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B-1 Airspace and UAS Traffic Management UAS integration with the NAS and associated traffic management with manned aircraft is a top priority of the FAA and aviation industry. Based upon meetings with FAA Airports, ATC and UAS Integration personnel, UAS operating within the airport airspace, including transi- tioning to and from the NAS, must follow established airport terminal airspace and ground operations procedures in addition to FAR Part 107 operational requirements. These include monitoring aircraft and ATC communications, contacting airport management and ATCT personnel (if available) regarding planned operations, monitoring for manned aircraft, giving âright-of-wayâ to manned aircraft operations. Thus, depending upon airport airspace class, additional UAS operating rules and air traffic management procedures will be required to support UAS airport activities. As part of this effort in March, 2019 the FAA proposed requir- ing UAS operators to use the LAANC system within 5 miles of airports. Airport Airspace and UAS The airport operating area includes controlled airspace, which is defined by the level and type of traffic. Depending upon mission and equipment, UAs operate at different altitudes. Commercial small UAS remain limited to altitudes of less than 400 feet, but military UAS can operate at higher altitudes. Figure B-1 illustrates the NAS operating levels for different UAS missions. Airspace surrounding an airport, depending upon type and level of activity and ATC, is defined as Class A, B, C, D or E. Class A is airspace from 18,000 feet to 60,000 feet above mean sea level where commercial UAS are not allowed to operate. Table B-1 describes FAA designated airspace. Each class of airspace requires different equipment and pilot ratings to allow legal entry. To be fully integrated into the civil airspace system, all aircraft, including UAS must comply with these standards for safety, especially with respect to collision avoidance. Airports with airspace classifications of B, C and D are equipped with an on-site ATCT, so a UAS pilot must obtain permission from ATC to operate within this airspace. For UAS opera- tions to be allowed in Class B and C airspace, an FAA waiver and special operating procedures are required. Class B airspace surrounds airports that support high volume airport operations or passenger enplanements (e.g., John F. Kennedy International Airport). Class C airports are also equipped with an ATCT and regularly support commercial passenger service. These airports are similar to Class B airports but on a smaller scale (e.g., Atlantic City International Airport). UAS transitioning from the NAS to the airport airspace must follow operating guidance pro- vided by ATC, if available, or the airport sponsor. This includes specific operating and noise A P P E N D I X B General Airport Issues and Challenges with UAS
B-2 Airports and Unmanned Aircraft Systems Figure B-1. Examples of current uses for drones and their altitudes of operation (GAO, n.d.). Class Coverage Entry Requirements A All airspace that is at or above 18,000 ft MSL (mean sea level) and below 60,000 ft MSL IFR clearance and two-way communication with ATC. B Usually has a radius of 15 miles and a height of 10,000 ft MSL A Mode C transponder within 30 (nautical miles) NM of the airport. Two-way communication with ATC and at least a Private Pilot Certificate. C Mode C transponder to fly in or above the airspace and two-way communication with ATC. D 5-mile radius from the airport, including the surface to 2,500 ft AGL Two-way communication with ATC E From the surface, sometimes 700 ft AGL and most often 1200 ft AGL or 14,500 MSL and below class A at 18,000 MSL Controlled airspace, IFR flights must have two-way communication while VFR must follow weather minimums F Ranges from the surface but below 14,500 MSL Uncontrolled Airspace does not require communication or special equipment Usually a 5-mile radius from the surface to 4,000 ft above ground level (AGL), and an additional 10-mile radius from 1,000 ft AGL to 4,000 ft AGL Table B-1. Classification of air space and entry requirements.
General Airport Issues and Challenges with UAS B-3 mitigation procedures. With the growth of UAS operations including the viability of air taxi, package delivery, and personal air transport, the airspace environment surrounding the airport will likely become larger to support additional approach and departure paths. Expansion of airport airspace, low airspace operations and the transition of UAS from the NAS to the airport environment will necessitate development of new airspace procedures and zoning requirements, which are addressed in later sections of this analysis. Air Traffic Management FAA and NASA are developing a UTM to support civilian low-altitude airspace and UAS operations. The purpose of the UTM is to avoid accidents between UAS and other aircraft. UTM keeps civilian UAS operations to below 400 feet thus limiting interactions with manned aircraft. However, effective coordination is required to address low-flying manned aircraft such as helicopters, crop dusting aircraft and other low-flying vehicles, as well as operations within controlled airspace. NASAâs UTM research platform is designed to provide an initial system for safely integrat- ing UAS into the NAS while obtaining critical data needed to safely incorporate UAS activity into higher altitudes and existing air traffic routes. Under UTM, UAS and manned aircraft would communicate in real time to determine which operation has priority and an alternate route would be provided if needed. Commercial and recreational UAS operators are limited to this lower altitude. However, some UAS research vehicles operated through the FAA UAS Test Centers in addition to DOD have permission to operate at higher altitudes. The impacts to air traffic management at the airport level involve coordination and transi- tion of aircraft to and from the NAS for approach and departure. To address UAS operations in controlled airspace while UTM is being developed, the FAA is implementing the Low Altitude Authorization and Notification Capability (LAANC) system. The system provides some specific ATC and operational requirements for low altitude (400 feet or less) UAS operations. It has been recently proposed that FAA would require UAS operators to use the LAANC system within 5 miles of an airport so they can receive near âreal-timeâ airspace autho- rizations to allow for better flight planning and issuance of NOTAMs and other guidance to manned and unmanned operators (FAA, 2019). The FAA states that LAANC uses airspace data obtained through âtemporary flight restrictions, NOTAMS and UAS facility maps (https:// www.faa.gov/uas/request_waiver/uas_facility_maps/) showing the maximum altitude ceiling around airports where the FAA may authorize operations under Part 107â (Lillian, 2018). It is important to note that the LAANC system also includes information for recreational, commercial and public UAS users operating outside airport terminal airspace according to Air Traffic Division Order N JO 7210.909. Other information regarding LAANC, COAs, and Part 107 waivers is highlighted below. For additional information, refer to the FAA UAS Resources Webinar (https://www.faa.gov/ uas/resources/webinar/faq/). ⢠âIf an operator already has an existing 107.29 waiver, they will still need to request authori- zation through the FAAâs Drone Zone to operate since LAANC does not currently recognize waivers. ⢠Under LAANC, when a part 107 operation is approved via LAANC, there is no require- ment to contact local ATC, as the approved flight will be at/below the pre-determined altitudes. ⢠What do we do if our local controlled airport isnât listed as participating in LAANC? If you do not see your airport on the list of facilities, participating in LAANC, you will need to apply
B-4 Airports and Unmanned Aircraft Systems airspace authorizations through DroneZone (https:FAAdronezone.faa.gov). LAANC is only available at FAA-owned and operated airports (e.g. DFW, LAX, BWI, and BOS). If your air- port does not show, it means your airport is either a Federal Contract Tower or is owned and operated by the DOD. ⢠Are cities and local governments required to have a waiver? Yes, City/county/state/federal governments need an authorization to fly. Those that qualify under the public statutes 49 USC 40102(a)(41) and 49 USC 40125, can fly some qualified missions as a public aircraft operator and need a COA to fly. To fly under the civil rules (Part 107) they need Part 107 certificated pilots and may need waivers to certain portions of Part 107. City/county/state governments must fully comply with either their COA or under Part 107 if flying under Part 107. If they want a waiver to fly at night under Part 107, for example, they must obtain a waiver to Part 107.29 just like any other Part 107 pilotâ (FAA, n.d.). The LAANC system is a temporary measure to support safe UAS operations within the airport airspace and NAS. In discussions with Airport Operators and FAA, airport sponsors have two options. If the airport does not currently have procedures in place to address UAS, including FAR Part 107, COA, or other guidance, then LAANC guidance should be applied. However, as is the case for GTR and Cape May County Airport, UAS air traffic management procedures are in place, thus UAS operators must follow the airport sponsorâs approved air traffic procedures. For either option, UAS operators must coordinate with ATC personnel before entering controlled airspace and give priority to manned aircraft operations. However, new regulations currently being drafted may impact the requirement to contact ATC, and require only that a proper flight plan is filed through the LAANC system (FAA, 2019). With the passing of the FAA Reauthorization Act of 2018, Congress directed the FAA to prepare a full plan for UTM services and applicable standards. The Act allows the FAA to authorize private UTM service providers on an interim basis, and publish all data associated with public use UAS COAs. In addition, the GAO was tasked to study the potential impacts of allowing local control of low-level airspace. Local control of low-level airspace may set a bad precedent since it would impact not only commercial UAS activity but low-flying manned operations as well. Safe use of various aero- nautical technology requires standardized national requirements. UAS local restrictions vary throughout the country and sometimes conflict with federal law. If such a transition in airspace control occurs, airport operators will need to work with the FAA, other airports, industry and local governmental personnel to develop simple and standardized operational and communication procedures. UAS Communications Communication infrastructure and procedures are needed to support UAS activity within a controlled and uncontrolled airport environment. Radio CommunicationâPilot and Unmanned Aircraft UAS consists of an aircraft, a remote operating platform and a communication, command and control system (C3), which links the UAS and operating platform. Since pilot control is provided using a radio data link from a remote location, communication is critical for safe operations. The majority of small UAS operations fly within visual line of sight and are con- trolled using unlicensed radio frequencies or spectrums. However, given planned expansion of UAS activities BVLOS, access to spectrum and infrastructure to transmit command signals to the unmanned aircraft is needed.
General Airport Issues and Challenges with UAS B-5 Existing aeronautical radio navigation spectrum between 700 megahertz (MHz) and 5 gigahertz (GHz) are typically used to support UAS command communication links. How- ever, use of these spectrum options along with a lack of licensing requirements is impacting UAS operator use. To address the issue of limited spectrum, the FAA Reauthorization Act of 2018 directs the FAA, the National Telecommunications and Information Administration (NTIA) and the Federal Communications Commission (FCC) to submit a report to Con- gress on whether UAS operations should be permitted to operate on the same spectrum as manned aviation use. To support UAS growth, a fair and efficient system for administering and assigning fre- quencies to government and commercial users is needed. In addition, the UAS industry must standardize the way command signals are delivered. Some international protocols allow for the use of commercial fixed satellite systems. However, it is anticipated that new ground-based facilities will also be needed to provide sufficient bandwidth and coverage. Use of the existing commercial wireless network and infrastructure could support a sub- stantial portion of low-altitude BVLOS missions. However, it is unlikely that the cur- rent commercial wireless system can accommodate operations in remote areas or higher altitude UAS operations. As a result, some communications infrastructure will need to be constructed at an airport to support UAS operations. The FAA and FCC are evaluating whether the system could âpiggy-backâ off existing airport systems or if new ground-based infrastructure would be required. Currently, UAS operators use mobile communication systems and existing wire- less radio frequencies to support the command and control process. But as the spectrum becomes more congested, regulatory action will be needed since the FCC will have to change its rules to allow UAS to use some of the commercial spectrum bands (Turner, 2016). Sense and Avoid Radar Communications FAA regulations require manned and unmanned aircraft operators to apply âsee and avoidâ to evade other aircraft and terrain. This requires UAS operations to remain within visual line of sight. However, as growth continues, BVLOS UAS operations will become the norm. Therefore, an alternative means of compliance is needed. One means has been to employ onboard sensors to provide the location of aircraft that might pose a collision threat. Given the size of most commercial UAS to date, the additional equipment would negatively impact operations by increasing the aircraft weight and takeoff needs as well as limiting range and time in the air. To address this issue, several U.S. and international companies have developed ground-based sense and avoid radar systems for UAS. These systems have and are being used by the U.S. military to allow UAS to fly within U.S. or international civil airspace. Currently, ground-based sense and avoid (GBSAA) is the only sense and avoid system certified by the FAA and other international regulatory organizations for routine use in civil airspace. According to one manufacturer, SRC Inc., its GBSAA System called LSTARtm can be used to support terminal area operations; lateral transit operations and vertical transit operations from different classes of airspace (SRC, Inc., n.d.). There are multiple options for installa- tion including tripod or pedestal, rooftop or vehicle mount. Ultimately as UAS use expands, GBSAA antenna will become a permanent fixture at the airport. Current information on range and antenna safety area is proprietary. However, applying current ground-based aug- mentation system (GBAS) guidance provided by FAA, an antenna safety area with a radius of 300 to 500 feet is likely with an antenna height of at least 33 feet. Airport development near the antenna must not interfere with the system signal. Therefore, buildings within 500 feet of the antenna can be no more than one-half the height of the antenna array. Building heights
B-6 Airports and Unmanned Aircraft Systems and development beyond the GBSAA safety area need to be designed to avoid limiting or blocking the signal. Radio Communication and Aircraft Management Radio communication between manned aircraft, UAS, and ATC continues be a concern. Since many UAS Part 107 operators are not certified as manned commercial or instrumented rated pilots, they are not familiar with existing radio communication procedures. Although UAS operators must contact local ATC, if available, or the sponsor before operating within airport airspace, ongoing radio communication between air traffic, manned aircraft and UAS operator is not required. Rather, FAA suggests that unless operating under special condi- tions, UAS operators must merely monitor the radio frequency and provide right-of-way to manned aircraft. Discussions with FAA personnel revealed concerns about radio communi- cation congestion associated with too many operators using the same frequency. The FAA Technical Center is currently studying communication procedures and spectrum congestion. Manned aircraft can enter Class B airspace only after obtaining ATC permission, whereas entry into Class C, D, E and G requires prior two-way communications if there is an ATCT present. FAA working with local ATC has issued individual waivers to allow some limited UAS operations within Class B, C and D airspace. However, as UAS operations increase, the LAANC system will no longer be feasible. UAS, ATC and manned aircraft need a communication system which allows for the efficient and safe movement of all aeronautical activity operating within and transitioning to and from airport airspace. Airport Charting Another issue highlighted by UAS users and airport operators involved airport charts and identification of UAS operations. With the growth of UAS and urban air mobility (UAM), alternative vertical takeoff and landing (VTOL) sites are forecast to be developed inside and outside the airport environment. Therefore, in addition to development of new flight routes and procedures, aeronautical charts need to be updated to identify UAS and UAM operating areas. FAA is considering revamping the existing sectional charts to enhance flight planning and readability. SKYVector Aeronautical Charts, provided at https://skyvector.com, identify drone activity areas or drone notices to airmen defining UAS operating areas (DROTAMsTM). Hovering over the DROTAMs, pilots can obtain information about the UAS operating area designation, operating days and times, and operating area. A sample DROTAM for Southwest Florida International Airport (RSW) is shown in Figure B-2. An additional challenge posed by NOTAMs, particular to UAS operations, is determin- ing the area that is being affected. New technologies are being developed by the FAA to help ensure airspace awareness and a safely integrated NAS. Tools that disseminate information rapidly for both manned and unmanned operations include the Low Altitude Authoriza- tion and Notification Capability (LAANC) or UAS Facility Maps. Airport operators can take Figure B-2. Sample DROTAM. NOTAM UAS Operating Area RSW_07/026 DEFINED AS 3NM RADIUS OF RSW262022.4 (19.0NM WSW FMY) SFC-420FT (SFC-400FT AGL) THU FRI TUE WED 1400-2100 1807121400-1812062100.
General Airport Issues and Challenges with UAS B-7 advantage of these tools to distribute cartographic representations when communicating with airport users. As noted in a discussion with Jonathan Daniels, CEO of Praxis Aerospace Concepts, specific charting and identification information needs to be provided to highlight airports that support UAS activity, airports specifically designed to support military and/or commercial UAS (drone) operations (i.e., Droneports) as well as VTOL facilities in urban areas that sup- port UAS and UAM activities. As UAS and UAM operations continue to expand, additional documentation and data need to be provided as part of flight planning and to promote safe operations in and around the airport airspace. Counter-UAS Technology and Airport Infrastructure UAS technology raises concerns relating to safety and security risks such as unauthorized access to critical facilities, terrorism, or other malicious purposes. In 2019 the FAA published Order 8900.504, Expanded UAS Oversight as a recognition of the risks posed by UAS (FAA, 2019). For these reasons, several counter-UAS systems which use radio waves to detect and restrict UAS operations were tested at a few civil airports as part of an FAA pilot program. There are two types of counter-UAS technology. The first type identifies and detects when the UAS enters controlled airspace. This type of technology may include radar, audio and camera systems, but does nothing to deter the UAS from entering the airspace. This type of counter-UAS system involves installing several antennas near the perimeter of the airport property or airport operating area. The ground-based radar systemâs initial detection area varies depending upon terrain and other obstructions, but preferred detection radius is approximately 2 kilometers (6400 feet). The second type of system involves true countermeasure technology allowing the airport to use various methods to take control, capture or destroy an unauthorized UAS entering the controlled airspace. Airports are just one of several industries interested in applying counter-drone technology. In 2016, the FAA UAS Integration Office, along with Department of Homeland Secu- rity (DHS), DOD and other federal agencies, initiated a pilot program with UAS detec- tion manufacturers to evaluate UAS detection and identification capabilities on and near airports. According to FAA guidance provided in a July 19, 2018 letter to airport sponsors, âa number of significant safety implications and practical issues, as well as legal restrictions, existâ (Dermody, 2019). For these reasons, the FAA has not authorized any UAS detection assessments at any federally obligated airports which had not previously participated in the FAAâs UAS detection pilot program. New guidance provided in a May 9, 2019 letter to air- port sponsors stressed that any âentity considering installing a UAS detection system may wish to seek systems specific and site-specific guidance from its legal counsel and/or the appropriate authoritiesâ (Dermody, 2019). Therefore, any airport considering this technol- ogy should evaluate potential impacts on grant assurances as well as how new systems may require updating airport certification manuals and Airport Layout Plan documents. The installation of UAS detection systems may lead to FAA aeronautical study, while national guidance continues to be developed. Further, because of the concerns raised by airport sponsors and elected officials, the FAA Office of Airports and Safety Standards released additional guidance and information about the pilot program findings. This information can be found at https:/www.FAA.gov/uas. The pilot program highlights several safety, legal and practical issues associated with airports deploy- ing UAS detection or other counter-UAS capabilities on or near airports (Dermody, 2019).
B-8 Airports and Unmanned Aircraft Systems A brief list of FAAâs findings is as follows: ⢠Due to substantial high radio spectrum congestion within the airport environment, UAS detection was difficult and, in some cases, impossible. ⢠Certain operational states also limited detection and require a high level of manpower to operate equipment and discern false positives. ⢠Current costs of the system are high and prohibitive. The current system requires several layers of redundant coverage and is likely to become obsolete as UAS technology continues to mature. ⢠The system requires the installation of a permanent system with several sensors to provide adequate airspace coverage. In addition to the sensors themselves which could result in an obstruction to air navigation, the safety areas and coverage distances for these detection tech- nologies varies and would likely negatively impact airport development. Lastly, based upon discussions with FAA Office of Airports and documentation (Dermody, 2019), the FAA reiterated that it does not endorse or support the use of countermeasures in the airport environment since it may introduce greater hazards to the NAS, cause legal issues associated with unauthorized âtakingâ of anotherâs property (i.e., conversion), and violate several provisions of federal criminal law in Title 18 U.S.C. Further, the detection technol- ogy has not yet advanced to the point where it provides reliable and immediate information regarding security threats. The FAA Reauthorization Act of 2018, in addition to UAS funding and guidance, includes a variety of new regulations related to UAS operations and security. One such measure is the Preventing Emerging Threats Act of 2018 which authorizes the Department of Justice and Department of Homeland Security to âtake actionsâ to âmitigate a credible threatâ (defined by the Secretary or Attorney General in consult with the Secretary of Transportation) that an unmanned aircraft system poses a safety or security threat of a covered facility or asset. This mitigation would not require a warrant or judicial review or oversight and could include physically disabling the drone, taking it over, intercepting communications or seizing the drone itself (Greenwood, 2018). As a result of this legislation, the Act requires FAA to deploy counter-UAS systems at five airports within 1 year. Also, under Sections 364 and 365 of the FAA Reauthorization Act of 2018 (2018 Act), the FAA must ⢠coordinate with government agencies authorized to operate counter-unmanned aircraft systems (i.e. Department of Justice, Department of Homeland Security and other federal law enforcement personnel); ⢠review interagency coordination and standards for use of these systems; ⢠establish a program to test existing remote detection and identification technologies; and ⢠âestablish and publicize a mechanism for the public and Federal, State and local law enforce- ment to report suspected unlawful operations of UAS. . . . and adds a civil penalty regimeâ (Kestleloo, 2018) Finally, according to the 2018 Act, the DOT must consult with the DOD related to âidentifica- tion and defensiveâ counter-UAS technology within the NAS. Recent events have increased international interest in applying counter-UAS technology. London Gatwick Airport was brought to a standstill due to drone sightings for 36 hours on December 19, and again for an hour on December 21, 2018 (Christian, 2019). More than 1,000 flights and 140,000 passengers were affected (Christian, 2019). Heathrow Airportâs departures runway was closed for more than an hour on January 9, 2019, because of reported drone activity (White & Grafton-Green, 2019). Both airports have announced they will make significant investments in counter-UAS technology (Morrison, 2019).
General Airport Issues and Challenges with UAS B-9 Urban Air Mobility and Autonomous Vehicles UAS technology has also spurred the development of urban air transport/urban air mobility (UAM). The UAM system involves an on-demand network of small, electric aircraft that takeoff and land vertically to allow for rapid passenger and cargo transportation between suburbs and cities and within cities. UAM systems would have the flexibility of having an onboard pilot, being remotely piloted or being fully automated. Uber Air, the companyâs planned urban aviation ridesharing program, plans initially include an onboard pilot before transitioning to a remote pilot system and ultimately to a fully autonomous system. Accord- ing to the company, operations are expected to start as soon as 2023 (Uber Elevate, 2016). In addition to Uber Air, over 75 UAM developers are anticipated to commence operations within the next 5 to 10 years. The UAM community includes FAA, NASA, DOT, General Avia- tion Manufacturers Association, transportation researchers, civil aviation authorities, aircraft manufacturers and startups. In New Zealand, China and Dubai, entrepreneurs are already testing and refining different prototype personal air taxi aircraft with governmental support. UAM uses low-altitude (500 to 5,000 feet AGL) airspace to shuttle one to five passengers or cargo to destinations between 5 and 50 miles. Since proposed UAM systems launch and land vertically, the system is anticipated to provide substantial cost benefits compared with traditional transportation infrastructure. Given the short-haul nature of UAM and existing landside and airside infrastructure at traditional airports, the two systems provide users a symbiotic platform for short and long-haul transportation needs. Many commercial airports are already equipped with large parking garages and ground parking facilities that could be repurposed to create VTOL hubs consisting of multiple takeoff and landing platforms. General aviation airport infrastructure could also be repurposed to support vertiport hubs as well as personal, business and academic manned aircraft activity. Many general aviation airports are located within 10 to 20 miles outside the commercial city center making airports ideal locations for cargo and passenger transportation hubs. By supporting UAM infrastruc- ture demands on an airportâs landside property and infrastructure, conflicts with manned and potentially unmanned large commercial aircraft would be limited. Self-driving cars and other ground automation technology is already being used at airports internationally. Although parking currently represents a significant portion of commercial airport revenues, a decrease in ground parking facilities would allow airport property to be developed based upon highest and best use while also decreasing airport operating and main- tenance costs. A multimodal network and airport city concept will allow airports to maximize their property, reduce environmental impacts, enhance economic growth, while also providing social benefits to its employees, users and the local community. Challenges currently impacting UAM integration include: ⢠Vehicle certification and regulatory operating requirements; ⢠Battery technology; ⢠Vehicle efficiency, performance, and reliability; ⢠Cost and affordability; ⢠Safety and ATC; ⢠Potential noise, emissions, and waste management impacts; ⢠Vertiport infrastructure (Uber Elevate, 2016); and ⢠Pilot, mechanic, and ATC shortages. Although it is anticipated that pilot augmentation technology and automation will reduce the need for pilots and ATC personnel, mechanics to support UAM, UAS and manned aircraft will continue to remain in demand for the foreseeable future. Thus, on-airport facilities to support aircraft maintenance, manufacturing and avionics would continue to remain in demand.
B-10 Airports and Unmanned Aircraft Systems Operational Challenges and Airport Land Use Zoning Integration of UAS operating in and around the airport environment is likely to impact airport operational procedures and airport zoning. Concerns identified by various stake- holders are highlighted in the following sections. Operational Considerations and Challenges Small UAS are difficult to see and be seen by manned aircraft operators and air traffic controllers since they typically lack the onboard avionics used by larger manned aircraft. Since small UAS are operating outside ATC, several operational challenges were identified in relation to airports. ⢠âHow will airborne surveillance of small UAS be assured? Should all UAS operating in and around airports be required to have transponders? ⢠What surveillance is required for airport surface operations? ⢠What airport infrastructure (i.e., information and communication systems and ATC tools) will be required to support anti-collision and airport efficiency? ⢠What type of control procedures need to be in place when airspace, runways, landing areas or parking is limited or capacity constrained? ⢠What is the minimum performance capability required of UAS to operate within the Airport terminal environment? ⢠To what extent would segregation of airspace and surface operations be required? ⢠What failure contingencies must be established to address UAS failures (e.g. lost ATC communications, navigation, surveillance, and emergency)? ⢠How can airports assess the operational and financial impacts of UAS operations on their current business, including liability?â (Matthews, Frisbie, and Cistone; 2017) Other operational concerns identified in discussions with FAA Airports and UAS Inte- gration Office personnel as well as representatives from Praxis Aerospace, Golden Triangle Airport, TBI Airports, and others contacted as part of this study include: ⢠UAS use of airfield facilities may negatively impact capacity. UAS have slower ground speeds and typically require more time than manned aircraft to establish communication and navigation links. ⢠Current UAS, like manned small aircraft, are impacted by wake turbulence, wind and visibil- ity conditions. Thus, larger separation requirements will be required between manned and unmanned aircraft to support safe operations. Since airfield capacity will likely be impacted, can UAS operations be evaluated as part of the airport capacity analysis? ⢠UAS operators must contact ATC and airport sponsors prior to flying in and around the airport environment, so NOTAMs may be issued. Discussions with airport operators revealed that coordination, especially at general aviation airports, is lacking. An electronic notification system warning manned aircraft operators of UAS activity within the area is needed. Operational challenges associated with integration of UAS are numerous and varied. How- ever, several airports such as GTR, Cape May Municipal, Sebring Regional, and Syracuse Hancock International Airport have all safely integrated some level of UAS operations within the airport environment. Each of these airport operators have established specific procedures and communication protocols, which promotes a safe operating environment. The manage- ment of these airports also work with the local community, government, manned aircraft tenants as well as UAS users to identify any issues, concerns and mitigation strategies.
General Airport Issues and Challenges with UAS B-11 Operational protocols must be flexible to allow for the growth of the UAS market and changes in technology. Coordination and communication according to operators is the key to providing a safe and efficient airport environment. Land Use Zoning Airport zoning regulations dictate land use adjacent to or in the immediate vicinity of an airport. Zoning ordinances in and around airports fall under the discretion of each state and are usually enforced by the stateâs department of transportation. Airport zoning guidance is provided by FAA as it relates to airport and airspace obstructions and land use compat- ibility. Discussions with UAS subject matter experts suggest that with improved technology and the rise of automation that current approach and departure zoning criteria may shrink. While others suggest that with the introduction of UAM and redevelopment of the landside areas to support these operations, airport airspace and zoning may in fact increase. To effectively address airport zoning and operational impacts, airports can update their ALP. The ALP depicts both existing and planned future development including existing and future airport property, existing and future airport infrastructure, safety zones and approach and departure profiles, existing and proposed land use on and adjacent to the airport as well as existing and planned non-aviation areas. Airport sponsors asked if UAS development including airspace and surface operating areas should be included on the airport layout plan documentation. Since the ALP is used by the FAA and DOT to identify future needs and zoning requirements, any existing or planned UAS development can be incorporated as part of an ALP update. Airport Compliance and Funding Airport sponsors continue to raise concerns about compliance and funding. At a recent meeting with airport managers in Florida1, several sponsors have and continue to be contacted by businesses requesting to establish UAS passenger air taxi, cargo services and other types of UAS activity at their airport. The FAA has officially designated UAS as an aeronautical activ- ity. âUAS are aircraft under the law and therefore fit the definition of âaeronautical user.â (49 U.S.C. §40102(a)(6), 14 CFR §1.1). . . . The FAA Office of Airports is in the process of updating the definition of âaeronautical activityâ â as it pertains to airport access â to include certain unmanned aircraft systemsâ (Price, Bonset, and FAA; 2018). However, under current Airport Improvement Program (FAA Order 5100.38) and Critical Aircraft and Regular Use Determination (FAA AC 150/5000-17), UAS facilities are not currently eligible for AIP funds. Although UAS infrastructure is not eligible, federally obligated airports must still comply with federal and state grant assurances to remain in compliance and eligible for traditional airport capital improvement funding. Airport Grant Assurances and Compliance All federally obligated airports are required under FAA Order 5190.6B to comply with standard airport sponsor assurances to remain eligible for federal funds or conveyance of federal property for airport purposes. 1 East Central CFASPP Meeting, October 22, 2018, discussion with FDOT Aviation representatives and Airport representatives from Flagler Executive, Orlando-Sanford International, Kissimmee Gateway, Orlando International, Valkaria, Ormond Beach, Deland Municipal and Melbourne International Airports.
B-12 Airports and Unmanned Aircraft Systems Airport sponsor grant assurances can be broken into two categories: general requirements for airport operations, finance and management, and requirements related to airport planning and AIP-funded projects. Since UAS activity cannot be used to support AIP-funded projects, only general airport sponsor grant requirements are currently relevant. Overall, the airport sponsor under Grant Assurance 22 must âmake reasonable and not unjustly discriminatory rules, regulations and minimum standards for the safety and efficiency of the airportâ and maintain safe operations and conditions in accordance with Grant Assurance 19. Grant assurances that relate to UAS airport integration are as follows: Grant Assurance 19, Operations and Maintenance: Some key aspects of Grant Assur- ance 19 related to UAS activity include requirements for the airport sponsor to notify pilots through the FAA NOTAM system of any closures or conditions that affect airport use. Currently, airports that provide certificates of authorization for UAS use are not required to issue NOTAMs since the COA is already identified on the airport charts. However, all other airports that allow UAS activity within the 5-mile airport radius should issue NOTAMs reflecting the location of UAS activity, day and time of operations and operating altitude and airspace envelope. An ongoing issue impacting airport operators are ârogueâ UAS operators who do not coordinate with ATC or the airport before initiating operations. Without this coordination, the airport is not able to issue a NOTAM prior to the UAS operator initiating operations. The question of whether the airport is âin complianceâ with Grant Assurance 19 in this case is yet to be addressed. Grant Assurance 22a, Economic Non-Discrimination: This grant assurance requires sponsors allow aeronautical users access to the airport on reasonable terms without unjust discrimination. Since UAS are defined by law as an aircraft, the sponsor should permit opera- tors to use the airport unless there is a reasonable justification to prohibit uses based upon safety or civilian aviation needs of the public. Sponsors may not limit or discourage UAS activity by denying use of the airport without reasonable justification, charging excessive or discriminatory fees or denying airport space without reasonable justification. Given the lack of standardized regulations and communications associated with UAS, many airport spon- sors do not support UAS activity because of safety concerns. Airport sponsors can coordinate with their local airport district and flight standards offices to determine if refusal to allow UAS activity is a violation of airport grant assurances. Grant Assurance 22h, Airport Safety and Efficiency: An airport sponsor may make rea- sonable and not unjustly discriminatory rules, regulations and minimum standards for the safety and efficiency of the airport. Sponsors must apply the rules, regulations and mini- mum standards consistently to all similarly situated aeronautical users. Therefore, UAS operations and business activity should be treated as any other similar aeronautical activity at the airport. Minimum standards and operating procedures can be implemented to sup- port safe and efficient airport activity. There is no requirement under 22h for an airport to adopt rules, regulations or minimum standards, but failure to do so could violate other assurances (i.e., Grant Assurance 5, 19 and 22). Grant Assurance 23, Exclusive Rights: A sponsor may not grant an exclusive right to pro- vide aeronautical services or conduct aeronautical activities. Sponsors must avoid imposing conditions or restrictions that grant an exclusive right to conduct any aeronautical activity. Given the mission and operating requirements of commercial UAS, development of segre- gated UAS-only infrastructure may be viable to support safe operations. This does not violate the Exclusive Rights grant assurance since development would not be limited to only one user but rather to a specific type of aeronautical activity. Grant Assurance 24, Airport Fee and Rental Structure: Airport sponsors are required to have a fee and rental system that is designed to make the airport as financially self-sufficient
General Airport Issues and Challenges with UAS B-13 as possible. However, the fee structure must be reasonable and not discriminatory. Airport sponsors can charge like fees for similarly situated users. Applicability to UAS operations depends upon whether they are based at the airport and require specific infrastructure or are transient users of the airport facilities. Rental fees may include transient or based aircraft hangar rental, building rental and user fees (e.g. waste management, electricity, and water), and apron parking fees. Sponsors can establish an agreement with users based upon cur- rent FAA Rates and Charges Policies and market information, if available. The FAA Airport District Office and state DOT aviation division personnel should be consulted regarding fair rates and charges. Note, the airport sponsor must allow federal government aircraft and thus UAS to use the airfield at no charge unless they represent a substantial use (See Grant Assurance 27). Grant Assurance 25, Airport Revenues: Sponsor must use airport revenue and aviation fuel taxes for airport capital and operating costs or other facilities directly and substantially related to the actual air transportation of passengers and property. Although UAS facilities are currently not eligible for federal capital improvement funding, the airport sponsor is not precluded from using airport revenues to support UAS infrastructure and operational activity. If the airport sponsor is complying with all other grant assurance requirements, airport revenues may be used in concert with other potential funding sources to support UAS development. Grant Assurance 27, Use by Government Aircraft: As noted in Grant Assurance 24, the airport sponsor must make available all facilities developed with Federal financial assistance as well as landing and takeoff of aircraft to be used by U.S. Governmental aircraft without charge unless use is substantial. Substantial by Government aircraft is defined, unless agreed to otherwise, to exist when Government operations would unduly interfere with the use of the airport landing areas by other authorized aircraft, or during any calendar month where: âFive (5) or more Government aircraft are regularly based at the airport or on land adjacent thereto; or b. The total number of movements (counting each landing as a movement) of Government aircraft is 300 or more, or the gross accumulative weight of Government aircraft using the airport (the total movement of Government aircraft multiplied by gross weights of such aircraft) is in excess of five million poundsâ (FAA, 2014). If the governmental aircraft activity is determined substantial, then the airport sponsor may charge the government for use of the facilities. This charge is based upon the proportionality of the facility use and is to be used for the cost of operating and maintaining the facilities used. Grant Assurance 29, Airport Layout Plan: Public airports which receive federal funding are required to keep up-to-date at all times an airport layout plan showing the following: âbound- aries of the airport and all proposed additions thereto, together with the ⢠boundaries of all offsite areas owned or controlled by the sponsor for airport purposes and proposed additions thereto; ⢠the location and nature of all existing and proposed airport facilities and structures (such as runways, taxiways, aprons, terminal buildings, hangars and roads), including all proposed extensions and reductions of existing airport facilities; ⢠the location of all existing and proposed non-aviation areas and of all existing improvements thereon; ⢠and all proposed and existing access points used to taxi aircraft across the airportâs prop- erty boundaryâ (FAA, 2014). ALPs are subject to conditional approval by the FAA, and the sponsor is required to not make or permit any changes at the airport or its facilities that are not in conformity with the approved ALP or that would âadversely affect the safety, utility or efficiency of the airportâ
B-14 Airports and Unmanned Aircraft Systems (FAA, 2014). If the changes are found to adversely impact the airport, the airport sponsor or operator must: ⢠Eliminate the adverse effect; or ⢠Bear all costs of relocating the airport facilities to a new site as well as the costs of provid- ing the facilities necessary to meet the level of safety, utility, efficiency and operations that existed before the unapproved changes were made. As this relates to UAS integration, UAS cannot as an aeronautical activity be prevented from operating at an airport if they comply with all operational and safety requirements. However, infrastructure used to support UAS operations must be approved by the FAA and state DOT, even though no funding is currently available. UAS facilities as well as proposed approach and departure procedures can be incorporated into an airportâs ALP set if the airport plans to support regular UAS operations and related activity. Thus, if an airport or associated public entity obtains either a Part 107 waiver or COA to support UAS activities at the airport, this data should be incorporated into the airportâs layout plan set to maintain conformity with airport sponsor grant assurances. Local and State Restrictions Historically, the authority to regulate aircraft and flight operations is controlled by the FAA. However, given the proliferation of UAS and concerns about privacy, law enforcement and safety, an inconsistent patchwork of local and state regulations are being created. This lack of uniformity is having a negative impact on UAS development but will also impact airport operations and development. Several airport sponsors and operators have had conflicts associated with local zoning ordinances and land uses within existing and planned approach and departure paths which have delayed or negated future airport development and capacity. Restrictions on aero- nautical activity by local and state law may also cause airports to be in direct conflict with their federally obligated grant assurances. Conflicting regulations impacts the overall safety of aircraft and airport operations. Further, according to the FAA Reauthorization Act of 2018, Section 373, the U.S. Govern- ment Accountability Office is tasked with evaluating federal control of low altitude airspace and viability of enhanced state and local control. State control of low altitude airspace would impact not only UAS operations but also low altitude manned operations (e.g. medi- vac and emergency operations, crop dusting, and aerial survey). State and local regula- tions along with proposed changes in airspace management would undermine development and implementation of uniform flight rules thus, negatively impacting the safety of airport operations. UAS Revenues and Airport Infrastructure Funding Recent legislation, combined with advice from governmental entities and drone/UAS advi- sory committees, highlights some of the potential sources for funding UAS integration and development into the NAS and airport arenas. Some funding and fee changes related to UAS provided in the 2018 FAA Reauthorization Act requires: ⢠â[The] Comptroller General of the United States to identify the appropriate fee mecha- nisms to recover the costs of âthe regulation and safety oversight of unmanned aircraft and unmanned aircraft systemsâ and âthe provision of air navigation services to unmanned aircraft and unmanned aircraft systemsâ (Rupprecht Law P.A., 2018).
General Airport Issues and Challenges with UAS B-15 ⢠FAA to update 107.205, flying a drone from moving vehicle, and 107.25, beyond line of sight, to allow for carriage of another personâs property for compensation or hire, and ⢠FAA to establish a small UAS air carrier certificate for the transportation of property for compensation or hire (Rupprecht Law P.A., 2018). Financial UAS and UAM forecasts predict a billion-dollar global industry supporting cargo, passenger, civil and military transportation needs as well as robotics and automation. A December 2017 McKinsey & Company study (Cohn, Green, Langstaff, & Roller, 2017) estimates that by 2026 âcommercial drones â both corporate and consumer applications â will have an annual impact of $31 billion to $46 billion on the countryâs Gross Domestic Product.â Since traditionally, airport infrastructure development can take up to 10 years from planning to construction, airports need to evaluate how UAS will impact business activity while identifying potential funding sources and return on investment. The advantage of an existing airport compared to other transportation systems is that most infrastructure to support UAS activity, both large and small, is already in place. There- fore, likely capital costs associated with UAS integration, depending upon the location and type of airport, could involve retrofitting or modifications of existing facilities as well as installation of additional radio communications and navigational aids. In March 2018, the final Drone Integration Funding Report was published by the RTCA (Radio Techni- cal Commission for Aeronautics) (Drone Advisory Committee, 2018). Potential funding mechanisms include user fees, public-private partnerships, and lease of airport facilities, properties and/or airspace. With the growth of UAM, airports, including general aviation airports, should also consider not only lease and user fees but also landing and parking fees as well to offset any lost ground parking revenues. Ultimately, airports should work with their local and regional FAA airport personnel to identify opportunities and documentation (i.e., market studies and benefit cost analysis) to determine potential funding sources. Regulatory EnvironmentâDomestic and International The FAAâs primary focus has and continues to be on UAS integration into the national and international airspace systems. Still, operations by larger UAS for cargo, personal travel and potential other commercial and civil activity is being tested as is beyond VLOS operations. To date, some foreign governments, including Israel, Dubai, Saudi Arabia, United Kingdom, France, Germany, as well as the Netherlands, are supporting growth and development of UAS technology. Discussions with UAS operators and manufacturers revealed that there are significant operational and regulatory differences among the United States, European Union and other ICAO member countries. Currently, UAS operators must follow at least two sets of operating rules and technical requirements if they want to operate both domestically and inter nationally. These operational and regulatory differences impact an airport sponsorâs ability to attract users and tenants from outside the United States, thus limiting revenue development. Several airports throughout the United States are equipped with a foreign trade zone (FTZ) since they may be operated by both public and private entities. An FTZ is a geographic area within or adjacent to a U.S. Port of Entry where domestic and foreign commercial merchandise receive the Customs treatment as if it were outside the commerce of the United States. Firms use FTZs to defer the payment of duties and taxes. FTZs also allow the re-export of cargo while avoiding applicable duties and taxes since merchandise never entered the U.S. consumption area (Hawaii Foreign Trade Zone, n.d.). Thus, given
B-16 Airports and Unmanned Aircraft Systems foreign investment and development of UAS and UAM technology worldwide in addition to the global nature of aviation, standardized UAS operating, manufacturing and design criteria will benefit all parties. To this end, the 2018 FAA Reauthorization Act provides the following support to UAS operators: ⢠âRequires the FAA to assist U.S. companies experiencing delays in foreign authorizations; ⢠Requires within 1-year a foreign engagement action plan; ⢠Requires FAA to coordinate with ICAO to ensure that any new international standards for aircraft tracking and flight data recovery is consistent with a performance-based approach and is implemented in a globally harmonized mannerâ (Dombroff & McKinnon, 2018). Airport Tenant Privacy Concerns In the case of Electronic Privacy Information Center (EPIC) v Federal Aviation Admin- istration (June 19, 2018), the FAA argued that privacy concerns are beyond the scope of its rulemaking authority. Since the Court dismissed the case, the FAA will stay out of regulating privacy issues associated with UAS activity leaving it to other federal agencies (FCC) and state and local governments (Makarious, 2018). Privacy continues to be an issue not only for the public but also for on-airport tenants. Airport tenants have raised concerns regarding on-airport UAS activity and intellectual prop- erty, operations as well as client and personnel privacy issues. For instance, Piper aircraft has requested that the City of Vero Beach and airport management not allow UAS activity near their manufacturing site located adjacent to airport property. Tenant concerns about privacy are not new. One method to address these concerns is to develop âno UAS fly zonesâ to eliminate operations over highly sensitive airport and tenant facilities. Under the 2018 Reauthorization Act, the Federal Trade Commission has the authority to pursue violations of privacy policies involving a UAS as an unfair trade practice. Thus, as part of the airportâs minimum operating procedures and tenant lease agreements, restric- tions may be put into place to limit overflight and recording of tenant facilities without prior permission. Also, concerns may be mitigated through stakeholder outreach and education seminars on UAS for airport tenants. UAS Rogue Operators An ongoing issue plaguing the FAA and airport operators is ârogue operators.â âThe question of how to deal with rogue operators remains unsettled but is perhaps one of the most vexing problems facing the industryâ (Turner, 2016). Rogue operations include a substantial number of commercial flights conducted without FAA authorization in addition to recreational users not following the rules regarding where they can or cannot fly. As discussed in Counter- UAS Tech- nology and Airport Infrastructure, rogue UAS operators can and have caused substantial delays and safety hazards at major metropolitan airports such as Gatwick International, Charles De Gaulle, Ronald Reagan, Miami International as well as at other airports and critical infra- structure (e.g. nuclear powerplants and dams). Although the FAA does not currently support counter-UAS technology either for UAS identification or UAS capture or destruction, there are several businesses working with the DOD and other organizations (e.g. powerplants, electrical grids, and state and federal prisons) to implement counter-UAS technology. A sampling of busi- nesses providing these services include:
General Airport Issues and Challenges with UAS B-17 ⢠SRC, Inc (www.srcinc.com) ⢠SENSOFUSION (www.sensofusion.com) ⢠DCAA (Dubai Civil Aviation Authority) & Sanad Academy (www.dcaa.gov.ae, www. sanadacademy.ae) ⢠ANTIDRONE (www.anti-drone.eu) ⢠Battelle (www.battelle.com) ⢠Blighter Surveillance Systems (Carlini, 2017) Unregulated UAS threaten not only air transportation operations and safety but have a negative impact on commerce and national security. Over 30 anti-drone companies world- wide are already in business to deal with these threats. During ongoing discussions with airport operators, recurring scenarios associated with unauthorized UAS activity within controlled airspace highlighted several operational issues: ⢠Airport tenants flying their UAS next to an active runway or taxiway without permission. ⢠Commercial operators not contacting the sponsor or ATC to get permission to enter airport airspace. ⢠Operators asserting they obtained permission to operate on the airport, but did not or were refused due to safety concerns. ⢠UAS operators acting with disdain or aggressively with Airport and Air Traffic Personnel when requesting permission to operate within the airport airspace. Most of these operators do not intend to jeopardize public safety but are merely trying to âshortcutâ the regulatory process. Still the risks posed by these operators can be signifi- cant. First is the potential to cause injury to people on the ground or in the air. Since most UAS are less than 55 lbs. and are small, they are hard to see in the air. Further manned air- craft operators during approach and departure procedures are focused on adjusting aircraft speed and trim as they transition to and from the ground to airspace rather than looking out for UAs. Because of these concerns, the FAA Reauthorization Act of 2018 now includes the following penalties: ⢠Intentional interference with a manned aircraft or airport is a felony with 1 year in prison, ⢠Causing injury is 10 years in prison, and ⢠In furtherance of another crime is life in prison. Further, if the incident occurs within the airport airspace or property, the sponsor may be found liable for not providing a safe and secure environment. Thus, making the sponsor a possible party to a potential lawsuit and impacting compliance with federal grant assurances and associated funding. Another indirect impact of rogue operations is the risk that state and local regulators will take actions that may negatively impact activity by rogue operators but also by âlaw-abidingâ commercial and recreational users as well. Although airports and airspace both are under federal jurisdiction, local and state regulatory actions that limit UAS activity may have a negative impact on airport operations and revenue development. Further, given Section 373 of the Reauthorization Act of 2018 suggesting the possibility of shifting low altitude airspace from the federal jurisdiction to state and local jurisdiction, this may raise a variety of issues including: non-standard procedures, differing operational requirements, and communication and coordination issues.
B-18 Airports and Unmanned Aircraft Systems Summary The increase in the number and type of UAS operations within the airport setting will pro- vide airports several revenue enhancement and operational opportunities, but stakeholders must also consider the challenges of integrating this new aeronautical activity. Given forecast demand, integrating UAS into routine airport operations will impact all airport stakeholders by affecting airport capacity. Airports could attempt to segregate operations, but given lack of funding and compliance requirements, construction of separate and potentially redundant UAS-specific facilities is unlikely. Thus, given the various uncertainties and challenges facing integration of UAS operations at an airport, it is suggested that the airport sponsor consider only one type of UAS use or business case initially to evaluate quantifiable costs, revenues, potential regulatory barriers, liability, community acceptance and other impacts. Sponsor actions can include to: ⢠Determine if proposed operations can be performed under existing FAR Part 107 or if addi- tional waivers may be required; ⢠Evaluate whether the airport has the facilities, capacity, services and insurance to support planned UAS operations while maintaining the overall safety of airport operations; ⢠Determine if the UAS operator mission is authorized and approved by FAA, and that the operator can perform planned operations safely both on and beyond the airport airspace; ⢠Assess whether tenants, users and other airport stakeholders will object to proposed UAS operations, and whether those concerns can be mitigated; and ⢠Assess whether the community has issues with proposed operations, and how these concerns can be addressed or mitigated (Matthews, Frisbie, and Cistone; 2017).
