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Combining Mixed-Use Flight Operations Safely at Airports (2016)

Chapter: Chapter Fourteen - Unmanned Aircraft Systems

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Suggested Citation:"Chapter Fourteen - Unmanned Aircraft Systems ." National Academies of Sciences, Engineering, and Medicine. 2016. Combining Mixed-Use Flight Operations Safely at Airports. Washington, DC: The National Academies Press. doi: 10.17226/23568.
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Suggested Citation:"Chapter Fourteen - Unmanned Aircraft Systems ." National Academies of Sciences, Engineering, and Medicine. 2016. Combining Mixed-Use Flight Operations Safely at Airports. Washington, DC: The National Academies Press. doi: 10.17226/23568.
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Suggested Citation:"Chapter Fourteen - Unmanned Aircraft Systems ." National Academies of Sciences, Engineering, and Medicine. 2016. Combining Mixed-Use Flight Operations Safely at Airports. Washington, DC: The National Academies Press. doi: 10.17226/23568.
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Suggested Citation:"Chapter Fourteen - Unmanned Aircraft Systems ." National Academies of Sciences, Engineering, and Medicine. 2016. Combining Mixed-Use Flight Operations Safely at Airports. Washington, DC: The National Academies Press. doi: 10.17226/23568.
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Suggested Citation:"Chapter Fourteen - Unmanned Aircraft Systems ." National Academies of Sciences, Engineering, and Medicine. 2016. Combining Mixed-Use Flight Operations Safely at Airports. Washington, DC: The National Academies Press. doi: 10.17226/23568.
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Suggested Citation:"Chapter Fourteen - Unmanned Aircraft Systems ." National Academies of Sciences, Engineering, and Medicine. 2016. Combining Mixed-Use Flight Operations Safely at Airports. Washington, DC: The National Academies Press. doi: 10.17226/23568.
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80 Unmanned aircraft systems (UAS) is the preferred collective term used to describe what formerly was known by other descriptors, such as drones, unmanned aerial vehicles, remotely piloted aircraft, or remotely piloted vehicles. In Unmanned Aircraft Systems (UAS) Frequently Asked Questions, the FAA defines UAS as unmanned aircraft and all of the associated support equipment, control station, data links, telemetry, communications and navigation equipment, and so forth necessary to operate the unmanned aircraft (FAA 2015d). An unmanned aircraft is an aircraft operated without the pos- sibility of direct human intervention from within or on the aircraft (14 CFR 1). Regulations affecting UAS are still very much in a state of flux, and the breadth and depth of describing UAS operation is beyond the scope of this synthesis. However, an ACRP Report has been published for those seeking to better understand the industry (Neubauer et al. 2015a). Textbox 12 provides five key sources of information available to an airport operator to remain informed about the changing UAS scenario. The North Carolina Division of Aviation is one of the first state organizations to develop criteria for the operation of UAS within its state. State statutes require a commercial and governmental operation in North Carolina to obtain a permit (www.ncdot.gov/aviation/UAS). Obtaining a permit requires an individual to pass a knowledge test on UAS operations. Other sections of the regulation govern the use drones for special imagery, hunting and fishing, weapons attachment, interference with manned flights, and launch and recovery sites. The FAA distinguishes UASs by categorizing their type of operation and by describing require- ments for both small and regular UASs. The different types of UAS operations can be categorized as public operations (governmental), civil operations (nongovernmental), and model aircraft (hobby or recreation use only). Information on model aircraft operation is described later in this chapter. UASs can be in a variety of shapes and sizes, from the size of corporate jets to hand-launch RC vehicles. They can serve diverse purposes, such as aerial photography and motion picture filming, livestock and animal monitoring, agricultural and geological surveying, utility patrol and infrastructure inspection, search and rescue, and hobby, police and military uses, to name a few. A small UAS (s-UAS) is an unmanned aircraft weighing less than 55 lbs on takeoff, including everything that is on board or otherwise attached to the aircraft (14 CFR 1). A published interim final rule affecting small s-UAS requires registration and marking of s-UASs weighing less than 55 lbs and more than 0.55 lbs (250 g) on takeoff, including everything that is on board or otherwise attached to the aircraft (80 FR 78594 2015). FAA reserves the right to further regulate future micro-UASs that weigh less than 0.55 lbs. FAA aircraft regulations as of February 2016 required any aircraft to be certified, have an air- worthiness certificate, be registered with the FAA, and be operated by a licensed pilot. For UASs, public law allows the FAA to accommodate unlicensed aircraft through what is known as a Section 333 Exemp- tion of the FAA Modernization and Reform Act of 2012, sec. 331(6); 49 USC 44703; 49 USC 44711) (FAA 2013f). Operations of UASs that are not model aircraft operations can only be done with specific authorization from the FAA. The FAA currently authorizes UAS operations that are not for hobby or recreational purposes through one of three means: 1. issuance of COA; 2. issuance of special airworthiness certificates, either in the restricted or experimental categories; chapter fourteen UNMANNED AIRCRAFT SYSTEMS

81 3. an exemption process in which it determines that such operations are in the public interest (also known as a Section 333 exemption). A COA is an authorization issued by the FAA’s air traffic organization to an operator for a specific UAS activity. The COA allows an operator to use a defined block of airspace and includes special provisions unique to the proposed operation. For example, a COA may require flying only under VFR or only during daylight. A COA is issued on a case-by-case basis. Whether a UAS requires an airport runway to operate to and from depends on the craft’s size and purpose. Figure 36 shows a UAS that would use an airport runway. The majority of anticipated s-UASs will not require a runway. Rather, they are hand launched, catapulted, or can operate from an area less than the size of a football field. As of early 2016 UASs could not comply with FAA “see and avoid” rules that apply to all aircraft, making the introduction of UASs into the nation’s airspace a challenge for both the FAA and aviation community. If not properly managed, the risk for collision with other aeronautical users can increase. An NPRM issued for the operation and certification of s-UAS operation uses the segregation of air traffic as the initial means of ensuring safety of operations (80 FR 9544 2015). If enacted, the rule would require s-UAS operators to fly their aircraft at less than 500 ft AGL and at speeds no greater than 100 mph (87 knots), remain within the line-of-sight of the operator, have visibility conditions of 3 mi or greater, be operated only during daylight hours, yield to all other aircraft, and have ATC permission if operated in Class B, C, D, or E airspace. The final rule is expected in June 2016. A task force was established to make recommendations to the FAA on s-UAS registration pro- cesses contained in the NPRM (available at https://www.faa.gov/uas/publications/media/RTFARC FinalReport_11-21-15.pdf). The recommendations were considered by the FAA and resulted in the publication of rules for the registration and marking of s-UAS (80 FR 78594 2015). Additional s-UAS and UAS regulations are expected to continue to evolve over the next several years. The latest information on UAS operations and regulations can be found using the sources listed in Textbox 12. UASs flown indoors, such as in an aircraft hangar or enclosed stadium, do not require registration. A question raised during this study was whether airports are required to make reasonable efforts to accommodate the aeronautical activity under Assurance 22. In a February 2016 update of Frequently TEXTBOX 12 Four Key Sources of Information on UAS 1. FAA’s UAS webpages (https://www.faa.gov/uas/) 2. Association of Unmanned Vehicle Systems International (AUVSI) (http://www.auvsi.org) 3. AC 91-57A Model Aircraft Operating Standards (Advisory Circular 91-57A 2015c) 4. National Conference of State Legislators (http://www.ncsl.org/research/transportation/current- unmanned-aircraft-state-law-landscape.aspx) 5. AAAE’s source for UAS integration (http://www.uashub.org) FIGURE 36 Unmanned aircraft system that uses a runway (Source: https://commons.wikimedia.org/wiki/File%3AHermes_ 450.jpg. Public domain.).

82 Asked Questions on the FAA’s UAS website, the FAA provides policy guidance to airport managers about potential UAS operations on their individual airport (http://www.faa.gov/airports/special_ programs/uas_airports/#qn3). In particular, if a COA has been issued to an operator, the airport spon- sor is to make efforts to accommodate the activity, as UAS operation is considered a permitted user of the National Airspace System like any manned aircraft flight. As part of the FAA’s safety assessment for issuing a COA, a civil or public UAS operation is to enter into an LOA with the airport operator. The LOA would address concerns on communication, ground access, runway and taxiway safety, and other user safety concerns. The airport operator can charge reasonable fees for use of the airport by a UAS. Additional guidance exists on the FAA UAS website for questions related to impact on other aeronautical users, NOTAM requirements, possible need for ALP updates, guidance for law enforcement agencies, and applicability of state and local regulation. ACRP Report 144 suggests that federally obligated airport sponsors treat a new UAS operator as they would any new operator or tenant. This implies that many airports may be unprepared to handle a request for accommodation (Neubauer et al. 2015a). None of the minimum standards and rules and regulations reviewed for this synthesis specifically addressed UAS operation. Some airport standards and regulations did include the statement that aeronautical activity not covered would be evaluated on a case-by-case basis. ACRP Report 144 serves as a primer on UAS, published for those seeking better understanding of the industry (Neubauer et al. 2015a). Information culled from the report that has relevance to this synthesis includes the following: • Research is ongoing across the country on the uses of UAS and how unmanned aircraft can be safely integrated into the NAS. • Early successful UAS operations have occurred at both military and civilian controlled airfields. • The near-term growth of runway-dependent UAS will likely occur at smaller airports with limited commercial air carrier service. • Airport planners and operations personnel need to understand the system requirements prior to commencing the planning for operations. • The operational requirements for runway-dependent UAS will vary from system to system. • For many systems, unmanned aircraft can be treated the same as manned aircraft by airport staff. • Large wingspan UAS may exceed airport design safety areas and require towing operations. • The operation of larger, runway-dependent UAS at civil airports is manageable. • UAS takeoffs and landings are concerned about wake turbulence, winds, and visibility. • A UAS and another aircraft (UAS or manned) are not allowed in an airport’s approach or departure pattern at the same time. Standoff distances are based on environmental conditions, such as weather in the area, and visibility. • A UAS and another aircraft are not allowed on the same airport movement area simultaneously. • 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. • Aircraft may need to sit on the runway for an extended time as navigation and communications systems are brought online. • Equipment used to support UAS can be located near the runway. • UASs taxi at slower rates than regular aircraft, or are towed to and from the runway. • As of early 2016, UASs are not allowed to operate at night, primarily because ATC might not be in operation while GA and cargo aircraft continue to fly. • Airspace separation is widened, based on environmental conditions. • The primary mitigation of collision risks around an airport is having “eyes on” the UAS to main- tain separation, such as a spotter on the ground, a chase plane in the air, positive radar control, or sterilization (separation) of the airspace. • COAs segregate UAS operations from manned aircraft and limit the number of UAS operations. • Careful planning of UAS lost link procedures and holding points are important operational issues to consider.

83 • In the event of lost communications, large UAS are preprogrammed to proceed automatically to a holding point and commence an automatic recovery procedure at a planned and predicted time. • Training of individuals accessing UAS on the airport is necessary. • The placement of communications antenna on an airport is an important factor to ensure no lost link during taxi and ground maneuvering. • Operators of UAS may have extensive to little knowledge of FAA flight and ground rule procedures. • Some UAS will require infrastructure support of land, building, utilities, and the like, similar to an FBO operation. • Some UAS will be independent of infrastructure requirements. • The communications infrastructure at the airport must support the needs of the UAS operator. • Building and maintaining community support for UAS operations is a continuous process. • The need to educate and communicate with local communities to gain acceptance of UAS will increase. • No special UAS environmental concerns were raised by operators, as no exotic fuels are involved and payloads are primarily data collection and communication equipment. • Potential noise impact has not been determined. • Current FAA regulation and safety require UAS to maintain a wider separation between the unmanned and manned aircraft. RADIO-CONTROLLED MODEL AIRCRAFT As defined in the FAA Modernization and Reform Act of 2012, a model aircraft is an unmanned aircraft that is (1) capable of sustained flight in the atmosphere; (2) flown within visual line of sight of the person operating the aircraft; and (3) flown for hobby or recreational purposes (14 CFR 1). Model aircraft and unmanned rockets are not specifically listed as an aeronautical activity, although they do meet the definition of a UAS. Recent rule-making requires model aircraft flown outdoors to be registered with the FAA (80 FR 78594 2015). Although RC model aircraft are not considered an aeronautical activity, the scope of this synthesis included a review of model aircraft activity because as a number of airport operators allow the activity on their airport. The review of the AFD identified 72 airports having issued a remark indicating model aircraft activity occurred on or in the vicinity of the airport (Table 2). The study identified the majority of model aircraft clubs operate on private airports. The evolution of UAS activity and subsequent proposed rules affected long-established and accepted RC model airplane activity because model aircraft meet the definition of UAS. To help clarify the niche that modelers have in being allowed to operate in the national airspace, the FAA updated AC 91-57A (FAA 2015c) and clarified the exclusion that model aircraft enjoy from the regu- lations. Whether a given unmanned aircraft operation may be considered a model aircraft operation is determined with reference to section 336 of Public Law 112-95. (1) The aircraft is flown strictly for hobby or recreational use; (2) The aircraft operates in accordance with a community-based set of safety guidelines and within the programming of a nationwide community-based organization (CBO); (3) The aircraft is limited to not more than 55 pounds, unless otherwise certified through a design, construction, inspection, flight test, and operational safety program administered by a CBO; (4) The aircraft operates in a manner that does not interfere with, and gives way to, any manned aircraft; and (5) When flown within 5 miles of an airport, the operator of the model aircraft provides the airport operator or the airport air traffic control tower (when an air traffic facility is located at the airport) with prior notice of the operation. Model aircraft operators flying from a permanent location within 5 miles of an airport should establish a mutually agreed upon operating procedure with the airport operator and the airport air traffic control tower (when an air traffic facility is located at the airport). Individuals who fly model aircraft within the scope of these requirements do not require FAA permission to operate, although their aircraft must be registered with the FAA if it weighs more than 0.55 lbs. Any flight outside the permission parameters (including any non-hobby, non-recreational operation) requires FAA authorization. FAA provides a brochure that helps to explain what RC model

84 aircraft and s-UAS operators can and cannot do with their model or UAS aircraft (Appendix R). It is noted that AC 91-57A and the NPRM on s-UAS operation and certification address operations of UAS and model aircraft within a 5-mi radius of the airport. Procedures and processes concerning permission to operate within the vicinity of a controlled or uncontrolled airport are still being formulated at the time of this report. The community-based organization that is the official national body for model aviation in the United States is the Academy of Model Aeronautics (AMA) (www.modelaircraft.org). The AMA is the organization whose purpose is to promote development of model aviation as a recognized sport and as a worthwhile recreation activity. In essence, the AMA is similar to the USPA in that both organizations seek to self-regulate members to preclude future federal regulation that may impede the enjoyment of their sport. The AMA has developed a plethora of standards and guidelines for its members. An airport manager seeking guidance about allowing model aircraft activities on his or her airport can find documents from AMA to support the efforts. The AMA operates a charter club system. Each AMA club and/or site owner or property manager decides what can or cannot be flown at a particular flying site. The manager of the club negotiates with the airport manager any conditions for operating on an airport. Model aircraft include fixed wing, rotary wing, and multi-rotor platforms. The AMA provides insurance coverage to its chartered clubs and routinely lists airport property owners as additionally insured. The AMA publishes a National Model Aircraft Safety Code that spells out the requirements for model aircraft clubs and their members when operating model aircraft (AMA 2014) (see Appendix S). The safety code was included in several lease agreements between airport operators and model aircraft clubs that were reviewed for this report. A number of additional safety codes exist on the AMA website for the different kinds of model aircraft flown, including large model aircraft (more than 55 lbs). The AMA requires each club is to adopt site-specific safety and operational rules. A sample site layout diagram is provided in Figure 37. Model aircraft operations are limited to no more than 400 ft AGL and to line-of-sight operation. This normally provides an airspace buffer of 600 ft between the model aircraft and a normal 1,000-ft airport traffic pattern. However, caution is issued for airports that have lower traffic pattern altitudes for helicopter or ultralight activity. The fuel capacity of a model aircraft generally provides for 8–10 min of flight. Fuels used in model aircraft are easily carried in appropriate small containers. On-site fire extinguishers are a norm. Battery-operated electric model aircraft are popular as well. As derived from interviews and the literature search, hazards and risks associated with model aircraft can be: • Interference with regular aircraft; • Use of fuels such as nitromethane, gas, diesel, or jet fuel, depending on the engine; FIGURE 37 Sample layout site plan for RC model aircraft (Source: Academy of Model Aeronautics Publication 706. Fair use.).

85 • Lithium-ion battery overheat; • Loss of radio control link (as a result of failure, out of range, or signal interference); • Radio frequency interference (other than 2.4 gHz); • Operator distraction or incapacitation; • Staging of vehicles and trailers (Figure 38); and • Control of access onto airport. To mitigate these hazards, a number of measures are used, including safety spotters, a buddy-box system (secondary override controller box), preprogrammed failure modes responses or fail-safe modes, operating rules, and safety lines and barricades. Established airport rules and regulations can govern access onto the airport and the placement of vehicles and equipment. Appendices T and U provide a safety briefing used by the Lakeland Linder Regional Airport for informing others of special aeronautical activity on their airport. The form can be used for other coordination and communication purposes. One main consideration for model aircraft activity is noise generation. Airports are often requested by RC modelers to accommodate their aircraft activity primarily because of the open space available, but also because model aircraft can be loud. A target decibel (dB) goal is less than 98 dB in the flight area, but actual noise can be louder. NOTICES TO AIRMEN Appendix G provides a sample of AFD remarks related to UAS and model aircraft operation. Examples of NOTAMs from JO 7930.2P are: • UNMANNED ACFT WITHIN AN AREA DEFINED AS 10NM RADIUS OF AML223010 (10NM SW IAD) SFC-5000FT 1310251000-1310251200 • UNMANNED ACFT WITHIN AN AREA DEFINED AS 10NM RADIUS OF NYL SFC- 10000FT 1312122100-1312122300 • WHEN CLASS D AIRSPACE IN EFFECT UNMANNED AERIAL VEHICLES OPER SFC TO 7000 FT MSL. • MANNED & UNMANNED ACFT NOT AUTHORIZED IN THE SAME TFC PAT. ARRIVING MANNED ACFT MAY FOLLOW UNMANNED ACFT ON FINAL. • CIVIL TRAFFIC PATTERN NOT AVAILABLE DURING DAYTIME UNMANNED AIR- CRAFT TRAFFIC PATTERN OPERATIONS. FIGURE 38 Gathering of model aircraft and support equipment at an airport site (Credit: S. Quilty, SMQ Airport Services, Lutz, Florida. Used with permission.).

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TRB's Airport Cooperative Research Program (ACRP) Synthesis 74: Combining Mixed-Use Flight Operations Safely at Airports documents practices in safely accommodating mixed-use aeronautical activity at airports. Mixed-use aeronautical activity refers to the different categories of aircraft a public-use airport is intended to accommodate in compliance with FAA sponsor assurances. These categories include gliders, helicopters, ultralight vehicles, balloons, airships, blimps, skydiving, aerial applications for agriculture and firefighting, banner towing, aerobatic practice, and similar flight operations. Also discussed are unmanned aircraft systems and radio-controlled model aircraft activity that take place on an airport and can become part of the mix of an airport’s operation. Not discussed are seaplane operations; ACRP Synthesis 61: Practices in Preserving and Developing Public-Use Seaplane Bases covers this topic.

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