1200 New Jersey Avenue, SE 

West Building Grotmd Floor, Room Wl2- 140 

Washington, DC 20590 

Re: Comment Extension Request, "Operation and Certification of Small Unmanned 

Aircraft Systems" Docket ID: FAA-2015-0150 

To Whom It May Concern: 

The National Agricultural Aviation Association (NAAA) respectfully requests an extension of 

the comment period for 60 days on Docket FAA-2015-0150, "Operation and Certification of 

Small Unmanned Aircraft Systems." 

Aerial applicators have been protecting the nation's cropland since 1921, nearly 94 years. The 

NAAA was founded in 1966 and consists of more than 1,900 members in 46 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 important 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 telTain or dense plant foliage or late stage crops prevents the use of other 

methods of pesticide application due to the risk of crop damage, aerial application may be the 

only remaining method of treatment. NAAA estimates that 71 million acres of cropland are 

treated via aerial application in the U.S. each year. This does not include the aerially treated 

pasture and rangeland 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 are treated by 

all'. 

Aerial applicators fly as low a few feet above ground level when making applications and up to 

several hundred feet in the tumarounds and while ferrying, thus it is vital that safe low-level 

airspace exists to ensure these pilots can continue to do their jobs safely. There are 

approximately I ,000,000 agricultural aviation flights flown each year. Additionally, according 

to the Association ofUnmanned Vehicle Systems International (AUVSI) and Lux Research, 

agriculture is poised to be a significant use for small unmanned aircraft systems (UAS) following 

commercial integration. AUVSI estimates a $13.6 billion economic impact within the first three 

years of integration and $82.1 billion between 2015 and 2025. Lux Research says that agriculture 

drones could generate $350 million in revenues by 2025 from an estimated 330,000 U.S. units. 

1440 Duke Street, Alexandria, Va. 22314 

Telephone: (202) 546-5722 Fax: (202) 546-5726 www.agaviation.org 
patrol aircraft; power line maintenance helicopters; fish and wildlife service aircraft; animal 

control aircraft (USDA-APHIS-ADC); military helicopter and fixed-wing operations; seismic 

operations (usually helicopters); livestock roundup (ranching or animal relocation); aircraft GIS 

mapping of cropland for noxious weed populations and the like. 

NAAA is concerned that the widespread use ofUAS as projected in agricultural areas without 

being safely integrated for ag aviators to track and see, will result in conditions ripe for low-level 

agricultural aviation accidents. Not only could this result to harm and death for agricultural pilots 

and chemical spills resulting in environmental endangerment, but it could also result in a black 

eye for the promising UAS industry. 

Because of the added risks to aerial applicators and other low-altitude NAS users, along with the 

length and complexity oftllis 195 page rule, 79 page economic analysis and hundreds of other 

pages of documents within the docket; we respectfully request a 60 day extension to the 

comment period for the proposal. With the extended comment period NAAA intends to perform 

additional regulatory analysis in order to provide a through response to the FAA that is fully 

representative of the unique risks posed to aerial applicators operating in and around the airspace 

to be shared by small UAS. Thank you. 

Sincerely, 

Andrew D. Moore 

Executive Director 

National Agricultural Aviation Association