Herbicide spraying using drones in the US


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Can someone point me to the FAA laws or rules regulating the use of UAVs to spray herbicide on crops and pasture land in the USA? What is required? What is allowed? Apologies if this subject has been covered here before. I am having difficulty in finding much information. 

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I'm guessing from your Avatar that you know something about ranching and possibly farming.  So you're probably aware operators who apply crop protection products operate under the watchful eye of many federal and state agencies. They include the Environmental Protection Agency (EPA), Department of Homeland Security (DHS), Federal Aviation Administration (FAA), Department of Transportation (DOT) and individual State Departments of Agriculture, Ecology, and Environment.

All of these agencies require strict and specific documentation of each field sprayed. These same agencies continually monitor environmental and public health to assure that we continue to have the safest, least expensive, and most abundant food supply in the world.

Again, I'm guessing that it is not legal to apply any airborne chemical from a UAS in the US, not simply because of the FAA but all of the other alphabet soup government agencies.   

Here's the FAA circular for manned crop dusting.

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_137-1.pdf

 

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Thanks for your reply Av8Chuck.  Very familiar with herbicide application rules and regulations.  Ranching/farming background and business, MS in Animal and Range Sciences, commercial herbicide applicator business covering 2 states.  Also have remote pilot certificate that we utilize in crop scouting, weather damage, etc.  Seems to not be a great amount of solid information out there on the spraying with UAVs.

I had a response from a law firm and university professor on a closed FB group say that the only requirements were a Part 107 waiver for the 55 lb weight rule (obviously would require a heavy payload to do any serious spraying) and a Part 137 Ag Aircraft Operator Certificate, as well as a state applicators license for restricted use (which I have). Even if we had the required waivers/certificates, I have a feeling the cost of the equipment may be prohibitive to pursue such a business :)  Just curious mostly.     

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Thanks for the reply Ed.  You are spot on, the information I was directed to is from Rupprecht Law. If they are correct in their information, the legal barriers to entry into such a business are not as high or difficult as I thought they might be. The financial barriers to entry may be another matter. 

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RW,

You have obviously done your home work on this topic. I know of only 2 Part 137 drone operations at this point, and most recently (last week) it was awarded to a guy servicing the mosquito control application. The initial 137 certificate was a part of the FAA IPP program and was awarded to Lee County Florida mosquito control operations who will fly a fixed wing drone. But you are already a State certified applicator so the main certificate remaining is Part 137. This certificate includes an onsite inspection of your operation. Since these regulations are on the books for manned aircraft it depends on your relationship with the local FAA as to how interested they are to buckle down and assist you with granting your certificate for drone use by having to interpret the existing law and apply it to drone use. For instance the law stipulates the aircraft to carry a certain level of fire extinguisher. So getting a bureaucrat to think outside of the box might be an obstacle.

My suggestion for you is to look at the several YouTube videos that demonstrate the use of the DJI Agras system. It has been on the market for over a year now. It does an adequate job but is very limited in terms of automated flight programming as it requires you to actually input the perimeter of your field and or delineation of obstacle areas to avoid. This is done by either bringing the actual remote control around your perimeter and clicking the input of a waypoint until you have the entire area input. Or if you choose the RTK option it will still require you to specify the individual waypoint but using a base station and rover instead of the remote control.

There are a couple of other non DJI machines available so perform some internet searches too for drone crop dusters or similar. If you have a large DJI reseller near by that actually could provide service if needed then you would be far ahead. Once you focus on the machine you will begin to notice some limiting factors, the most apparent is flight time and cost of additional batteries. It is ideal for spot applications of herbicides versus large acreage needs. I have seen demo flights of the system and if you are in hilly locations, the latest version of the Agras will also provide terrain contour automation for altitude control. If you currently fly a DJI aircraft then you will not be impressed with the flight pattern input, but once you go through the field setup you will be able to save these flights for future missions.

Some of the spray nozzle choices might be an issue but I think there is some commonality for adding industry standard alternates depending on your products used and or surfactant added etc. Again your current expertise will be helpful in addressing this issue.

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Cyclops- Thanks for your input. No contact with anyone at Flight Standards Office yet.  

FYI to anyone following this, apparently an individual named Robert Blair is doing a pre-conference class called Spray Drones in Agriculture at InterDrone in Las Vegas Tuesday September 4th at 11:00.  He is to be covering rules/regulations as well as challenges facing this use of drones. 

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Hi Ranchwise! This is Piper from Leading Edge Associates. We have been applying pesticides for mosquito (our background for over 30 years - Lee County Mosquito Control is one of our customers) and weed control for almost 2 years now. We are also testing UAS application technologies for certain agricultural crops - particularly rice. And yes, the state regulations can be quite variable but you will need the 137 regardless. We are one of only a handful of pesticide UAS applicators in the US and it took us 3 years to get to this point through regular contact with the FAA. Our exemption includes the Yamaha RMAX as well as other aircraft including our own engineered systems. We are also a DJI dealer so we have experience with the Agras MG-1 and MG-1s (using RTK in the rice fields to control for weeds). But currently our favorite aircraft is the PV600 (PrecisionVision 600) - engineered from a DJI Matrice 600 airframe but redesigned to perform granular and liquid applications using our own flight planning software. We also teach classes in aerial applications using UAS as well as sell the systems plus we do contract applications in several states (California, Utah, Colorado, and Montana to name a few). We would be more than happy to discuss the opportunities (and challenges) available to you. You can check out our website www.leateam.com for more information. Bill Reynolds is the person to contact. It would be great to see more folks with backgrounds like yours getting into UAS applications and the costs are not as expensive as you may think. I have attached photos of Bill and the PV600 set up for granular applications.

IMG_5146.png

Edited by Leading Edge Associates
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