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How to develop, deploy a successful (and legal) sUAS program

10 May 2019 10:44 AM | International Public Safety Association (Administrator)

By Phil Raum, Maryland Emergency Response System and IPSA UAS Committee Member

The goal of creating a drone program is to create a deployable sUAS capability to meet the agency’s mission requirements. Generally, building a capability requires several tasks associated with planning, organizing, equipping, training, and exercising. Just buying equipment does not necessarily give an agency a deployable capability. There are usually policy and training issues that need to be addressed with the purchase of equipment, and sUAS equipment is no exception.

Here are 10 tips to assist an agency in developing a legally deployable drone capability. 

1. Define objectives and outcomes. Clearly define the outcomes the agency wants to achieve with the sUAS capability, such as:

  • Situational awareness.
  • Payload delivery.
  • Search and rescue.
  • Other.

2. Create policy, plans and procedures. Develop appropriate agency policy, plans and procedures for deploying a drone capability that cover the entire range of drone activities.
  • FEMA considers drone equipment to be controlled equipment; therefore, if the agency is using federal grant funds to purchase drone equipment, FEMA must approve the agency’s policy prior to the agency spending grant funds on that equipment. 
  • Policy should be compatible with political leadership requirements.
  • Policy addresses all legal privacy concerns, as well as other community concerns.
  • Policy addresses evidence retention issues for video, photos, and other sensory information gathered. 
  • SOPs and operations manual. 
  • Mutual Aid Agreements (MAA’s), where appropriate.

3. Comply with all legal requirements. Ensure that the agency complies with all federal, state, and local laws, regulations, and case law.

  • The Federal Aviation Administration has authority to regulate the nation’s air space
  • The FAA’s website lists all appropriate laws and regulations for sUAS operations.   
  • Public Safety agencies can operate drones under a COA (Certification of Authorization) or a 14 CFR Part 107.  There are advantages and disadvantages to each option.  The agency needs to be familiar with them in order to choose the option that best meets the needs of the jurisdiction or agency. 
  • There is federal case law that addresses privacy rights as it relates to surveillance by sUAS vehicles. 

4. Identify risks and mitigation strategies. Identify risks associated with developing and deploying this this capability and the strategies to mitigate those risks, such as:

  • Political support.
  • Senior leader support.
  • Damage to drones and private property.
  • Personal injury.
  • Staff time for training.
  • Budgetary sustainment of this capability over time.
  • Maintenance.
  • Evolving technologies.
  • Legal and regulatory changes.

5. Develop a realistic budget. Ensure that the agency’s budget addresses all the expenses associated with developing a deployable capability.  There is a significant risk that equipment will be damaged or destroyed during training and/or deployments. 

  • sUAS vehicles and replacement vehicles
  • Control equipment
  • Batteries and chargers, enough to sustain extended flight times. 
  • Replacement parts, e.g., rotors
  • Signal amplification equipment
  • Operator training
  • Landing pads
  • Software for aerial mapping, live-streaming and GPS.

6. Consider building the sUAS capability in phases.

  • Build upon lessons-learned during real world deployments and exercises. 
  • Leverage the development and advancement of technology over time.  

7. Ensure all the right people, disciplines and agencies are involved. Ensure that all the appropriate personnel, disciplines, and agencies that should be involved in the development of the sUAS capability are, in fact, involved and can weigh in on that process. 

  • Political leadership.
  • Agency senior leadership.
  • Agency legal representatives.
  • Budget personnel.
  • Community leadership (Experience has shown that involving the community in the capability development early in the process can significantly increase public support for a sUAS program.).
  • Risk managers.
  • Drone SMEs.
  • Unions and collective bargaining units.
  • Jurisdictional and agency technology review committees. 
  • End-users.
  • Others.

8. Buy the right stuff appropriate for the agency’s mission. Ensure that the agency purchases equipment and software that will accomplish the mission of the sUAS program.  Do the research and talk to the people who have already developed a sUAS capability.    

  • sUAS Vehicles. There are a variety of drone vehicles that have varying capabilities relating to durability, flight time and load capacity.
  • Flight Control Equipment.
  • Sensory Equipment. Video cameras, thermal cameras, night vision and radiation detectors.
  • Payload Capacity. What equipment does the agency need to deliver the payload required of the mission, such as delivering items to remote or inaccessible areas, e.g., PFDs, radios, EMS supplies, food and water.    
  • Batteries and Chargers. Enough batteries and battery chargers to provide the agency with the flight time required for the missions.    
  • Live-Streaming software.    
  • Evidence Retention. Ensure that the agency’s evidence retention system can handle the additional load created by a sUAS program.
  • Flight Software. There is software available that will automatically restrict the use of the drone inside of a federal “no fly zone” (NFZ). Additionally, there is other software that will direct the drone to fly a precise path to search and photograph/video a designated area. Other types of software are available and will develop even more over time. 

9. Operators need the right training. sUAS Operators need to be very familiar with the legal and regulatory requirements, as well as the safe operation of the vehicles.

  • Operators can receive FAA Part 107 certification by taking the required written test through the FAA.  No skills demonstration is required at this time.
  • While not required if operating under a COA, agencies should consider training their operators to the Part 107 standards for the sake of proficiency.   
  • There are private vendors that can provide the training and education to prepare for the Part 107 test and to fly the sUAS vehicles.
  • As with maintaining any type of skill, some regular practice is required. 

10. Agencies need to exercise this capability. Agencies should ensure that drone operators maintain and enhance their flight capability through real-world deployments and exercises. Additionally, command staff and others in decision-making roles should participate in exercises to test, develop, and enhance the agency’s sUAS capability.

  • Test the capability of the agency’s equipment and operators in drills in a variety of indoor and outdoor environments.
  • Participate in discussion-based exercises for operators and command personnel to develop and enhance the operational planning for drone deployments. 
  • Include the deployment of the drone capability in other operations-based and discussion-based exercises conducted by the agency and/or jurisdiction. 

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