Comment from Anonymous

This petition submitted by Kirk Timber & Land Management, LLC, represented by ROcoza LLC, requests permission to legally operate unmanned aircraft systems (UAS) weighing over 55 pounds for the purpose of commercial agricultural practices. While this may appear as a great technological innovation on the surface, using unmanned aircraft systems for agriculture actually poses many risks, environmental concerns, potential hazardous health concerns, and many other downsides. It is for this reason that I am against this petition that supports the legalization and usage of such machinery in the practices of agriculture. One of the main issues about this petition is that it proposes the legalization of using heavy drones for commercial agricultural practices under the assumption that these heavy drones can be operated safely. However, further research has been conducted the opposite, that there are and will be high safety risks that are unresolved. MDPI published an article written by Gang Zhong and several other contributors, titled “Safety Risk Modelling and Assessment of Civil Unmanned Aircraft System Operations: A Comprehensive Review”, that does this. This article says “Civil UAS operations bring novel safety issues distinct from traditional aviation, like ground impact risk…” This is just one of many instances that the article highlights that utilizing unmanned aircraft systems bring challenges and issues that are not fully understood or accounted for in current frameworks. The article also points out another issue that I had researched, which is the fact that human error is still a major cause of UAS incidents. The article says, “The proportion of UAS incidents and accidents directly related to flight crew/pilot error was found to be approximately 48%.” This means that even though UAS provide automation, it is the human operators that still introduces a high failure rate. While this can easily be concluded as a user issue and not a problem with the hardware, it can also be argued that even with trained professional pilots, the technology is still difficult to use, prone to bugs and other issues. Another issue related to legalizing heavy drones for commercial agricultural practices is the health risks that come with it. The petition suggests that these heavy drones will be used to complete several agricultural tasks, which also includes the use of airborne pesticides on crops and vegetation, which are, without a doubt, a hazardous risk to human health. Titled “Airborne Pesticides from Agricultural Practices: A Critical Review of Pathways, Influencing Factors, and Human Health Implications”, Pubmeb published an article that discusses this. They say in the article, “The review delves into the effects of airborne pesticides on human health and their contribution to anthropogenic air pollution.” The petition itself involves aerial pesticides being sprayed by these heavy drones, which would naturally increase the risk of pesticide drift and airborne exposure which could lead to long lasting negative effects on nearby ecosystems and communities. There is another important issue I’d like to point out regarding the idea of legalizing heavy drones for commercial agricultural practices. This issue revolves around the general software security of the drones being operated, alongside the potential risks. The petition assumes that these drones will operate safely and conduct reliable operations. However, there has been several research done that promotes otherwise. Specifically, there is an article titled “A Survey on Security and Privacy Issues of UAVs” published by Cornell University. Their article states, “The development of drone technology is associated with vulnerabilities and threats due to the lack of efficient security implementations.” This article, among many others, highlights that drones are not secure enough for broad deployment, especially those involving potentially hazardous and dangerous materials like pesticides. In addition to this, the fact that drones are run by software like many other devices, makes it easily vulnerable to hacking attacks, especially without the proper security implementations. I am studying to become a software engineer and have worked with programmers in the past that have worked on developing prototype drones. I can certainly say that they have even created devices that take a lot of time to make and even more time to implement security into the software. Without that security programmed into these hypothetical drones for agricultural use, I highly doubt that they will provide more benefits than harm to the environment, especially if they are handling potentially dangerous things like pesticides into important assets such as crops. Until these problems are resolved or at least addressed, I oppose the use of UAS in agricultural practice.