Dear California Department of Pesticide Regulation,

As CEO of UAV-IQ, a veteran-owned certified pest control business, we strongly believe that we have the unique knowledge of how to safely conduct aerial applications of beneficial insects and that we are the proper authority to educate, train and supervise drone pilots who apply natural enemies. Scheduling and studying for an exam which has no content at all about drones or biological pest control creates an unjustifiable burden on drone pilots. Instead, we suggest that CDPR requires that the companies providing drone-performed biological pest control be certified as currently required, removing the requirements for having insurance policies against pesticide exposure liability since they don’t use pesticides. This approach would allow companies such as UAV-IQ to hire more drone pilots and safely and efficiently expand the usage of pesticide alternatives, and thus aid CDPR in its goals of reducing pesticide usage in California. It would also enable us to employ more veterans who are looking for seasonal work flying drones in agriculture.

Our company has lost potential pilots due to this requirement, and as a result, we have not had enough operational capacity to service some clients. Some of these clients were forced to use pesticides since they did not have a workforce available to apply the beneficial insects and mites they wanted to use. We strongly feel that the aerial application companies which provide biological pest control services and have demonstrated that they help growers use safe alternatives to pesticides can supervise drone pilots and ensure that they operate safely without having to force pilots whom they want to employ to take an exam which is not actually relevant to their work.

CDPR’s Sustainable Pest Management Roadmap for California affirms that the release of beneficial insects is a tool which will help reach the goal of meaningful reduction of pesticide usage in California agriculture. It is proven to be effective when implemented as a key component of an IPM plan, and has none of the risks associated with pesticide usage which CDPR is seeking to mitigate; health risks to the field workers, wind drift that impacts neighboring communities, water contamination and other environmental issues. CDPR’s requirement for all drone pilots who release non-registered/non-chemical pest control products to obtain an APC, even products which the FAA specifically states do not require an Agricultural Pilots License (Part 137 Certification), is counterproductive to its goal of increasing the adoption of biological pest control.

We urge CDPR to reconsider the current requirement and work with certified pest control businesses like ours to find a more efficient and effective way to promote the use of pesticide alternatives through drone-performed biological pest control. We believe that this change would allow us to hire more drone pilots and safely and efficiently expand the usage of pesticide alternatives, which would benefit the growers, the environment, and the state of California as a whole.

Sincerely,

Andreas Neuman,

CEO of UAV-IQ