Comment from Stu Sprung

Public Comment in Support of Seneca's Petition to Amend Grant of Exemption No. 25122 I submit this comment in support of Amor Fati Industries Corp. (d/b/a Seneca) and its petition to amend Grant of Exemption No. 25122. I offer this perspective based on more than 35 years in the fire service and aviation. I previously served as Chief of Flight Operations for CAL FIRE, where I helped oversee operations of one of the world's largest dedicated aerial firefighting aviation programs. In that role, I helped evaluate and integrate new aircraft, technologies, and operational concepts into public safety aviation while ensuring they could operate safely alongside existing crewed aircraft. I currently serve as Vice President of an aviation research and development division, where I continue to work closely with emerging technologies focused on improving wildfire response. The views expressed here are my own and are based on my professional experience. From my perspective, this petition represents more than an individual exemption request. It is part of a broader evolution in how public safety aviation will operate within the National Airspace System (NAS) over the coming decade. Wildland firefighting continues to face longer fire seasons, increasing fire intensity, expanding development in the wildland-urban interface, and growing demands on limited aviation resources. Initial attack remains one of the most effective opportunities to reduce fire growth, protect lives and property, and reduce overall suppression costs. Providing firefighters with additional tools that can respond rapidly, particularly during periods when traditional aviation resources are unavailable, delayed, or operating under higher risk, is in the public interest. Importantly, I do not view systems such as the Seneca Argo-3 as replacements for crewed airtankers or helicopters. Rather, they represent an emerging capability that can serve as a valuable force multiplier for ground resources and existing aviation assets. Used appropriately, these aircraft have the potential to provide persistent surveillance, rapid initial attack, suppressant delivery, cargo transport, and other mission support, particularly in high-value, low-coverage, or difficult-to-access areas. Throughout my career, one of the most important considerations has always been the safe integration of aircraft operating in shared airspace. Through my discussions with Seneca and by observing its development approach, I have been encouraged by the emphasis placed on layered safety mitigations, operational discipline, detect-and-avoid technologies, ADS-B In, shielding concepts, and engagement with end users. Equally important, the company has invested significant effort in understanding operational needs directly from firefighters and public safety agencies before developing technical solutions. In my experience, that operationally driven approach is both uncommon and valuable. Looking beyond this individual petition, I believe the FAA has an important opportunity to establish an appropriate regulatory path for public safety UAS operations. Commercial UAS activity is expected to increase substantially over the coming years. Some forecasts suggest commercial UAS operations may outnumber crewed aircraft flights in portions of the National Airspace System by five to ten to one within the next five years. As this transition occurs, it will be important that public safety operations are not simply accommodated within the evolving regulatory framework, but intentionally considered alongside larger commercial interests. Beyond Visual Line of Sight (BVLOS) operations will be a critical component of that future. Technologies supporting safe BVLOS operations, including layered detect-and-avoid systems, ADS-B In, infrared sensing, LiDAR, redundant flight systems, and increasingly capable autonomous decision support, are advancing rapidly. While innovation is moving quickly, it is equally important that regulatory pathways continue to maintain the exceptionally high safety standards that define the National Airspace System. In my opinion, companies that have demonstrated technical maturity, operational discipline, and a sustained commitment to solving real public safety problems should have a clear and rigorous pathway to demonstrating these capabilities. Based on my experience, I believe Seneca represents one of the more mature and operationally informed efforts currently underway in the wildfire UAS sector. For these reasons, I respectfully support Seneca's petition to amend Grant of Exemption No. 25122. Approval would not simply benefit one operator. It would represent another measured step toward integrating a new class of public safety aircraft into the National Airspace System in a manner that enhances safety, strengthens wildfire response capabilities, and ultimately improves outcomes for firefighters and the communities they serve.