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Managing and Engaging Stakeholders on UAS in the Vicinity of Airports Â 25 3 Safety and Emergency Management Best Practices It is important for airport operators to understand how to deal with UAS accidents and incidents, including sightings of unauthorized UAS operations, and their potential ripple effect on airport operations. This section describes best practices related to handling emergency situations due to UAS operations in the vicinity of an airport. In developing these topics, both tactical operations (reacting to a UAS incident) and strategic planning (guidance on anticipating UAS incidents) were considered. Safety Management Systems A safety management system (SMS) addresses the safety risks to people, property, and business needs through the declaration of an organizational safety policy, promotion of an overall safety culture within the organization, safety risk management (SRM) personnel and protocols to address and mitigate potential safety hazards, and a safety assurance policy to ensure long-term safety is maintained as it evolves. A relatively recent tool used by airports, an SMS document captures this system. This allows dissemination to the appropriate stakeholders, defines clear instructions on the system and its execution, and can be shared with others as part of certification, operational approval, or demonstration of the organizationâs safety protections. Note that most smaller airports may not have an SMS in place. To-date, a clear mandate for inclusion of UAS-specific SMS sections or documents does not exist. However, it is a best practice to integrate UAS safety within an SMS program. The ACRPâs SMS guidance for airports (ACRP, 2007) defines an SMS and system safety as follows: ï· âA safety management system (SMS) is a formal, top-down business-like approach to managing safety risk that is built on basic system safety principlesâ (ACRP, 2007). ï· âSystem safety is the application of engineering and management principles, criteria, and techniques to achieve an acceptable level of safety throughout all phases of a systemâ (ACRP, 2007). Additionally, the FAAâs Air Traffic Organization (ATO) has published its own Safety Risk Management System Manual (2017b) to provide SMS specific guidance its overall safety assurance of an evolving national airspace system. Additional guidance regarding SMS principles is contained in FAA Advisory Circular 120-92B. 3.1.1 UAS Considerations for an Airport SMS A well-defined airport SMS could be sufficient to address the integration and approval needs of UAS operations at the airport, including operations within the vicinity of the airport, operations by airport tenants, operations from outside organizations, and operations performed by airport personnel in support of airport operations. UAS Considerations for SMS Development or Revision: In Table 3, a number of special considerations for the SMS are provided for each major element of the SMS. Typically, safety and security considerations are handled by the airport operations department or managers in the case of smaller airports that fall under Part 139 certification. Larger airports have a dedicated safety officer that oversees the development and management of the SMS.
Managing and Engaging Stakeholders on UAS in the Vicinity of Airports Â 26 Table 3: UAS considerations for airport SMS Element SMS Considerations Safety Policy An airportâs policy statement should remain consistent so long as it is sufficiently broad and inclusive such that UAS operations addressed implicitly or explicitly. An airportâs organizational structure may wish to identify special safety personnel to oversee UAS operational safety. Safety Risk Management (SRM) Airport Safety Risk Management (SRM) should promote best practices in the assessment of UAS operations and systems integration within the SRM and Safety Assurance (SA) processes. It should account for safety risks within the airportâs control, such as approval of public and commercial UAS operations in the vicinity of the airport. It should also consider safety risks resulting from potential nearby hobbyist activities such as those from nearby neighborhoods, parks, schools, etc. SRM should utilize tools such as UAS Facility Maps (FAA 2017e) and Geographic Risk Maps. Risk Mitigation strategies should consider at a minimum: ï· Airport emergency planning ï· Contingency management ï· Issuance of NOTAMs ï· Personnel training ï· New infrastructure/resources (e.g. changes in airspace, changes in safety resources at airport, new off-limit areas, etc.) Safety Promotion UAS tenants, operators, and maintainers should be integrated into the airportâs safety culture. Periodic training should include UAS tenants, operators, and maintainers. These training sessions can be conducted as workshops and webinars with updates and information shared through various mediums (e.g., websites, web application, flyers) developed to engage with the community. Safety changes resulting from UAS integration should be communicated to all appropriate employees. UAS safety lessons learned should be shared with airport employees, tenants, and other airport stakeholders.
Managing and Engaging Stakeholders on UAS in the Vicinity of Airports Â 27 Element SMS Considerations Safety Risk Assurance (SRA) Safety Risk Assurance should include regular UAS safety reviews (e.g. internal or external safety audits) to ensure UAS operations are adhering to the safety standards of the airport. UAS incident/accident reports should be shared with airport safety personnel to ensure lessons learned are captured and newly identified hazards are addressed by the SRA process. Corrective action should be taken to address new safety issues identified by a UAS safety review. Coordination with FAA and local law enforcement could help facilitate the identification of safety hazards from off-airport entities operating in the vicinity of and/or over airport property/airspace. Utilization of SMS by Airport for Integration of UAS: The SRM and SRA process should be triggered with the integration of any related operational change including any new UAS system introduced into the airport environment under an SMS. This is not currently a regulatory requirement, but it is a recommended practice to ensure that operations sponsored by the airport or airport tenants are conducted in adherence to the established safety culture of the airport. For the integration of a new UAS into the airport environment, an SRM review and SRA will be required to examine identify and mitigate all potential hazards prior to approval of operations. This review should include, but not be limited to the details of the operation, its contingency management strategies, personnel, airport access requirements, infrastructure requirements, and ATC coordination. For the integration of long-term infrastructure to support UAS operations, or the development of an environment for routine UAS operations and support (i.e. launch and recovery systems, control stations, communication systems, staging areas for runway takeoff and landing) the SRM SRA process is also required to determine the impact of these changes and mitigate risks to an acceptable level. Other uses of the SMS for support of UAS can vary based upon circumstances including the airportâs other SMS requirements. With airport operations, promotion of safety is also important. Given that some UAS operators may have limited or no aviation experience, it is important that fundamental SMS safety promotion and training is provided to those tenants/operators performing the UAS operation. Figure 9 presents a notional workflow of the safety risk assessment process for an airport with an established SMS. Within the workflow, the airport has direct authority to accept or reject proposed operations launching and/or recovering from its airspace (e.g., operated by airport or airport tenant). Additionally, the airport can collect data of local incidents/accidents, pilot reports, and reports to law enforcement regarding unsafe or unauthorized UAS operations. For either path, the safety risk assessment process commences to determine if a hazard exists exceeding acceptable risk thresholds to warrant mitigation (as documented in the airport SMSâs SRA process). Mitigation can be performed by the requesting UAS operator when the SRA is addressing a requested new UAS operation. Mitigations can also be performed by the airport and other relevant stakeholders (e.g. ATC and law enforcement). Once risks are sufficiently mitigated, the results of the process should be documented and any further actions (e.g., approval to UAS operator to commence operations) is performed.
Managing and Engaging Stakeholders on UAS in the Vicinity of Airports Â 28 Figure 9: Notional SMS/SRA workflow for airports. 3.1.2 SMS Resources Table 4 defines resources that provide more guidance and insight on SMS development. The resources in the first three topics (SMS Manuals, SRM/SA Guidance, and SMS for Airport Guidance and Resources) possess generic SMS information, while the resources in the last topic (SMS for UAS Operators Guidance) are specific to UAS.
Managing and Engaging Stakeholders on UAS in the Vicinity of Airports Â 29 Table 4: Safety Management System resources Topic Resources SMS Manuals FAA Safety Management Systems (web portal) (FAA 2017b) FAA Advisory Circular 120-92B FAA Air Traffic Organization Safety Management System Manual (FAA 2017d) ICAO Safety Management Manual (ICAO, 2017) SRM/SASRA Guidance FAA/Eurocontrol ATM Safety Techniques and Toolbox (FAA and Eurocontrol, 2007) System Safety Handbook (FAA 2017c) SMS for Airports Guidance and Resources FAA Order 5200.11: FAA Airports (ARP) Safety Management System (FAA 2010) AC 150/5200-37: Introduction to Safety Management Systems (SMS) for Airport Operators (FAA 2007) External SMS Efforts, Part 139 Rulemaking: Documentation from Airport SMS Pilot Studies (FAA 2017) ACRP Report 1: Safety Management Systems for Airports, Volume 1: Overview (ACRP, 2007) ACRP Report 1: Safety Management Systems for Airports, Volume 2: Guidebook (ACRP, 2009) ACRP Synthesis 37: Lessons Learned from Airport Safety Management Pilot Studies (ACRP, 2012) SMS for UAS Operators Guidance The Safety Risk Management of Unmanned Aircraft Systems (Clothier and Walker, 2014). Safety Risk Assessment for UAV Operation (Wackwitz and Boedecker, 2015) UAS Contingency Management Contingency management defines how the system and people should respond to common UAS in- flight hazards. For such hazards, a contingency management plan defines the system response and/or procedures that will be executed upon detection of a contingency state. Table 5 presents several common UAS contingency types with a brief overview. Despite the benefits of integrating UAS operations in and around airports, there are accompanying challenges and potential uncertainties impacting airport operations posed by routine UAS operation within its vicinity. To this end, airport managers need to be conversant with the possible contingency modes of UAS to better anticipate and mitigate the impact of UAS operating within a contingency mode. Airports should consider developing a general contingency plan for UAS
Managing and Engaging Stakeholders on UAS in the Vicinity of Airports Â 30 operations around an airport that addresses the roles and responsibilities of different stakeholders, including, among others, UAS operators, airport personnel, and local air traffic control. However, the uniqueness of each unmanned system also requires that airport managers coordinate with the UAS crew on the plans of action that may not fit the general contingency plan. Such plans should be well-articulated and distributed to appropriate stakeholders so that each has clear and concise roles, responsibilities, and courses of action when such situations arise. This has the potential to mitigate or reduce the adverse effects of unplanned Situations. Table 5: Common UAS contingency event types Contingency Events High-Level Overview Lost Link Lost link procedures define the method of detection and response to a loss of positive control of the UAS as a result in an intermittent or full loss of radio frequency (RF) communication between the ground control station (GCS) and the UAS. Lost Communications with ATC Lost communications with ATC procedures define the pilotâs response in the event that communication with ATC is lost. These procedures could include technical debugging of the appropriate systems, communication through alternative means (e.g., phone), transponder settings (if equipped), or initiating a return home. Degraded or Lost GPS Lost GPS procedures address the situation in which the quality of the GPS measurement of aircraft position and altitude are not sufficient to navigate and/or maintain safe operation. In addition to notifying ATC, the procedure must define procedures to safely land or terminate the UAS manually, since most automated operation relies upon GPS. Engine Failure An engine failure procedure must provide guidance on how to determine that the engine has failed or is failing based upon engine parameters, altitude loss, and audible cues. Typically, contingency management of an engine loss for fixed-wing UAS involves locating a suitable location within the power-off glide distance of the aircraft (unpopulated or sparsely populated), notification of ATC, and attempting to restart the engine (time permitting). For multi-rotor UAS, contingency management must consider the capabilities of the platform. It is typical for a multi-rotor UAS to lose control and crash upon an engine failure. Some systems are equipped with suitable propulsion redundancy and/or advanced control algorithms permitting limited control suitable for an emergency landing. Loss of Electrical Power Loss of electrical power represents a challenging contingency state as most flight controls reply upon electrical power to operate. Contingency procedures for a loss of electrical power would identify any diagnostics and guidance on suitable safety notifications. Fly Away A fly away is typically a more extreme case of a lost link, in which the aircraft not only has a loss of positive control from the PIC, but has also deviated from its pre-
Managing and Engaging Stakeholders on UAS in the Vicinity of Airports Â 31 Contingency Events High-Level Overview planned contingency route. To address fly away, procedures must exist to determine that the aircraft has deviated from its intended path, coordinate with ATC regarding the emergency situation, and terminate flight when available. Of the various contingencies identified above, only lost link contingency planning is well-defined within FAA documents. FAA Order JO 110.65X (October 12, 2017) provides guidance to traffic controllers regarding how to handle UAS lost link events. While this guidance is geared towards ATC personnel, this document should be considered as part of the coordination between ATC and airport operations departments/managers responsible for handling lost link procedures. UAS contingency planning is unique to its operational environment, equipage, capabilities, and crew. Section 3.2.1 briefly defines the elements required for a contingency plan and Section 3.2.2 describes contingency planning procedures for a lost link event. 3.2.1 Elements of a Contingency Plan This section defines the key elements that must be addressed in a UAS contingency plan. Definition of Failure: UAS operations are still evolving and the potential for unpredictability during operations remains very high. A contingency plan is a series of actions to be taken in the event of an unforeseen or unpredictable event occurring during a planned mission (FAA 2006; Fern, Rorie, & Shiveley, 2014). This section generally describes steps to help prevent a hazardous condition from further developing into a dangerous or fatal situation. Some possible occurrences identified include loss of communication with ATC, engine failure, loss of electrical power, and navigation failures including lost link, GPS failure, and fly away. Method of Detection: The prompt identification of a potential situation requiring activation of an alternative plan is key to minimizing the adverse effect of such a situation. Different methods of detection exist for emergency situations in UAS operations; the most effective means of detection includes a combination of detection methods. Some methods of detection in UAS operation available to airport operators include verbal communication from UAS flight crew, visual identification of UAS flight modes, and electronic detection methods such as ATC radar displays. A combination of more than one of these modes would be an effective means to confirm a situation exists and trigger appropriate response to meet the situation. Action by relevant parties: Based on the nature of the situation, the following parties would respond: ï· Unmanned Aircraft (UA); ï· Remote PIC and crew; ï· ATC/Airport manager; ï· Others. The contingency plan must define the roles, responsibilities, and procedures of each party to ensure proper coordination among relevant stakeholders.
Managing and Engaging Stakeholders on UAS in the Vicinity of Airports Â 32 3.2.2 Example: Lost Link Procedure Considerations Lost link procedures are one of the most common types of contingency management procedures. A lost link situation occurs whenever the pilot loses positive control of the UA because of a full or partial interruption in RF communication between the GCS and the UA (Fern, Rorie, & Shiveley, 2014). This is sometimes referred to as loss of command & control link or âC2â link. ATC requirements for UAS lost link events involving UAS operating under a COA or Section 333 Exemption are provided in FAA Order 7110.65X (201765W (2015), Section 5-2-9, âUnmanned Aircraft Systems (UAS) Lost Link.â Figure 10 describes the process for dealing with a lost link problem. Figure 10: Roles and responsibilities for a lost link procedure Other Responses: A lost link procedure could include additional support including the use of spotters to help locate the aircraft, emergency personnel to clear the scene near the rally/termination point, airport rescue and firefighting (ARFF), or other suitable firefighting/first responder organizations support to address any injury or fires resulting from an unsuccessful recovery. 3.2.3 Airport Considerations for Contingency Management In general, UAS contingency managementâs purpose is to mitigate the risk of a UAS incident/accident by addressing common technical issues through pre-defined and pre-coordinated procedures. Some considerations for UAS contingency management that should be addressed by airports include, but are not limited to the following: ï· Identify the person responsible for reviewing contingency management plans for UAS operations at the airport or in its vicinity
Managing and Engaging Stakeholders on UAS in the Vicinity of Airports Â 33 ï· Identify hazards addressed by the contingency management plan, and determine if those hazards are sufficiently mitigated as per the SRA defined in the airportâs SMS ï· Ensure that the contingency management plan does not produce secondary or tertiary hazards through its impact to the terminal airspace and airport surface operations. Airport-specific contingency management plan factors should be developed by airport management in coordination with their operations department/manager as well as local ATC. It is important to ensure that the UAS emergency plan and/or Airport Emergency Plan (AEP) sufficiently addresses preparation and response to hazards produced by the contingency state and/or the results of a UA failing to return home safely. Guidance for Emergency Plans for UAS Operations at Airports This section provides guidance on developing an AEP for UAS operations at airports or integrating UAS emergency considerations to an existing AEP. An AEP should provide guidance on: ï· Preparation for an impending emergency; ï· Response to that emergency with a primary goal of public safety; and ï· Recovery post-accident including investigation, clean-up, reporting, and restoration of airport services. An AEP is required for all airports certified under Title 14 CFR Part 139 Â§ 325 (2017), which includes most non-general aviation airport categories supported by this guidance document. Airport operators should reference the FAAâs guidance under FAA Advisory Circular (AC) 150-520-31C, âAirport Emergency Planâ (FAA 2009). For all other airports, even if an AEP is not required, documentation of UAS emergency planning at the airport would improve the overall safety of routine UAS operation at the airport and promote a safety culture within the organization. The guidance provided herein should be applicable to either circumstance. Additional references include in Section 3.3.6 of this guidebook. 3.3.1 UAS Incident/Accident Procedures The UAS Emergency Plan must define UAS incident/accident procedures (i.e., how the actors within the emergency plan respond to the emergency, including pre-emergency and post-emergency response). An airportâs AEPâs hazard-specific plans addressing aircraft accidents and incidents is a great resource to support the development of these procedures; however, UAS-specific considerations should also be addressed, such as those highlighted in Table 6. The airport will follow a process similar to the one shown in Table 7 to develop their UAS Emergency Plan.
Managing and Engaging Stakeholders on UAS in the Vicinity of Airports Â 34 Table 6: Considerations for UAS incident/accident procedure development Examples of UAS-specific considerations for Emergency Plan Incident/Accident Procedures ï· UAS type, size, and operational characteristics ï· Procedures to mitigate risk identified by the airportâs SMS for UAS operations for UAS incidents/accidents during: o Uncoordinated operations (e.g., hobbyist operations), and o Operator-Airport Coordinated operations; ï· Procedures established by the UAS operatorâs SMS or emergency management plan; ï· Air-to-air and air-to-ground collision incidents/accidents; ï· Procedures for handling incidents/accidents involving unsafe use. The following process could support the development of the UAS incident/accident procedures for a UAS Emergency Plan: Table 7: Process for UAS incident/accident procedure development Collect ï± Current AEP or similar relevant emergency plans ï± Emergency procedures from airport, local, state, and federal response agencies ï± Existing SMS documents from airport and/or UAS operator(s) ï± UAS contingency management plan(s) ï± Associated UAS manuals and SOPs ï± UAS -specific documents including material safety data sheets (MSDS) and recovery procedures Analyze ï± Identify gaps in current aircraft incident/accident procedures ï± Identify UAS-specific hazards and procedures identified from collected materials Develop ï± Draft new UAS incident/accident procedures such that it o Addresses all identified gaps o Aligns with airport, local, state, and federal response agenciesâ procedures o Includes standard operating procedures for pre- and post- accident response 3.3.2 Communication Planning The UAS Emergency Planâs communication planning section should address UAS-specific gaps in the existing communication plan.
Managing and Engaging Stakeholders on UAS in the Vicinity of Airports Â 35 The plan should consider the location of UAS personnel during the operation and their roles within the routine operation and emergency procedures. Off-airport resources must also be identified, including local police, firefighting, and rescue services, and the communication infrastructures needed for the response to a UAS incident/accident. The plan should include the proper procedures for communication that includes appropriate UAS operations and support personnel. An example of this communication is provided in Figure 11. In the example, the UAS pilot in command, who could be located on airport or off airport, is able to communicate with airport operations via VHF radio using the airport operations frequency. This communication allows the UAS operator to provide airport operations with UAS specific information, including details of incident/accident and hazardous materials (if relevant), as well as the identification and location of UAS crew members (including visual observers), etc. A typical communication plan (as shown in FAA AC 150-520-31C, âAirport Emergency Planâ (FAA 2009) includes the declaration of communication frequencies between various emergency response organizations. Those elements are excluded to highlight the UAS PICâs relationship with the key response team entities. When defining the organization and assignment of responsibilities section of the communication plan, the plan must incorporate the roles and responsibilities of all personnel, tailored toward any UAS- specific needs. Furthermore, the section must identify and assign responsibilities to relevant personnel associated with UAS operation, which may vary between organization and operation, but could potentially include: ï· Airport tenants providing UAS services; ï· UAS pilot in command; ï· UAS visual observers; and ï· Other UAS-specific safety personnel and human resources.
Managing and Engaging Stakeholders on UAS in the Vicinity of Airports Â 36 Figure 11: Example of a UAS integration into emergency management communication plan 3.3.3 Alerts and Notifications An emergency planâs alerts and notifications section addresses the needs for alerting those whose safety is potentially impacted by the UAS operation. For a UAS emergency plan, the authors must consider what UAS-specific warnings are relevant to their airport and its supported operations. Some considerations include: ï· Purpose of the alert; ï· Individuals to be notified by the alert; ï· Mechanism for issuing alert and how individuals with special needs are accommodated; ï· Addressing system failures with the alerting mechanism; ï· Coordination of alerts across multiple jurisdictions (especially when considering off-airport emergencies); and ï· Pre-written alert messages and their variations.
Managing and Engaging Stakeholders on UAS in the Vicinity of Airports Â 37 3.3.4 Local Media Coordination FAA AC 150/520-31C, Airport Emergency Plan (2009) provides guidance regarding coordination with local media in the event of an airport emergency to address the timely release of information relevant to public safety, notification to impacted, and address any misinformation. This task is typically delegated to a public information officer. In addressing UAS-related emergencies, much of this plan remains consistent with the reporting of all other airport emergencies as defined by the airportâs emergency plan. One consideration for local media coordination on UAS emergencies is the handling of sensitive and/or proprietary information. For instance, operation by a military or law enforcement agency may wish to limit the details of information release to avoid inadvertent disclosure to the nature of the operations being performed by the unmanned system. The terms of non-disclosure agreements and other arrangements must also be considered. A greater sensitivity exists when addressing UAS emergencies to the media. Misinformation related to UAS operations has adversely harmed the UAS industry/operations several times in the past decade. Therefore, it is critical that information related to a UAS emergency is delivered in a timely manner to avoid excessive speculation with the utmost clarity. A variety of communication modalities can be considered within the communication plan. Direct interaction with media includes interviews, press releases, and press conferences. Additionally, release of information to the public and media through social media is becoming more common. Social media provides one avenue for information release for public alerts and to directly share statements from the airport and/or responding entities, which provides additional modalities of information dissemination in a world where communication modalities are becoming increasingly varied. 3.3.5 Post-Emergency Reporting and Recovery Procedures External reporting of aviation incidents and accidents are also required. Under Part 107, within 10 calendar days of an incident or accident that results in serious injury/death to a person or damage to property (excluding the sUAS) so long as the repair costs or fair-market cost of a total loss of property exceeds $500. Reporting is handled either by phone with the operatorâs local FAA Regional Operations Center, or via an online form (FAA, n.d.-b). UAS operated under a Section 333 Exemption and blanket COA have different reporting requirements, which require using the COA online system. As per FAA Form 7711-1 (FAA n.d.), within 24 hours of an incident/accident, the FAA must be notified via email and an online form. Accidents/mishaps must be reported in the event that the incident/accident resulted in a loss of life resulting from the UAS operation within 30 days of the accident, serious injury, total unmanned aircraft loss, substantial aircraft damage, and damage to property other than the UAS (FAA n.d.). Incidents must be reported if one of several inflight system failures/emergencies occurred: if the incident was an airborne collision with another aircraft, deviations from the terms of the COA, ATC instruction, or other agreements; a fly away aircraft; or contingency plan execution for lost link procedure (FAA n.d.) Under Title 49 CFR Â§ 830.549 CFR Â§ 830.5, the UAS PIC must also report incidents and accidents to the National Transportation Safety Board (NTSB). The NTSB reporting requirements are separate and distinct from FAA reporting requirements.
Managing and Engaging Stakeholders on UAS in the Vicinity of Airports Â 38 3.3.6 Emergency Planning Resources Additional planning resources can be found in the following sources: ï· Airport Emergency Planning Resources o AC 150/520-31C: Airport Emergency Plan (FAA 2009) o Airport Emergency Plan Checklist (FAA n.d.-c) o Airport Emergency Plan Template (NH.gov, 2017) o ACRP 04-19 Airport Emergency Planning Template: NIMSâIncident Command System Compliance (ACRP, n.d.) (project ending soon) ï· UAS Incident/Accident Reporting Resources o FAA FORM 77-11 UAS: Blanket COA for any Operator issued a valid Section 333 Exemption (FAA n.d-a) o FAA Reporting an Accident (Part 107) (FAA n.d.-b) o 49 CFR Â§830.5 Immediate Notification (49 CFR Â§ 830.5, 2017). Â