft aide in thorough and efficient
application of crop protection product
• A four gallon, 15 mph Yamaha R-MAX costs $86,000.
Large UAVs cost in multi-millions of dollars and are not
available for application. Manned ag aircraft range from
$100,000- $1.5 million (800 gallon 160 mpg) and by far
have the cost, speed and efficacy advantage.

10. FAA Rules for UAVs
• UAVs first mentioned in 2004 FAA
Reauthorization (P.L. 108-176)
• Extensive provisions provided in the FAA
2012 Reauthorization
– Mandate for full integration by Sept. 30, 2015
– Propagation of special rules for UAVs under
55lbs (released for comment February 2015).

11. Current FAA UAS Use Policy
• Methods of legal UAV commercial
operation:
– Petition for a use under Section 333
– Operation under the Small UAS Rule (expected
promulgation 2017)

12. Sec. 333 Petitions
• Established under the 2012 reauthorization,
permits limited use of UAVs for commercial
purposes
• Administrator must consider at a minimum
the UAVs size, weight, speed, operational
capability, proximity to airports and populated
areas, operation within visual line of sight,
and national security implications

13. Sec. 333 Petitions (con’t.)
• Currently 325+ petitions pending (Many granted)
• Sectors vary from agriculture, to real estate to filming to
search-and-rescue
• NAAA has commented on a number (60 thus far) of
these petitions
• Remain only legal method of commercial use until final
small UAS rule is adopted (estimated 2017)
• Exemptions granted require private pilot’s license, 48
hour NOTAMs, operation within line of sight, preflight
inspection, and registering the UAV with an N-number.

14. Small UAS Rule
• On Feb. 15, 2015 the FAA released
it’s long awaited small UAS rule
• Ignored many of NAAA’s UAS
recommendations and even the
agency’s own safety measures used
in Sec. 333 exemptions

15. Small UAS Rule
Summary
• Applicable to UAS 55 pounds or less being operated for
compensation or hire
– Not applicable to “model aircraft,” (operated for hobby or recreational
purposes)
– Prohibits some operations (external load, air carrier, international, and
foreign-owned aircraft). Prohibits night operations.
• Requires operation within “visual line of sight” of the operator.
– Operator may only operate the UAS within range of “natural vision”
– UAS must give way to manned aircraft

16. Small UAS Rule
Summary
• Operator must self-certify that they have no condition that would medically
prevent them from seeing and avoiding aircraft (no medical exam required)
• Creates training requirements for operators
– Written operator exam to be taken at a FAA certified test center
– A recurrent written test must be retaken every two years
• Requires UAS to be registered with the FAA
– UAS must receive and display on the aircraft a aircraft registration number “N number”
• Operator must assure prior to flight that the aircraft is airworthy
– Unlike manned aircraft, there is no requirement for a FAA certification for airworthiness
• Requires coordination with ATC when operating in controlled airspace and
airport operators when operating near airports

17. Low-Level Manned
Aircraft Hazards
– Birds: birds try to avoid
collisions, they are very
motivated and usually they
take sufficient evasive
action to avoid their peril,
yet…
– Birds are the second
leading cause of aviation
fatalities
– 142,000 wildlife strikes with
civil aircraft between 1990
and 2013, with 25 fatalities
Above: Luckily, operator Steve Fletcher only
sustained minor injuries when a buzzard blew out
the cockpit window of his Air Tractor 802 while he
was flying.

18. Low-Level Manned
Aircraft Safety Hazards
• Unmarked Towers
– Since 2005 7 percent of aerial
application accidents were the
result of collisions with towers
– Since 2005 15.5 percent were
the result of collisions with wires
• UAS? June 2014 Washington
Post Article:
– 400 accidents/incidents
involving military UAVs
– Dozens of near-misses
between commercial aircraft
and illegally operating UAVs
– Two near misses between ag
aircraft and UAVs in 2014
Fatal Air Tractor collision with a meteorological evaluation
tower (MET). August 2013.

20. Fatal Accidents (Ag Aviation)--2014
»

21. NAAA’s UAV Safety Concerns
• UAV inability to “Sense and Avoid,” Manned
aircraft’s inability to see/sense UAV
– GAO: No adequate technology currently exists
that would allow UAVs to sense and avoid other
traffic
• Security Concerns
– UAV “spoofing” or hacking
• “Lost Link” concerns
– Some aircraft have no lost link procedure and
continue flying until they hit a obstacle or run out
of fuel

22. NAAA Safety Recommendations
• NAAA is urging the FAA and Congress that
UAVs be required to have:
– ADS-B Out transponders
– Strobe lights
• To identify operator’s vehicle (line of sight) and UAV
– Marking similar to that required for other low-level
obstacles (aviation orange and white paint)
– Monitoring of a locally defined radio frequency
– Distraction-free operation of the UAV

23. NAAA Safety
Recommendations (continued)
• Pilot training:
– Commercial pilots license and UAS operations type-rating
– Reoccurring training
– Class 2 Medical
– Commercial Pesticide License if treating crops, if used for
application
• Operation within visual range of the operator (line-of-sight)
• Aircraft airworthiness
– Similar to manned aircraft, certified airworthy

24. NAAA Safety
Recommendations (continued)
• Medically qualified observer (line-of-sight)
• Registered with an indestructible “N-Number”
• Issuances of NOTAMs when UAVs are operating
• Immediate grounding of the UAV if a low-level
manned aircraft is operating within two miles

25. Small UAS Rule vs. NAAA’s
recommendations
• Accepted NAAA Recommendations
– Mandatory UAS registration
– Manned aircraft have the right-of-way over unmanned aircraft
• Ignored Recommendations
– No ADS-B Out requirement
– Strobe lighting
– No medical requirements
– No airframe certification
– No pilots license or UAV experience necessary (written test
only)
– No aviation orange and white painting
• NAAA is filing comments

26. Responsibility and Liability
• UAV Insurance currently offered by certain insurance
providers
• § 107.37 of FAA Proposed Rule for UAV’s states: “(2)
Yielding the right-of-way means that the small unmanned
aircraft must give way to the aircraft or vehicle and…No
person may operate a small unmanned aircraft so close
to another aircraft as to create a collision hazard.”
• Farmer insurance policies typically only cover between
$100,000 and $300,000 in damages, and only in limited
circumstances if at all when it comes to aviation
• $6.7 million wind energy settlement demonstrates liability

27. Conclusion
• NAAA supports the safe integration of UAVs into the NAS,
and urges the FAA to carefully consider all of the manned
aviation industry’s safety concerns when integrating UAVs into
the national airspace and urges the agency to follow a
comprehensive, well thought out safety-oriented approach
using the association’s recommendations.
• UAVs will likely not be used for spraying anytime soon, but
have crop sensing, aerial imaging and other non-application
capabilities. Manned aircraft, such as ag aircraft are able to
conduct crop sensing and aerial imaging services too.
• Considerable liability risk for UAV operators and providers.

28. Questions?
National Agricultural Aviation Association
www.agaviation.org
admoore@agaviation.org
202-546-5722