Unmanned Aircraft Systems (UAS) at Airports: A Primer (2015)

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37 Chapter 1 Chapter 5 Chapter 3 Chapter 7 Chapter 9 Chapter 2 Chapter 6 Chapter 4 Chapter 8 A ppendices When the introduction of UAS into the environment of an airport is considered, an impor- tant question that must be answered by airport managers is how the unmanned aircraft will impact current airport operations and procedures. In general, airports having experience with UAS indicate that unmanned aircraft operations can co-exist with manned aircraft on civilian airports with relative ease. This chapter discusses some of the aspects of UAS operations that should be considered prior to introducing UAS activities to the airport. 7.1 Segregation of UAS Operations The segregation of UAS and manned aircraft is typical when UAS operations are integrated with civil aircraft. In the early stages of UAS development this was not the case. During the initial integration of UAS operations at the VCV, UAS and manned civil aircraft were allowed to occupy the same airspace, operate together in the airport traffic pattern, and taxi about the airfield simultaneously. This was accomplished without major incidents or accidents between aircraft. As UAS activities grew across the nation and the FAA instituted restrictions on UAS operations, the segregation of manned and unmanned aircraft was mandated at civil airports, along with limiting UAS flights to daytime only. These changes came about when the institu- tion of the requirement for an approved COA became the norm and the FAA reviewed all COA requests. These additional restrictions were deemed necessary in order to provide an acceptable level of safety. While complete segregation of UAS and manned aircraft operations might be possible at most towered general aviation airports, it can be problematic at non-towered airports. Even though an operating restriction might be put in place through a COA, the enforceability of the separation requirement rests primarily with the UAS operators given their size and the challenge for pilots of manned aircraft to see them. At general aviation airports, it will be important for the UAS operator to communicate with other airport users via Unicom or Multicom radio frequencies. Other airport users will need to know that a UAS is operating at the airport and ensure separation themselves. This situation will likely cause operational limitations and capacity issues for the airport. Under- standing and communicating any restrictions placed on manned aircraft operations to the ten- ants based at the airport, and to known transient users, will be important for airport operators. This will allow airport tenants and known transient aircraft pilots to adjust schedules and flight plans accordingly. UAS Operational Considerations C H A P T E R 7

38 Unmanned Aircraft Systems (UAS) at Airports: A Primer Ch ap te r 1 Ch ap te r 5 Ch ap te r 3 Ch ap te r 7 Ch ap te r 9 Ch ap te r 2 Ch ap te r 6 Ch ap te r 4 Ch ap te r 8 A pp en di ce s 7.2 Similarities and Differences Between Manned and Unmanned Aircraft Operations In general, large, unmanned systems can require the use of runways and taxiways and oper- ate in a manner similar to manned aircraft. Many large UAS move about the airport like a manned aircraft, they require ramp space and hangar space, and fly in the same airspace. Unlike manned aircraft, some UAS need a ground control facility from which the pilot communicates with and flies the aircraft. A number of UAS types also require more direct monitoring and control while in the movement area or flying in the airspace in order to maintain separation with other aircraft. Smaller UAS that do not require the use of movement area surfaces will require a differ- ent type of oversight by the airport should they operate on airport property. Hand-launched UAS might operate from remote sections of the airport or from fields and areas away from the airport runways. As an example, at the VCV the National Guard units not only fly large UAS like the MQ-1 Predator and MQ-9 Reaper, units also train with land-launched UAS in a separate area of the airport in support of urban warfare training. These two types of opera- tions are planned for and segregated by the UAS operators and ATC during airport operations scheduling meetings. UAS That Require Aircraft Movement Areas Larger UAS that require use of a runway and taxiway can use the same movement areas as a manned aircraft. The most notable differences between large UAS and manned aircraft are the methods of communication and the separation required between aircraft. A larger UAS that operates beyond line-of-sight is flown by a pilot from a remote fixed ground control station (FGCS) as opposed to the pilot in the cockpit of the aircraft. In general, UAS that utilize movement areas use the same means of communication as manned aircraft. The pilot communicates with ATC and with other aircraft on the same radio frequencies as other aircraft at the airport. The difference is that the pilot’s ability to see traffic on the ground and in the air is a function of the sensors on the UAS. In some cases, when a UAS approaches an intersection on the taxiway, the pilot may stop the aircraft and scan the area with the air- craft’s optical sensor. The margin of safety is recovered in the form of increased separation. In other cases, the UAS might be monitored or escorted by an observer to increase the margin of safety. Current state of regulation and safety requires that UAS must also maintain a wider separa- tion between themselves and manned aircraft. This approach will likely remain the primary FAA approach to ensure safe operations until such time that UAS safety and self-contained separation capabilities can be determined to be reliable enough to allow open access to the NAS. Operational Limitations UAS that utilize aircraft movement areas in the same fashion as manned aircraft may have certain operational limits placed upon them to ensure the safety of operations. For example, the airport and ATC may require the UAS operator to provide a wider margin of separation from other UAS and manned aircraft during taxi, takeoff, and landing to minimize conflicts. Some operational limitations followed at airports operating UAS include: • A UAS and another aircraft (UAS or manned) are not allowed in the airport’s approach or departure pattern at the same time. Standoff distances are based on the environmental condi- tions, such as weather in the area and visibility. • A UAS and another aircraft are not allowed on the same movement area simultaneously.

UAS Operational Considerations 39 Chapter 1 Chapter 5 Chapter 3 Chapter 7 Chapter 9 Chapter 2 Chapter 6 Chapter 4 Chapter 8 A ppendices • The taxi route to and from the runway must be completely clear of aircraft prior to the UAS going to or from the runway and ramp area. • UAS are not allowed to operate at night. This restriction might be based upon a lack of ATC after midnight while general aviation and cargo aircraft continue to fly. • Airspace separation is widened based on environmental conditions. Requirements such as these can be placed upon unmanned aircraft by the FAA. The limitations tend toward the conservative side of operational safety, which is understandable at this point in the growth of UAS activity. The limitations are not typically based upon aircraft limitations or the actual operational capabilities of the aircraft. Safety Margins The need for a wider margin of safety also comes from the potential for lost link situations when the UAS suddenly becomes disconnected from its pilot-in-command. This situation must be planned for and built into the way in which UAS are controlled. At airports without ATC services, these margins of safety are even more critical and can require significant planning and contingency plan development on the part of the UAS operator, the FAA, and the airport operator. Separation of aircraft is a key factor to managing some of the inherent safety risks associated with UAS. Operational speeds of UAS that require the use of movement areas are very similar to general aviation aircraft. Larger jet powered UAS (such as the Global Hawk) taxi at speeds similar to a small business jet or turboprop aircraft. Because they travel at speeds similar to like-sized manned aircraft, the typical limiting factor between UAS and a manned aircraft is the communication required to operate the UAS safely. Wider separation is used to ensure safe operation, something that airport operators need to understand so that they can plan for the potential reduction in airfield capacity. 7.3 Training of Airport Personnel The training of airport personnel on UAS and UAS operations on or near the airport is depen- dent on the type of UAS. At this point in the evolution of UAS integration into the NAS, the need for extensive or UAS specific training has not been necessary. In general, airport personnel, especially those associated with emergency response may benefit from familiarization training with the UAS that is going to operate on or near the airport. Currently, UAS are not using exotic fuels or new structural material that would demand specialized training for response teams. Thus, general familiarization with the systems being introduced to the airport is likely all that is necessary. Examples include: • Fuel and fuel tank placement • Fuel shut off valve • Onboard fire suppression systems • Control systems (onboard computers) • Communication devices • Payload access • Operational characteristics Training for Airport Personnel at VCV A specific example of airport personnel training came from the VCV. At VCV, airport ARFF personnel went through a familiarization on the UAS itself, the ground crews, and the operators. The familiarization was intended to make the ARFF personnel aware of the issues listed earlier so that in the event of an emergency response the ARFF personnel will have a better understanding of how response situations might proceed.

40 Unmanned Aircraft Systems (UAS) at Airports: A Primer Ch ap te r 1 Ch ap te r 5 Ch ap te r 3 Ch ap te r 7 Ch ap te r 9 Ch ap te r 2 Ch ap te r 6 Ch ap te r 4 Ch ap te r 8 A pp en di ce s Airport personnel should also be made aware of stationary communication systems and oper- ating systems. The location of the FGCS and any support utilities should be included in the familiarization. In general, airport personnel should treat the UAS as they would any new tenant or aircraft operator. New equipment and new requirements that differ from common aircraft operations at the airport should be noted and understood. In addition to the physical differences of the aircraft and facilities, airport personnel should also be made aware of any communication requirements for the UAS. Airport personnel should understand any potential impacts to locally used radio frequencies, microwave links, or other communication systems. The airport staff should understand any additional data collection and storage requirements. These requirements will depend upon system tasks. For example, if the UAS is intended to photograph, map, chart, and otherwise collect information, special airport consid- erations may need to be addressed regarding the data capacity and storage the airport has available. 7.4 Airport Certification Impacts and Requirements Research for the primer did not identify any impacts associated with UAS on airport certifica- tion. The introduction of UAS into or near a certified airport does not impact its certification status. The impact of introducing UAS is similar to that of any other new tenant or aircraft operator. The airport operators should ensure they continue meeting all applicable regulations and standards during and after UAS introduction. 14 CFR Part 139 certificated airports have a well-documented process for certification and compliance. General aviation airports, also classified within the National Plan of Integrated Airport Systems (NPIAS), have a set of standards they are required to meet. All 14 CFR Part 139 certificated airports are included in the NPIAS as well. All NPIAS airports are considered signifi- cant contributors to national air transportation and are eligible to receive federal AIP funds. In receiving these funds, the airport operator must meet certain obligations and standards regarding the administration of the airport and the safety of the facilities. Section 5.5 contains additional information about grant assurances. 7.5 ATC Operations and Coordination with Airport Operations ATC personnel with UAS control experience have not identified any specific and consistent issues that impact airport operations or the ability to fly UAS in conjunction with manned air- craft. Airports with UAS operational experience, including VCV, MHK in Kansas, and GRK in Texas, have developed some fundamental coordination procedures that are being used to handle the differences between UAS and manned aircraft. ATC personnel are, for the most part at these airports, doing much of the coordinating with the UAS operators due to the separation and seg- regation requirements currently associated with UAS. The following are operational examples from select airport operators and ATC personnel. Southern California Logistics Airport Airport personnel at VCV are not routinely notified when UAS operations are conducted on the airport. During the early stages of UAS integration, airport personnel became familiar with the systems and their operation. With the large experience base at VCV, there is no longer a need for special coordination for UAS operations unless there is an emergency or special request outside of accepted operations. ATC personnel coordinate directly with the UAS operators on

UAS Operational Considerations 41 Chapter 1 Chapter 5 Chapter 3 Chapter 7 Chapter 9 Chapter 2 Chapter 6 Chapter 4 Chapter 8 A ppendices scheduling and flight plans, as well as in the airport pattern for landings and takeoffs for segrega- tion and separation between UAS and manned aircraft. • Prior to a COA being put in place, the VCV ATC would allow one UAS in the Class D airspace with manned aircraft. Following the requirement for a COA, UAS and manned aircraft are no longer allowed to operate simultaneously. If a UAS is in the Class D airspace, manned aircraft are not allowed in and vice versa. • The VCV COA does allow for night UAS operations in conjunction with manned aircraft operations. However, the Class D airspace can be designated as “sterilized” thus allowing UAS flying only. If a manned aircraft needs to access the airport at night, all UAS are removed from the airspace. • VCV ATC prioritizes general aviation and civil aircraft (such as large commercial aircraft using the airport’s maintenance, repair, and overhaul services) ahead of UAS. • VCV ATC adapt their procedures to accommodate the added time required for UAS ground operations and for taxi to and from the runway and ramp areas, as compared to manned aircraft. Manhattan Regional Airport (MHK) • MHK is in close proximity to Marshall Army Airfield where the Army flies the MQ-1C Grey Eagle. The ATC at MHK ensures that UAS operations coming from Marshall Army Airfield do not impact the commercial flights into and out of MHK. Both the Army and the MHK manage- ment felt it was very important to ensure coordination processes between the facilities were in place to deal with airspace issues early in the process of UAS introduction. • One airport operational issue discovered during early UAS operations at Marshall Army Air- field was the difference in communications terminology between the UAS operators and the ATC in the tower. Some UAS require an extended period of time on the runway prior to take- off. The Grey Eagle takes off automatically. Because it requires GPS synchronization prior to departure, it needs to “sit” on the runway threshold for up to 2 minutes prior to starting its takeoff roll. Early in Grey Eagle operations, the UAS operators defined 2 minutes as a “short delay” on the runway, as compared to a few seconds being the definition of a “short delay” used by the tower controllers. Thus, coordination between the airport, UAS operators, and the ATC on common terminology is important for operational continuity. • At Marshall Army Airfield, Grey Eagle operations require support equipment to be in close prox- imity to the runway end when launching the aircraft. This equipment is considered an obstruction and therefore the runway becomes unusable until the aircraft has departed and the equipment is removed. While this requirement does not impact operations at the Marshall Army Airfield since the Army controls the airspace, the facilities, and the aircraft, it does require coordination with ATC. Operations of this sort would have a major impact to a civil airport. Operational require- ments that impact runway availability require planning and coordination with the airport. Killeen-Fort Hood Regional Airport (GRK) • GRK is a military airfield but has scheduled commercial service by three airlines. The Army operates the RQ-5 Hunter and the MQ-1C Grey Eagle UAS from GRK. The key to the success of their operations is continuous coordination and information sharing between the UAS operators, ATC, and the airfield operations supervisors. • The controllers at GRK point to integrated planning on lost link or lost communications procedures and an acceptable lost link loiter point for the UAS as keys to success. All stake- holders were involved in this planning, including members of the local community, so that the selected location was away from population and infrastructure, making property damage and injury highly unlikely.

42 Unmanned Aircraft Systems (UAS) at Airports: A Primer Ch ap te r 1 Ch ap te r 5 Ch ap te r 3 Ch ap te r 7 Ch ap te r 9 Ch ap te r 2 Ch ap te r 6 Ch ap te r 4 Ch ap te r 8 A pp en di ce s • GRK only uses NOTAM to inform other flying organizations and pilots of upcoming UAS operations. There is no additional coordination done with the commercial air carriers. This method of coordination ensures that information on UAS operations is found in only one place, thus minimizing confusion and duplication. As illustrated with these experienced airports, the coordination necessary between ATC and the airport operator is dependent upon the type of UAS, the airspace, and the existing manned aircraft traffic at the airport. A concerted effort needs to take place to ensure that all known issues with the UAS operation are discussed by and with all interested parties. 7.6 UAS Communications and Electromagnetic Spectrum Related Issues Communications for UAS operations is the most important aspect. If a manned aircraft loses communication with the ground, the pilot still has the skills and the training to operate the aircraft safely. Unless fully autonomous operations are approved, the UAS pilot must normally have a link to control the aircraft at all times. UAS communication requirements vary widely and are based upon the aircraft’s purpose and the capabilities. Some UAS operate in an automated mode until they reach an established alti- tude following takeoff. Others require human control during takeoff and landing, and fly in an automated mode during the rest of the operation. Still other aircraft takeoff, maneuver, and land automatically with operator intervention required only when deviations to the planned route of flight are required, say for weather or for traffic deconfliction. Most UAS, however, require con- stant control and therefore communication with a human throughout the operation. Radio Frequencies Radio frequencies are commonly used to communicate with most small UAS. The power used to “push” these radio signals is not usually strong enough to disrupt other vehicles or services in the area. However, research conducted at the North Dakota University UAS Test Site has shown that in some cases systems were pushing radio waves strong enough to disrupt some ground based operations in Canada. It is imperative for the UAS operator and the airport to understand the possible communication issues prior to commencing operations. Airport operators are advised to have a communication checklist established that will aid in determining if potential issues with communication frequencies exist. Radio frequencies and the power by which they are pushed to the UAS are issues that are considered during the COA and Airworthiness Certification processes. According to the FAA’s Order 8900.1 (Flight Standards Information Management System—FSIMS), Volume 16, Chapter 5, Section 3, the following guidance regarding spectrum authorization is offered: 1. Every UAS proponent must have the appropriate National Telecommunications and Informa- tion Administration (NTIA) or Federal Communications Commission (FCC) authorization/ approval to transmit on the radio frequencies (RF) used for UAS uplink and downlink of control, telemetry, and payload information. 2. Non-federal public agencies, such as universities and state/local law enforcement, and all civil UAS proponents generally require a license from the FAA as authorization to transmit on frequencies other than those in the unlicensed bands [900 megahertz (MHz), 2.4 gigahertz (GHz), and 5.8 GHz]. This generally will be in the form of an experimental radio license or a special temporary authority (STA) issued by the FCC. Non-federal public agencies and civil UAS proponents that operate systems using frequencies assigned to the federal government (e.g., the DOD) must demonstrate they have the proper authorization through FCC-issued documentation.

UAS Operational Considerations 43 Chapter 1 Chapter 5 Chapter 3 Chapter 7 Chapter 9 Chapter 2 Chapter 6 Chapter 4 Chapter 8 A ppendices 3. DOD agencies will typically demonstrate UAS spectrum authorization through an STA issued by NTIA or a frequency assignment in the NTIA-administered Government Master File (GMF). Authorizations issued under Title 47 of the Code of Federal Regulations (47 CFR) part 300, in the NTIA Manual, Chapter 7, paragraph 7.11, Use of Frequencies by Certain Experimental Stations, are not appropriate for UAS operations. 4. Federal public agencies other than DOD, such as NASA, U.S. Coast Guard (USCG), and U.S. Customs and Border Protection (USCBP), also need an STA issued by NTIA or a frequency assignment in the NTIA-administered GMF. This is especially important for systems designed to operate on frequencies assigned to DOD. Airport operators who have an interest in UAS operations being conducted at their airport should be aware of potential radio frequency issues. These may become limiting factors in UAS operations on or near the airport. If an airport operator has a working knowledge of the issues, they will better prepare the UAS operator for the COA application process and mitigate any communications issues.