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New Directions in Risk and Safety Brandon Stark, Director Unmanned Aircraft System Safety Center of Excellence University of California Drone Licenses and Operations
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New Directions in Risk and Safety Topics Overview of UASs in the UC System The UC UAS Workflow UAS Laws Enforcement of UAS Policies Upcoming Changes 2
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New Directions in Risk and Safety 3 What UAS activity is already occurring in the UC system? Nearly every campus has a ‘Drone Lab’ Largely Engineering groups Increased interest in Environmental, Agricultural, Archeological, and Ecological research groups Journalism, Facility Management, Publicity/Multimedia groups
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New Directions in Risk and Safety UAS Vocab UAS – Unmanned Aircraft System FAA – Federal Aviation Administration COA – Certificate of Authorization, applies for both Public Agencies or Commercial UAS flights Pilot Certificate – Pilot’s license UAS Registration – Each aircraft must have an FAA number (starts with N or FA) SUAS – Small UAS (under 55 lbs) Section 333 Exemption – Congressional exemption from the prohibition of commercial UAS flights PIC – Pilot in command VO – Visual observer 4
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New Directions in Risk and Safety UAS Roadmap 5 UC Merced receives COA (2013) UC Receives Section 333 Exemption (March 2, 2016) UC Receives Section 333 Exemption (March 2, 2016) UC Receives Public Blanket COA (April 5, 2016) UC Receives Public Blanket COA (April 5, 2016) Part 107 Rules (July? 2016) Part 107 Rules (July? 2016) Online Registration (April 7, 2016) Online Registration (April 7, 2016) Flying over People Rules (2017?) Large UAS Laws (2020?) Public COAs available to Public UAS (2005) Sec 333 Exemptions Introduced (Oct 2014) Small Drone License (Late 2016) DJI Starts selling Drones (2008) Drones are “Next Big Thing” (2012) 300 COAs approved in 2010 NPRM For SUAS (Feb 2015) UAS Hobby Registration (Dec 2015) UAS Registration Mandatory (Nov 2014) SUAS Recommendations Released (2009) Educational Allowance (May 2016) ~3000 Section 333 (Feb 2016) ~6000 Section 333 (June 2016) Unmanned Traffic Management (2019?) Beyond Line of Sight (2018?) Amazon announces Drone Delivery (2013)
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New Directions in Risk and Safety Center of Excellence on Unmanned Aircraft System Safety One stop shop for all things UAS Services Manage UAS registrations and authorizations Files permissions and requests on behalf of faculty/staff Answer any questions related to policies or risk management Provide reports on UAS activity 6
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New Directions in Risk and Safety Big Bad Federal Laws Any UAS operated by the UC within the United States National Airspace is subject to FAA rules and regulations There are three types of UAS authorizations available to the UC Recreational/Educational Public COA Section 333/Civil Any UAS operated by UC faculty, staff or students in connection with or part of his/her official duties does not quality as recreational/educational use. The UC must obtain authorization for any faculty, staff or student use in connection with or part of this/her official duties. There is no middle ground. Either the UC obtains the authorization or there is no flight operation. There is no middle ground. Either the UC obtains the authorization or there is no flight operation. 7
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New Directions in Risk and Safety UAS or Model Aircraft Aircraft Unmanned Aircraft Small Model Aircraft Model Aircraft are defined as a subset of Unmanned Aircraft. Model Aircraft are differentiated from Unmanned Aircraft only by the purpose in which they are flown Sec 336 in H.R. 658 – “The FAA Modernization and Reform Act of 2012” Model Aircraft are defined as a subset of Unmanned Aircraft. Model Aircraft are differentiated from Unmanned Aircraft only by the purpose in which they are flown Sec 336 in H.R. 658 – “The FAA Modernization and Reform Act of 2012” 8
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New Directions in Risk and Safety Disclaimer: There is an accurate summary of the laws and a summary of the laws that can fit in a hour-long presentation. There will be some conservative simplifications! Check with me for an exact analysis of any situation 9
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New Directions in Risk and Safety UC User Flight Workflow Flight Request To Center (UC form) File special permission with FAA Clear Airspace? Where: When: Purpose: Pilot: Aircraft: Where: When: Purpose: Pilot: Aircraft: Aircraft Registered? Licensed Pilot File NOTAM (online system) Flight Authorized Flight Report (UC form) Flight!
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New Directions in Risk and Safety Requirements UC Flight Rules Flowchart 11 Purpose File special permission with FAA Airspace Class Need Spec. Permissions ? Approved Vehicle Ground School Cert. File special permission with FAA Private Pilot’s Certificate Clear, Away from airports Commercial Public Yes No Yes Urban, or near airport FAA Recreational Registration Recreational/Class Curriculum
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New Directions in Risk and Safety How does the UC get flight authorizations 12 UC Submits Records to FAA UC grants Authorization Recreational UAS Student Recreation Student Curriculum Not for research Recreational UAS Student Recreation Student Curriculum Not for research Public Agency Operations (PAO) UC-Owned Aircraft Only for public research purposes Public Agency Operations (PAO) UC-Owned Aircraft Only for public research purposes Section 333 Exemption UC-Owned Aircraft Only specific UAS models allowed Requires Private Pilot’s License Can operate as a service (commercial) Up to 400 ft Section 333 Exemption UC-Owned Aircraft Only specific UAS models allowed Requires Private Pilot’s License Can operate as a service (commercial) Up to 400 ft Stop Not Legal Section 333 Blanket COA Must be 5 NM away from an airport 500 ft away from any persons, vehicles or structures Authorization granted by UC Section 333 Blanket COA Must be 5 NM away from an airport 500 ft away from any persons, vehicles or structures Authorization granted by UC Section 333 Commercial COA May be within 5 NM from an airport with permission May operate in closed-set filming (no distance requirements) Requires separate FAA approval (4- 6 weeks) Section 333 Commercial COA May be within 5 NM from an airport with permission May operate in closed-set filming (no distance requirements) Requires separate FAA approval (4- 6 weeks) Public COA Requires Separate Application (3-5 months) One application per purpose, active for 2 years No strict limits on operations (ex. Enables above 400 ft, night-flying, within 5 NM of airport, etc) Operator must submit reports to FAA Public COA Requires Separate Application (3-5 months) One application per purpose, active for 2 years No strict limits on operations (ex. Enables above 400 ft, night-flying, within 5 NM of airport, etc) Operator must submit reports to FAA Blanket Public COA Class G Airspace only UC Airworthiness Certificate Ground School Certificate minimum Authorization granted by UC Blanket Public COA Class G Airspace only UC Airworthiness Certificate Ground School Certificate minimum Authorization granted by UC
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New Directions in Risk and Safety 13 Recreational/Class Curriculum Recreational Cannot receive money or compensation Cannot be used in furtherance with a business or official duty Must be operated within a community-based set of safety guidelines and within the programming of a nationwide community-based organization Education Students may build and fly a UAS as a component of a course curriculum or senior project UAS flights by students must be in accordance with Campus oversight. UAS flights in pursuit of research projects or university business are not considered recreational
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New Directions in Risk and Safety 14 Examples A student club is considered recreational A student that flies a UAS as part of a class on remote sensing techniques is considered recreational A student building and flying a UAS as part of a class on aerodynamics is considered recreational A student building and flying a UAS for a senior project is considered recreational A student club that is paid to perform at an event is not recreational A student flying a UAS under the direction of a faculty’s research is not recreational. A course where the primary objective is learning how to fly is not considered recreational. A student conducting sponsored research (faculty, company, student gov’t) is not recreational Campus should still provide oversight!
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New Directions in Risk and Safety 15 Section 333 Exemption vs Public COA Section 333 Exemption – Commercial Only FAA-approved Aircraft Requires a Pilot’s License Operations within 5 Miles of an airport requires further FAA authorization ~ 60 days Public COA – Public Agency Operations Public Aircraft (owned by UC) UC certifies Airworthiness Public Purpose Law Enforcement, Search & Rescue, Aerospace Research, Biological Resource Management, Geological Resource Management Operations in Class G airspace can be authorized by the UC UC may petition for ANY UAS operation Night Flying, Beyond Line of Sight, Delivery Services, Above 400 ft Takes 3-8 months to approve Both options have a nation-wide blanket authorization under certain conditions for immediate approval by the Center Best for Research, Engineering and LEOs Best for Facilities, Videography, Corporate Partnerships Either option requires the UC to report all operations to the FAA!
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New Directions in Risk and Safety 16 Cheat Sheet (Also a handout) User Group/Purpose Model Aircraft Public COA Section 333 Part 107 Athletics - Over GameCurrently not legally allowed Athletics - Over Practice X Athletics Promotional Video – Controlled Environment X Campus Law Enforcement XXX Campus Search & Rescue XXX Campus Video Production XX Construction Survey XX Engineering Research Project (Faculty Directed) X*XX External Contractor XX Flying over a access-controlled consenting people X*X Flying over non-participating peopleCurrently not legally allowed Flying within 5 NM of an AirportRequires Additional Clearance ^ Internal Service Provider X*XX Research Project on Aeronautical Research XXX Research Project on Agriculture X*XX Research Project on Biological Resource Management XXX Research Project on Digital Archeology X*XX Research Project on Geological Resource Management XXX User Group/Purpose Model Aircraft Public COA Section 333 Part 107 Research Project on Wildlife Monitoring XXX Student BodyX XX Student Class ProjectX XX Student ClubX XX Student Demonstration at Campus EventX+ XX Student Dissertation Project X*XX Student in an Aviation ClassX XX Student Journalist with Campus Media XX Student Journalist with Student Government XX Student Providing a Commercial Service XX Student Research Project (Funded by External Agency) X*XX Student Research Project (Funded by Faculty) X*XX Student Research Projected (Funded by Student Gov’t) X*XX Student Thesis Project X*XX Video Production for Campus Showcase XX
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New Directions in Risk and Safety UAS Enforcement Universities may not regulate FAA airspace, but they may put in place policies regarding student use of UAS on their campuses Laws and Policies traditionally related to state/local police power – including land use, zoning, privacy, trespass can be implemented. 14 CFR 91.13 – Careless or Reckless Operation (a) Aircraft operations for the purpose of air navigation. No person may operate an aircraft in a careless or reckless manner so as to endanger the life or property of another. 17 Air Navigation is mentioned as contrast to operating an aircraft on the ground
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New Directions in Risk and Safety What to do if you suspect unauthorized UAS activity? 1.Locate the operator 2.Ask for registration and verify markings on the UAS 3.Ask operator for the type of operation and to present appropriate documentation 4.Interview operator and collect the following information 1.Name, address and positive ID of owner 2.Record registration number and the Exemption or COA 3.Document time, place and details of flight 5.Take action based on local Laws, Ordinances, Directives 6.Contact the FAA 1.General Inquiries – Regional Operations Center 2.Investigative Support – Contact FAA Law Enforcement Assistance Program 18
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New Directions in Risk and Safety 19 Types of Authorized UAS Ops and Required Documentation Commercial Section 333 Exception Certificate of Authorization (COA) Aircraft Registration and Markings Pilot Certificate FAA UAS Registration is not accepted Public/Government Certificate of Authorization (COA) Aircraft Registration and Markings Further details can be found at http://tinyurl.com/UC-UAS-COE or http://uassafety.ucmerced.eduhttp://tinyurl.com/UC-UAS-COEhttp://uassafety.ucmerced.edu
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New Directions in Risk and Safety 20 Future Drone Laws Part 107 Blanket Authorization for any purpose Under 55 lbs, VLOS, Daylight Up to 500 ft No flying over people Requires ATC approval for Class B, C, D, and E airspace No ATC approval required for Class G Requires preflight inspection Records must be available Part 107 Rules (July? 2016) Part 107 Rules (July? 2016) Flying over People Rules (2017?) Large UAS Laws (2020?) Small Drone License (Late 2016) Unmanned Traffic Management (2019?) Beyond Line of Sight (2018?) Small Drone License Aeronautical Knowledge Test at an FAA testing facility Requires record keeping and preflight inspections $150 Fee + $50 TSA check
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New Directions in Risk and Safety 21 Future Drone Laws Part 107 Rules (July? 2016) Part 107 Rules (July? 2016) Flying over People Rules (2017?) Large UAS Laws (2020) Small Drone License (Late 2016) Unmanned Traffic Management (2019) Beyond Line of Sight (2018) The FAA recently released the recommendations for the next major regulation change on flying over people (for licensed SUAS operators) Performance-Based Standard for the Classification of UAS Operated over People Classification based on kinetic energy of a falling drone Low risk flights would be enabled for flights over people and crowds Higher risk flights must include a risk mitigation plan
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New Directions in Risk and Safety 22 Future Drone Laws Part 107 Rules (July? 2016) Part 107 Rules (July? 2016) Flying over People Rules (2017?) Large UAS Laws (2020?) Small Drone License (Late 2016) Unmanned Traffic Management (2019?) Beyond Line of Sight (2018?) Beyond Line of Sight The next big target, especially for long- range inspections, agriculture, and delivery services Unmanned Traffic Management How do we keep all the drones from crashing into each other? Currently a major NASA project Large UAS For platforms over 55lbs The Ubers of the sky?
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New Directions in Risk and Safety Federal Compliance UAS Laws are complicated and detailed There are 30+ different permutations of UAS procedures to follow, and even more on the way Varied interpretations of Federal Law leaves the UC vulnerable 23
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New Directions in Risk and Safety UC UAS Activity How many UAS does the UC system have? According to the FAA – 7 According to UCOP Risk Services – 73 According to my list – 130 The true number ~ 200-300 Where are the UASs flown? According to the FAA – only in Davis and Merced since 2009 According to the news media – All over the US and the world How many illegal UAS flights are being done by our UC students/faculty and staff? 24 The UC has a UAS problem!
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New Directions in Risk and Safety What’s going wrong? Lack of knowledge of UAS regulations Don’t blame recent changes! – UAS have been heavily regulated since 2005 Recent changes have only decreased the number restrictions (by adding more alternative process with new rules) Affects both for end-users and the campus administrators Lack of value-added oversight Current reporting mechanisms offer no improvement to regular use Hard to encourage buy-in 25
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New Directions in Risk and Safety Introducing the UC UAS Fleet Management System 26
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New Directions in Risk and Safety UC UAS Fleet Management System UAS Infrastructure to enable UC flights Students, Researchers, Staff Recreational and Education Administrative Oversight Organized/Consistent interpretation of UAS regulations Automated systems for keeping track of UASs, pilots and flights Built-in safety metric analysis 27 But I don’t need to convince this audience!
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New Directions in Risk and Safety End-User Value-Added Experience Having to figure out new laws Where can I fly? Keeping track of the condition of aircraft Keeping track of hours of flight time Remembering what the correct operating procedure is Checklists! Forgot to arm the plane before launching it Reporting to the FAA Reporting to administrators Did I charge the batteries? Why did it crash? Forgetting to pack all the things Cows! How many flight hours do I need before I’m qualified? Who do I call if something goes wrong? Do I need to tell the FAA is the UAS crashes? What do I need to tell the FAA? Too much air traffic 28 Common Issues of End-Users
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New Directions in Risk and Safety Common Themes Keeping track of things Automating the workflow Providing clarity on regulations 29 Providing a system that does these things will eliminate 90% of all UAS issues
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New Directions in Risk and Safety UC UAS Fleet Management System Single portal system for all UAS activity 1.Enter the aircraft and pilot 2.Check airspace 3.Fly 4.Report Aircraft/Pilot/Crew hours are automatically updated Airspace, weather, air traffic and other conditions can be checked instantaneously Can automatically prepare necessary checklists and flight instructions 30 Integrated into the UC’s Safety Training System
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New Directions in Risk and Safety 31
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New Directions in Risk and Safety End-User Benefits Clear workflow guides all (new and experienced) users into the correct process Minimize processing dead-ends, missing approvals, improve planning efficiency Federal laws, UC policies built into the workflow Researchers can focus on their research and projects, and not have to figure out laws Automatic tracking of UAS usage and crew operation Enables accurate maintenance scheduling, documented crew qualifications Enables customizable processes for improved planning Automated weather planning Automated generation of in-field checklists, planning checklists, flight logs Simple generation of usage reports Fulfills FAA reporting mandates, painless reporting to administrators Integrated into the UC’s Safety Application system Tied into system authentication – Use your own UC log-in information Enables privacy control or transparency 32 A little bit of data analytics can go a long way What are the most common UAS platforms? Who does the majority of the flying? How many tests flights are typically taken before mission flights? What are the most common UAS issues? A little bit of data analytics can go a long way What are the most common UAS platforms? Who does the majority of the flying? How many tests flights are typically taken before mission flights? What are the most common UAS issues?
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New Directions in Risk and Safety Future Proofing UAS Portal keeps the interpretation of Federal Laws consistent across the campuses Single point of operation = high traffic for important announcements Future Anticipation of Unmanned Traffic Management Systems 33 Part 107 Rules (July? 2016) Part 107 Rules (July? 2016) Flying over People Rules (2017?) Large UAS Laws (2020?) Small Drone License (Late 2016) Unmanned Traffic Management (2019?) Beyond Line of Sight (2018?)
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New Directions in Risk and Safety Improving UAS Safety in the UC System The UC system must be organized and forward thinking for UAS safety Build an infrastructure in management and safety The UC will have students, researchers and staff all actively looking to do UAS flights both on their campuses and all over the state The airspace around all UC campuses are complex Each campus will have a multitude of activities and large crowds 34
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New Directions in Risk and Safety 35 UAS Management with AIRMAP Integration of Airspace class layers into Flight Request Enables automatic flight request authorizations depending on airspace Removes the potential for misreading VFR charts Improves awareness of operators
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New Directions in Risk and Safety 36 UAS Management with AIRMAP (Under Development) Integration of Airmap’s D-NAS™ into UC UAS Management Infrastructure UC flight planning could automatically trigger D-NAS messages Immediate notification to nearby airports Enables ATC to send messages directly to UC operators Move to a standard for airport communication
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New Directions in Risk and Safety 37 UAS Management with AIRMAP (Under Development) Campus Public Safety access to D-NAS Campus Public Safety can view active flights and their contact info Campus can mark no-fly zones, specific procedures/rules for certain areas on campus, regulate commercial and recreational activity. Send messages or alerts to users in specific campus regions D-NAS is built into many commercial drones Would allow Campus Public Safety to keep track of non-UC drone flights on UC campuses Safe at any time Never permitted Requires prior approval
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New Directions in Risk and Safety Total UAS Safety Solution (Under Development) 38 UC Fleet Management AIRMAP UAS Monitoring Airport Notification UC Operators UC Campus & Public Safety Non-UC Operators UC Risk Management Enables UC Campus & Public Safety with improved awareness of all UAS activity on their campuses
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New Directions in Risk and Safety 39 The problem isn’t that this is going to be difficult…. The problem is that this is coming to our campuses very soon The problem isn’t that this is going to be difficult…. The problem is that this is coming to our campuses very soon
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New Directions in Risk and Safety In 10 years! How many drone deliveries are you going to allow simultaneously? Who will decide who has authorization to record football practices? What happens when the police want to use a UAS to monitor a crowd? What are all the drone startups going to do? Will the drones crash into each other in flight? Will there be an airborne Uber or Lyft? 40
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New Directions in Risk and Safety This is where the aviation industry is going… and I want the UC to be in the front
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New Directions in Risk and Safety Contact Page Email: bstark2@ucmerced.edubstark2@ucmerced.edu UASSafety@ucmerced.edu http://tinyurl.com/UC-UAS-COE http://uassafety.ucmerced.edu/ Phone: (209) 201 - 2051 Facebook page: TBA Twitter account: TBA 42 Please sign up for the UC UAS Listserves if you’d like to be kept in the loop of the latest developments
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