By Charles L. Werner, Chair - IPSA Unmanned Aircraft System Committee
Almost every week there are news stories about how public safety is using unmanned aircraft systems (UAS, also called drones). There are documented public safety uses such as structural firefighting, wild land firefighting, hazmat incidents, search and rescue, radiological incidents, lifeguard operations, shark shoreline patrols, technical rescue operations, critical infrastructure inspections, pre-incident planning, damage assessment, flood rescues, delivery of medicine/AEDs and more. After a three-year journey into the world of drones, I continually learn new aspects about the ever-changing world of drone technology, payloads and the associated rules and regulations.
Know the National Airspace System
Flying a UAS or drone comes with a great deal of responsibility as every aspect of flight involves the National Airspace System. Flying in the NAS requires knowledge of the different classifications of air space which dictate where a remote pilot can and cannot fly. There are some areas like the National Capitol Region near DC that have very strict flight restrictions.
Additionally, there are restricted air spaces where UAS either cannot fly or require special permission. As a remote pilot of a drone, you must have knowledge of both manned and unmanned flight operation in order to safely fly as both are operating in the NAS. This requires the knowledge to read aeronautical sectional charts, understand weather and UAS limitations.
Additionally, daily activities on the ground (emergency incidents, wildfires, large public events, VIP movements, etc.) can generate Temporary Flight Restrictions (TFR) which limit UAS operations for a specified period of time.
Know your Missions
Before jumping into purchasing a UAS, know how your organization can and will operate a UAS program. Knowing your mission(s) will be the single most important information to make the correct selection of a drone. It is also important to identify how the UAS will be used as it has a direct bearing on the required remote pilot certifications.
Know your UAS operations options
There are a number of options to obtain UAS capabilities. If you are unsure about developing a department drone program, you might consider a contractual service from a private UAS company. This can be established in advance, and you would only pay as agreed and when needed.
Another option is to explore if neighboring public safety organizations have a UAS program and see if it is possible to utilize their UAS capability through a mutual aid agreement. Another option would be to join with several public safety organizations to create a regional public safety UAS program. This allows sharing the financial costs and human resources needed to sustain a UAS program. Last, but not least, is to develop an in-house UAS program.
Know certification requirements
Before deploying your department's UAS, you must know certification requirements established by the FAA. This is very important to understand as there are two very distinguishable paths for UAS flight operations.
- Public flight operations (Certificate of Authorization or COA)
- Civil flight operations (14 CFR Part 107 Rules)
Each set of rules have unique nuances that you must be aware as it relates to flight operations.
Option 1: Public flight operations
Public flight operations are defined as those flights that are performed as a tribal, local, state or federal government entity.
Under a COA, public entities can self-certify its pilots and various program elements. The problem is that there is no reference or basis for the self-certification which leaves each agency to develop/define their own self certification process which creates some significant liability concerns for risk managers.
Option 2: Civil flight operations (14 CFR Part 107 Rules)
Civil flight operations are inclusive of the general private sector. Civil flight operations require remote pilots to pass an FAA Knowledge Test to meet the requirements of 14 CFR Part 107 Rules. This test is designed to ensure that remote pilots understand the NAS and the general FAA Rules and Regulations related to UAS operations and safety. This test must be taken at an official FAA Test Site, has a $150 fee and must be renewed every two years. Unfortunately, there is no practical training or skills testing.
NOTE: There is a general consensus that public entities should require their remote pilots to take the FAA Knowledge Test (Part 107). This is done to ensure that remote pilots have the necessary knowledge of the NAS, FAA Rules and Regulations, general UAS operations and safety.
Know FAA rules and regulations
It is necessary to know and abide by FAA Rules and Regulations to ensure that all UAS flights are done in a safe, legal and effective manner. These rules outline the NAS requirements, flying parameters and UAS specific requirements such as weight, speed and flight altitude.
Know the scope and effort
Starting a UAS program in your department is a huge undertaking. A UAS program must address training requirements, UAS and payload care & maintenance, flight documentation, data requirements, remote pilot proficiency, insurance/liability, public outreach and thorough documentation on all program elements.
Know where to look for information
Fortunately, there is an organization that has been established to advance Public Safety Unmanned Aircraft Systems. This organization is the National Council on Public Safety UAS and its website URL is http://publicsafetyuas.org. The IPSA is actively involved with the National Council and participates on its Governing Board.
Webinar: Drones/UAS and Public Safety