In my daily visits with agencies across the country, I find the biggest source of confusion concerning the topic of drones is how to fly legally. My aim in this article is to help eliminate that confusion, and potentially save your agency thousands of dollars in consulting and training fees. To do so I’ve prepared a basic process and prepared some vital resources to make the job of being legal easy, and at worst…much easier than figuring it out on your own.
The Two Paths
Currently, there are two legal mechanisms provided by the FAA for drone operations. The most recent, Part 107 Remote Pilot Certificate is in lay terms a driver’s license for drones. The other is a COA (certificate of authorization) which is issued after the FAA examines the associated paperwork that you produce, and determines that your agency has a sound drone program. In my personal opinion, these two paths should be used in conjunction with each other. In the recommended process below, I’ll provide some reasoning for doing both.
Step 1 – Get a Plan Together!
Just like you would do for any activity in public safety, make a plan. This plan doesn’t necessarily need to be one-hundred pages long, even some basic details are going to be very helpful in executing the overall process. For instance…what are your agency’s desired missions with the drones? Knowing the missions will aid you in making other decisions such as what drones to buy, what vehicles are needed to support the drones, and who in your agency is apt to pilot them well.
Another great question for your planning is when, when do you want to fly the drones? Will it be at night? In foul weather? Hereto, the questions will be very important in getting the right gear and later in the process, completing the paperwork correctly.
Along with your planning, it’s obviously important to incorporate all stake holders involved. If the drone program will be supporting multiple sections inside of your agency, it will probably surprise you how many unique drone missions are possible. Somewhere in the midst of your planning, it’s also a great idea to reach out to a vendor (please call MAXSUR) to get advice on gear, and other agencies that can provide some lessons learned from down-range.
When it comes to gear, here is a great starting point that compares popular off-the-shelf drones from a public safety viewpoint. Public Safety Drone Comparison Chart
Step 2 – Get Your Pilots Licensed
Hopefully in step 1 you were able to identify team members that will be piloting drones. If I was working in your agency, I would have already identified you and volunteered pretty quickly. Getting paid to fly drones and help people…how much cooler can it get!
Once you’ve identified the folks forming your drone team, I highly recommend that they obtain their Part 107 Remote Pilot Certificate as soon as possible. Even though under a COA you can self-certify your pilots and there is technically no need for a pilots license…requiring that each team member holds a part 107 license will mean that they must pass a FAA issued 63 question test. With each team member passing the test, it will ensure a level of basic, uniform knowledge about drone operations, airspace navigation, weather and communications. Additionally, it will go a long ways in convincing FAA that your agency has its act together.
As a potential bonus to the individuals holding a Part 107 Remote Pilots Certificate (RPC), they will be legally able to conduct drone flights in off duty hours for extra income and obviously, the increased experience will benefit the agency as well.
Getting a RPC will require a bit of study on the individuals part but it’s far easier to pass that test than any public safety test for law enforcement, fire or EMT. To make it as easy as possible, I do recommend taking some courses to help make the unique aviation terms and concepts second hand. Today, there are online courses as inexpensive as $99 that provide excellent training. Here is an article for how to pass the Part 107 test and links to all necessary resources…click here.
Step 3 – Purchase and Register Your Gear
Before you can proceed with obtaining a COA from the FAA, you’ll need to have the gear in hand. Reason being, when submitting the necessary paperwork, the FAA will need to know detailed equipment specifications and serial numbers. Upon receiving your drone equipment, the very first thing you should do is register it with the FAA. Drone registration is required of all groups, hobbyist, professionals and public safety operators. The FAA drone registration portal can be found by clicking here.
Once you’ve registered your drones, and because your pilots are already licensed by this point…you can now start some early flights. But before you get too wild & crazy, adhering to Step 4 can save a lot of heart ache.
Step 4 – Get Trained
Some might argue that training is not required, after all…little Johnnie in the neighborhood has a drone and he never went through training. I must admit, drones have never been so easy to use….but also bear in mind that little Johnnie doesn’t have to operate in stressful situations or worry about the being the constant subject of the evening news. That being said, I highly recommend some type of training from a veteran drone instructor. At minimum, pilots should receive what I call system training on the aircraft they are flying. With any given drone system, there are known limitations that if not trained against could spell disaster when the drone is needed most. Typically, this level of training requires around 8 hours depending upon the complexity of the drone.
To bolster your teams capabilities, training should also include maintenance of the drone, public safety scenario based training and lastly demonstration of individual proficiency. For additional information on training services, please contact the MAXSUR team at firstname.lastname@example.org
STEP 5 – Submit a Public Declaration Letter to FAA
COA’s are only issued to government agencies. In light of that, the FAA wants to know that they’re dealing with a legitimate public entity. The FAA’s preferred method of proving that your agency is a public entity, is to receive a signed & submitted letter from your City, County or State Attorney’s office declaring that fact. Click here for a sample letter and guidelines.
The public letter of declaration should be submitted from your Attorney’s office and mailed to the FAA. The letter should name you as a technical point of contact so that after a couple of weeks, you will receive details on gaining access to FAA’s online COA submission portal.
STEP 6 – Submit COA Application
After you’ve received your login credentials, you’ll be able to access the FAA’s UAS COA Online System. Once logged in, you’ll recognize that the FAA will ask for quite a bit of information. However, they’ve categorized everything quite well and there are some excellent resources available to assist in compiling the information.
Here is a broad overview of the application categories:
Where – As part of the application, the FAA will want to know where you are planning drone operations. They’ll want to know your geographic areas of operation and how operations may influence local airspace.
Drone System – Obviously the details for your sUAS (small unmanned aerial system) will be very important to the FAA. Beyond the basic details, the FAA will want to know the full specifications and performance characteristics. For this area especially, you’ll need to lean on your vendor to gather those details. Your vendor should be familiar with each of the questions that FAA will ask and be able to provide an adequate response.
Procedures – In the application to the FAA, a critical element will be your agency’s SOP’s. Chiefly, they will want to hear about your procedures when things go wrong such as losing data link communications with your drone, losing communications with ATC and other emergencies that can occur. To aid you in forming these procedures, click here for examples.
Crew – In times past, the FAA required drone pilots to hold airmen certificates for manned aviation. Now they are allowing your agency to self-certify your pilots. However, they do want to see the requirements that the pilots have to meet. In my opinion, the requirements should start with them holding a Part 107 Remote Pilot Certificate which will ensure a minimum level of knowledge and prompt 10 to 30 hours of study. Additionally, I recommend training to cover the drone systems they will use, mission based scenario training and maintenance of the equipment. Lastly, I recommend that each pilot demonstrates proficiency to an instructor. For additional information on training services, please contact the MAXSUR team at email@example.com
Take Advantage of Resources!
During this step, some of the information request may seem a bit daunting. To make it as easy as possible, I recommend taking advantage of some important resources.
• Your Vendor – The technical aspects of the application may seem pretty greek. But your vendor should be able to get you the right answers. In the case that they can’t, feel free to contact the MAXSUR team even if you didn’t purchase your drone system from us.
• The FAA – During the process of submitting your COA application, you likely receive a POC for the FAA. Your POC will likely be very apt to assist and the FAA has set aside dedicated personnel to liaise with public safety.
• Example/Template Documents – Click here for a recent example of a COA submission packet. This example is a fairly recent one, but should be used as an example only.
• Other Agencies COA Submittals – Fortunately, hundreds of agencies have already blazed the trail of getting a COA. Many of their COA submission have been made publicly available. Here is searchable database for their submissions https://www.faa.gov/uas/resources/foia_responses/
STEP 7 – Wait & Take Advantage of the TimeOnce the COA application is submitted, the wait time is as short as a few weeks but on average, a couple of months. While the COA is being processed, certainly there will be great anticipation…and thankfully, the FAA allows you to check the status online without having to call anyone.
While you’re waiting for the COA to be approved, it’s an excellent time to further refine your drone program. For a few ideas:
• Table Top a Variety of Drone Missions
• Visit with local airports and become familiar with traffic patterns
• Get More Training
• Refine deployment protocols
• Learn tips from the field from neighboring agencies with drone programs
Thanks for reading, I sincerely hope this information has been of assistance to you and your public safety team. If the MAXSUR team can be of further assistance, please give us a shout at 1-855-778-6565 or via email at firstname.lastname@example.org
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