Comment from National Agricultural Aviation Association

Summary: The National Agricultural Aviation Association (NAAA) opposes the requested amendments to Exemption No. 25122, arguing that the proposed "shielded" techniques and ADS-B In are insufficient to mitigate the risk of midair collisions with manned aircraft. They express concern that granting this relief would set a dangerous precedent for future Part 137 UAS exemptions, potentially allowing for high-risk BVLOS swarming operations without visual observers.