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Q+A: FAA considerations for getting operational with UAS in public safety

31 Aug 2017 6:43 AM | International Public Safety Association (Administrator)

By Mr. John Meehan UAS Integration Office, AUS-430, Safety & Operations Branch, FAA

Mr. John Meehan was one of four panelists during the 2017 IPSA Webinar Week – FAA Considerations for Getting Operational with UAS in Public Safety. Hundreds of public safety professionals attended the event. The IPSA selected the top questions by the audience and Meehan responded.

Our department wants to get a new UAS program in place. Who do I contact first at the FAA to get started?

Download the FAA Advisory Circular AC 00-1.1A and review the Statutes (49 USC 40102 and 40125) concerning public aircraft operations (PAO) to help you understand if your entity qualifies to operate as a PAO. Not all public safety entities qualify to operate as a PAO under the Statutes (must be a political subdivision of a State, for example) and some missions will not meet the “governmental functions” listed in the Statutes to be flown as a PAO, and therefore must be flown under the civil rules, Part 107. And then if you have additional questions, we invite public safety entities to reachout to Steve Pansky and/or John Meehan, until there is some basic starter information posted on the FAA website.

What are the requirements for demonstrating UAS airworthiness?

107.13 Registration.  A person operating a civil sUAS must comply with the provisions of 91.203(a)(2).  The procedures for registration are on

107.15 Condition for safe operation applies here. Prior to each flight the RPIC must check the sUAS to determine whether it is in a condition for safe operation.

107.49(c)(d)(e) Preflight Familiarization, Inspection, and Actions for Aircraft Operation also applies. Again, prior to each flight the RPIC must ensure that all control links between ground control station and the sUA are working properly; ensure that there is enough available power for the sUAS to operate for the intended operational time; and ensure that any object attached or carried by the sUA is secure and does not adversely affect the flight characteristics or controllability of the aircraft.

How much concern should public safety agencies place into security concerns over foreign UAS products and software? And will agencies such as DARPA weigh in on the issue soon? Does the FAA have an official stance?

The FAA is most concerned about safety of the NAS and people and property on the ground. Security concerns should be determined by each public safety entity in accordance with their own needs and requirements.

The FAA website had sample COA's that you could look at for best practices. Those appeared to be taken down in May or around that time frame. Is there an opportunity for them to come back?

COA applications are not cookie cutter exercises as each entity has their own unique circumstances and missions, and some of the information in the COAs is protected. The FAA does not publish the approval of all COAs for public agencies, however for there are some older COAs available that were requested under the FOIA. 

However, these examples are relatively old and may not be good examples for your use. UAS in the NAS is evolving every day and requirements change as we learn more or modify our processes, knowledge, and expectations from operators, for example.  For Civil Part 107 approvals, the location was renamed and the new locationIf you want to obtain Part 107 waivers, pay close attention to the Safety Waiver Guidelines and answer those requirements carefully and thoughtfully. Remember that the FAA’s mission is the safety of the Airspace (NAS) and those who use it, so keep the safety of the NAS and persons and property on the ground foremost in your mind as you complete the applications. Don’t assume technology by itself will solve the fundamental safety issue.

Who do I contact to speak about removing DJI geofencing that is hampering our jurisdiction? Name, phone, email please.

You’ll have to contact the manufacturer or software producer on that issue. 

Can you go over a few of those UAS use cases for law enforcement and the fire service to help demonstrate the need for a UAS program?

Use cases are best developed from discussions with your fellow public safety entities who have successfully implemented UAS, and with your leadership and community to determine who, what, when, where, why, and how you will deploy your UAS. We suggest you reach out to trade associations, interest groups, and fellow first responders who have developed those use cases since the applications for UAS are infinite. The FAA does not favor or disfavor any particular use case, as long as they comply with the regulationss and laws and do not compromise safety.

About the Author

John is a Management & Program Analyst and Industry Liaison in the Federal Aviation Administration’s (FAA) Unmanned Aircraft Systems (UAS) Integration Team, located at FAA Headquarters in Washington, DC. In this role, John provides technical support, subject matter expertise, and performs detailed research in response to inquiries from within the agency, other agencies, industry, Congress, and the general public, and coordinates responses with appropriate FAA personnel. John holds a Commercial Pilot Certificate with Instrument rating rotary wing, a Private Pilot Rating with Instrument rating, single engine land airplane, and a UAS Remote Pilot Certificate.

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