April 22, 2013
Docket Operations, M – 30
U.S. Department of Transportation
1200 New Jersey Avenue, SE
West Building Ground Floor, Room W12 – 140
Washington, DC 20590-0001
Re: Docket Number FAA 2013-0061
To whom it may concern:
The National Agricultural Aviation Association (NAAA) is pleased to provide the FAA with our unique perspective as it relates to the privacy issues at the six test sites designated for UAS testing, research and development. NAAA believes the FAA’s primary focus should be the safety of the existing airspace, whether that be the upper reaches of the national airspace or low-level airspace. No integration of UAS’ into the airspace should occur until it is certain that it will not compromise the safety of current users of the national airspace system.
Importance of Aerial Application Industry. The NAAA consists of more than 1,800 members in 44 states, and represents the interests of small business owners and pilots licensed as commercial applicators that use aircraft to enhance the production of food, fiber and bio-fuel; protect forestry; protect waterways and ranchland from invasive species; and control health-threatening pests.
Aerial application is vital to agriculture, forestry and public health protection because it is by far the fastest method of application. Furthermore, when the presence of water, wet soil conditions, rolling terrain or dense plant foliage prevents the use of other methods of pesticide application, aerial application may be the only remaining method of treatment. Moreover, aerial application is conducive to higher crop yields, as it is non-disruptive to the crop and causes no soil compaction.
Applying crop protection products by air is an essential component of no-till or reduced tillage farming operations which limit storm water runoff and reduce soil erosion. These farming methods, through their preservation of organic matter and topsoil, help maintain productive soils and reduce greenhouse gas emissions through the sequestration of carbon.
According to the USDA’s Economic Research Service, there are a total of 408 million cropland acres in the U.S. Approximately 70 percent are commercially treated with crop protection products, and an estimated 25 percent of commercial crop protection product applications are made through aerial applications.
As a result, NAAA estimates that 71million acres of cropland are treated via aerial application in the U.S. each year. This does not include the aerially treated pasture and range-land of which there are 614 million total acres in the U.S. or the 671 million total forestry acres and 61 million total urban acres in the U.S.—a portion of which is treated by air.
