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

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44 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 Introducing UAS into the airport environment will introduce additional levels of safety and security risk. This is always the case when introducing new systems to the airport. The current application and approval processes for UAS are aimed at managing these risks, protecting the operators and aviation assets, and ensuring the safety of communities surrounding the airport. As discussed earlier in the primer, the process for UAS to access the NAS requires a COA to be issued and the receipt of an airworthiness certificate on the specific UAS. This FAA process includes a risk assessment with regard to the safe operation of the UAS and its potential impact on the NAS. Airport security issues are directly tied to the UAS itself and its mission or function. UAS oper- ators might require special security measures if the information they gather is highly confidential or if the UAS itself is experimental and proprietary designs or information need to be protected. This chapter addresses these issues in more detail, along with safety, emergency response, and ARFF. 8.1 Safety Management System (SMS) Development for UAS The pending requirement for Part 139 certificated airports to develop and implement a SMS has been well publicized and valuable guidance is available on the topic. Several resource links are provided in Appendix D for reference. Commercial air carriers are now required to develop and implement an SMS to help improve safety performance and better protect the flying pub- lic. As the aviation industry moves toward the systematic approach to managing safety risks, it makes sense for organizations looking to introduce UAS have sound safety programs and plans in place. The FAA’s SMS processes for risk management are well documented and have been in use for almost a decade by the air traffic and aviation safety lines of business. The COA application process and airworthiness certification process support the internal FAA SMS and are intended to provide enough information about the UAS so that risk informed decisions can be made relating to UAS operations approval. That said, because the FAA will continue to use SMS to identify hazardous conditions and mitigate their associated risks, airport operators will likely benefit from an understanding of how UAS operations can and should be viewed through the SMS lens. SMS Illustration—Maintaining Aircraft Separation As discussed in earlier sections, segregation and separation of UAS from manned aircraft operations is currently the general approach to mitigating most of the aircraft collision UAS Safety and Security C H A P T E R 8

UAS Safety and Security 45 Chapter 1 Chapter 5 Chapter 3 Chapter 7 Chapter 9 Chapter 2 Chapter 6 Chapter 4 Chapter 8 A ppendices risks. Until UAS technology has evolved to fully demonstrate the ability to see and avoid through sense and avoid methods, the primary mitigation of collision risks around the air- port is having “eyes on” the UAS to maintain separation. This might involve a spotter on the ground, a chase plane in the air, or through positive radar control when the UAS transits to working areas. Should these methods not be practical, sterilization of the airspace becomes the default mitigation strategy. To better understand how SMS processes can be used toward successful UAS integration, the development of these aircraft collision risk mitigations is illustrated here. UAS, SMS, and the Airport Operator Fully developed SMS are coming to airports. Early adopters are finding that integrating SMS processes not only improves safety performance, but also adds value to the operational effec- tiveness of the airport. There are several Part 139 certificated and a handful of general aviation airports that have developed and implemented an SMS and much that can be learned from those airports. Appendix D provides links to SMS experienced airports and to the results from FAA sponsored SMS pilot studies involving several of them. Developing and implementing an SMS that integrates UAS safety processes is a sound method of protecting the airport and gaining the confidence of the surrounding communities. A sum- mary of SMS components and concepts, along with some examples of how they might be used to support UAS introduction is provided here. SMS Components An SMS consists of four components; they are: • Policy: The policy provides the safety direction, commitment to safety of airport management, and articulates the responsibilities for safety. • Safety risk management (SRM): SRM provides the tools to identify hazards, assess their risks, and mitigate the risks. (This is the most important operational aspect of SMS, and therefore will be vital to addressing UAS operational risks.) • Safety assurance: Safety assurance provides the data collection and analysis of safety processes, enabling management to understand how the system is performing. • Safety promotion: Safety promotion provides the information and communication aspects of the overall safety program, along with safety training and orientation. The introduction of UAS operations, in most cases, will represent a system change to an air- port. This change to the system is not ordinary, and may require some distinctly different ways in which aircraft are operated. Therefore, some level of risk assessment is prudent on the airport operator’s part. A system change is usually classified as a trigger to initiate a safety risk assess- ment (SRA), a process used in the SRM component of the SMS. As the introduction of UAS to the airport is considered and planned for, conducting an SRA to identify anticipated hazards and assess the associated risk will benefit the airport and the UAS operator. A great way to prepare for the submission of a COA application might be to conduct an SRA and submit the identified hazards and risk mitigations along with the application to demonstrate a proactive approach to UAS introduction. The 5-Step Process The SRA employs a 5-step process for assessing the system change risks. The steps are: 1. Define the system: Identify the elements and stakeholders of the system within which the UAS will be operating. 2. Identify the hazards: Determine the hazardous conditions the UAS may be introducing into the airport system. Multiple hazards are possible.

46 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 3. Analyze the risks: Evaluate the possible outcomes of the hazardous conditions. Each hazard may have multiple effects associated with it. 4. Assess the risks: Risks are defined by two elements: severity (how bad the outcome might be) and likelihood (what is the possibility of the outcome occurring). The combination of the severity and likelihood provides the level of risk. 5. Mitigate the risks: Develop actions or strategies to reduce the risks identified to acceptable levels. The FAA has used this fundamental approach in dealing with UAS introduction into the NAS. A simple example is: 1. The system is the NAS in its current state. 2. The hazardous condition identified is that UAS cannot currently meet the “see and avoid” requirement for aircraft operations. 3. The potential outcome of this hazard is that a UAS could collide with a manned aircraft, another UAS, terrain, and or facilities on the ground or in the air. An accident could result. 4. The risk has a severity of a catastrophic accident, and the likelihood of this occurring was determined to be high enough that the overall risk was deemed too high or unacceptable, and therefore needed to be mitigated. 5. One of the mitigations to reduce the risk is “eyes on” the UAS when the aircraft is moving. The use of a ground spotter or a chase plane was determined to provide the mitigation to reduce the likelihood of a collision, therefore reducing the overall risk to an acceptable level. This explanation is oversimplified as months and years of effort and multitudes of data were used by the FAA to determine the appropriate mitigations. The FAA uses this process for each individual COA application in order to ensure each UAS operation is dealt with appropriately. Airport operators are encouraged to learn and use this process to understand the risks associ- ated with UAS operations at their airport. This process can and should be applied to all aspects of the UAS operation, not just when the UAS is moving on the ground or in the air. 8.2 Security and Access Control The physical security and access control aspect of UAS will depend on the UAS operator’s needs and the airport environment. Part 139 certificated airports have specific security and access control requirements because of the commercial aspect of the operation. For all airports looking to bring in UAS operations, modifications to the airport security and access control plan may be required. Airport operators can work with the UAS operator to define the specific, detailed UAS security requirements, and integrate them into the airport security and access plan using 49 CFR Part 1542, Airport Security, as guidance. In the airport cases researched for the primer, the UAS operation fit into the existing security program at the particular airport. This was identified as one of the primary reasons the UAS operator began operations at the particular airports interviewed. For many UAS systems, the personnel maintaining and operating the aircraft will need access to the majority of the airfield. Some UAS personnel may only need to access hangar and tie- down areas, while others will need full access to the movement and runway safety areas in order to launch and recover the aircraft. An airport might introduce a catapult launched system where the aircraft and support personnel transit to a remote part of the airport to conduct flight operations. Thorough planning will ensure the security of the operations and the airport in general.

UAS Safety and Security 47 Chapter 1 Chapter 5 Chapter 3 Chapter 7 Chapter 9 Chapter 2 Chapter 6 Chapter 4 Chapter 8 A ppendices Airport operators that anticipate UAS operations are forthcoming or are actively pursuing UAS tenants, may be well served by developing a security and access control plan that is tailored to meet a UAS operator’s needs. The plan may include the following aspects: • UAS isolation from other tenants and operations (perhaps using a completely separate facility) • Controlled access to the facility (card access, lock and key) • UAS operational security requirements (special considerations for when the UAS is moving on the ground or within close proximity to the airport, such as a total ground stop of other aircraft) • Special UAS operator security requirements (data and document storage) • Special UAS operator security requirements (data and communications transmission) This list is intended to begin a thoughtful process on how security issues with UAS might be managed. In some cases, no additional security arrangements will be required, but sound planning and research will go a long way to ensuring a secure airport environment. 8.3 Emergency Response Requirements UAS operations typically fit within the current emergency response plans and systems airports have in place. Outside of the thorough planning and implementation of lost link procedures and emergency holding points, no specific or unique emergency response requirements associated with UAS were introduced by the airports with UAS experience. In many cases, general aviation airports without dedicated emergency response assets merely made the responding authority aware of the UAS activity just as they would if a new tenant flying manned aircraft entered the operations and considerably increased the number of flights conducted from the airport. Airport operators should consider an emergency response overview as part of any UAS educa- tion and outreach that they provide to their communities. Educating local law enforcement and fire departments should be a priority when UAS operations are anticipated or are in the plan- ning stages. Emergency responders should be provided information such as UAS types, sizes, fuel types and capacities, propulsion systems, and payloads should the UAS suffer an accident. Providing this information and getting feedback from local responders may ensure the success of response actions and improving the public’s perception of UAS. 8.4 Aircraft Rescue and Firefighting Considerations ARFF considerations are driven by the type of UAS at the airport and the operational modes of the UAS. The ARFF personnel at some airports interviewed for the primer received specific UAS familiarization. As an example, the airport ARFF personnel at the VCV in Victorville, CA went through a complete familiarization of the different systems flown at the airport. The familiariza- tion included briefings on the aircraft, the duties of the ground crews, and the general operation of the UAS on the ground and in the air. The familiarization was intended to make the ARFF personnel aware of any unique issues so that in the event of an emergency response, the ARFF personnel would have a sound understanding of the situations to which they could respond. The familiarization included but was not limited to the following: • Fuel used and fuel tank placement • Fuel shut off valve location • Onboard fire suppression systems • Control systems (onboard computers) • Communication devices

48 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 • Payload access • Operational characteristics (performance) The ARFF considerations are listed on the checklist included in Appendix C for reference. For those airports that do not have ARFF coverage, the issue is still applicable and one to be discussed with the fire department that is responsible to the airport for response in the event of an emergency. 8.5 UAS Safety Incident Reporting The success and acceptance by the public of expanded UAS operations will hinge partly on how safe and secure those in the communities served by airports feel with UAS flying above or near them. As UAS flight exposure increases, the likelihood of an accident or incident involving a UAS will also increase. Airport operators can play an important role in ensuring the successful integration of UAS into the NAS. Airport operators will play an important role to ensure safe UAS operations. While the inte- gration of runway dependent UAS at airports may take time, the introduction of small UAS is gaining momentum at a very rapid pace with many of the small UAS operators flying with a varied understanding of current rules and regulations. As discussed in Chapter 5, the draft rule for small UAS operations would prohibit flights within 5 miles of an airport unless the UAS operator has coordinated the activity with the airport and ATC. The airport operator can serve as a key enforcer and safety monitor for small UAS operations by knowing the rules, educating their communities on the rules, and reporting incidents to the FAA for both proper enforcement and safety data collection. The FAA offers an Aviation Safety Hotline that can be used to report incidents involving UAS. The hotline can be reached by telephone by dialing 1-866-TELL-FAA (866-835-5322) and select- ing Option 4. Incidents can also be reported by completing the form on the FAA Contact the Aviation Safety Hotline webpage located at https://www.faa.gov/contact/safety_hotline/. Airports are also encouraged to use their individual safety reporting systems as a means to collect information on UAS safety. Such reporting systems are vital parts of an airport SMS. Whether the system involves a telephone hotline, a specific safety email address, or an anony- mous means to report concerns, all airports including those that do not currently have UAS activity can plan important roles in ensuring the safe and successful growth of UAS operations in the United States.