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Airports and Unmanned Aircraft Systems, Volume 3: Potential Use of UAS by Airport Operators (2019)

Chapter: 3 Integrating UAS Related Risk into an SMS Plan

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Suggested Citation:"3 Integrating UAS Related Risk into an SMS Plan." National Academies of Sciences, Engineering, and Medicine. 2019. Airports and Unmanned Aircraft Systems, Volume 3: Potential Use of UAS by Airport Operators. Washington, DC: The National Academies Press. doi: 10.17226/25607.
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Suggested Citation:"3 Integrating UAS Related Risk into an SMS Plan." National Academies of Sciences, Engineering, and Medicine. 2019. Airports and Unmanned Aircraft Systems, Volume 3: Potential Use of UAS by Airport Operators. Washington, DC: The National Academies Press. doi: 10.17226/25607.
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Suggested Citation:"3 Integrating UAS Related Risk into an SMS Plan." National Academies of Sciences, Engineering, and Medicine. 2019. Airports and Unmanned Aircraft Systems, Volume 3: Potential Use of UAS by Airport Operators. Washington, DC: The National Academies Press. doi: 10.17226/25607.
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Suggested Citation:"3 Integrating UAS Related Risk into an SMS Plan." National Academies of Sciences, Engineering, and Medicine. 2019. Airports and Unmanned Aircraft Systems, Volume 3: Potential Use of UAS by Airport Operators. Washington, DC: The National Academies Press. doi: 10.17226/25607.
×
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Suggested Citation:"3 Integrating UAS Related Risk into an SMS Plan." National Academies of Sciences, Engineering, and Medicine. 2019. Airports and Unmanned Aircraft Systems, Volume 3: Potential Use of UAS by Airport Operators. Washington, DC: The National Academies Press. doi: 10.17226/25607.
×
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Suggested Citation:"3 Integrating UAS Related Risk into an SMS Plan." National Academies of Sciences, Engineering, and Medicine. 2019. Airports and Unmanned Aircraft Systems, Volume 3: Potential Use of UAS by Airport Operators. Washington, DC: The National Academies Press. doi: 10.17226/25607.
×
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Suggested Citation:"3 Integrating UAS Related Risk into an SMS Plan." National Academies of Sciences, Engineering, and Medicine. 2019. Airports and Unmanned Aircraft Systems, Volume 3: Potential Use of UAS by Airport Operators. Washington, DC: The National Academies Press. doi: 10.17226/25607.
×
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Suggested Citation:"3 Integrating UAS Related Risk into an SMS Plan." National Academies of Sciences, Engineering, and Medicine. 2019. Airports and Unmanned Aircraft Systems, Volume 3: Potential Use of UAS by Airport Operators. Washington, DC: The National Academies Press. doi: 10.17226/25607.
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Page 19

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Potential Use of UAS by Airport Operators   11 in more detail in a companion handbook: “Incorporating UAS into Airport Infrastructure – Planning Guidebook. 2.6 Airports Using UAS: Nationally, several airports have taken an active role in addressing the emergence of UAS, providing guidance to UAS operators, and pioneering new uses and techniques for integration with manned operations. In particular, Golden Triangle Regional Airport (GTR) and Ventura County Airports, and Dallas Fort Worth Airport (DFW) have developed procedures supporting the expansion of safe UAS operations. As guidance continues to be developed by the FAA, airports will continue to play an important leadership role in establishing best practices and will serve as examples for new regulations. For example, the FAA has determined that airports completing independent safety risk assessments and safety risk management plans will not be required to participate in the Low Altitude Authorization and Notification (LAANC) systems. Golden Triangle Regional Airport has developed its own safety risk management plan. As part of this plan, UAS operators and ATC coordinate over the radio and via ground communications. This is in spite of the fact that the FAA has not recommended that UAS pilots use the same frequency/spectrum as ATC. GTR’s procedures allow ATC personnel and manned aircraft users to be aware of UAS operating in the vicinity and allows the UAS user to apply the traditional “see and avoid” procedures for collision avoidance. As a result of enhanced overall safety and greater flexibility in handling manned and unmanned operations, the airport continues to attract both manned and unmanned businesses. In January 2019 Golden Triangle Regional Airport, organized a seminar, bringing together UAS operators from Columbus Air Force Base, Mississippi State University, and industry to focus on the regulation and use of UAS as they continue to coordinate efforts bring attention to the rapidly occurring changes in the industry. (Golden Triangle Regional Airport, 2019) DFW’s support of innovative uses of UAS will also be an example for other airports to follow. In March 2018, first responders received permission from the FAA to operate UAS over the airfield at DFW to benefit public safety. (Robertson, 2018) Additional testing has been pioneered at DFW including FAA UAS detection systems. (Federal Aviation Administration, 2017) Ventura County Airports also provides an example of how to communicate with the airport community. The detailed guidance on their website provided for recreational and commercial UAS operators allows for safer flights near the airport. There are links to FAA guidance, custom “No Drone” zone maps for Ventura County airspace, and a one-page flyer that includes a list of relevant airport contacts. (County of Ventura, 2019) The tools used by Ventura county can be particularly useful for airports planning on increased UAS activity. 3 Integrating UAS Related Risk into an SMS Plan In order to deal with the impacts of UAS operations in airports described in Sections 2.5.1, 2.5.2, and 2.5.3, airport operators should consider the inclusion of UAS in their SMS plans. An SMS plan is a system established within an organization to address safety risks to people, property, and business needs through the declaration of an organizational safety policy, promotion of an overall culture of safety within the organization, safety risk management (SRM) to address and mitigate potential safety hazards, and a safety assurance policy to ensure long-term safety is maintained as it evolves. An SMS document captures this system so that it can be disseminated to the appropriate stakeholders, defines clear instructions on the system and its execution, and can be shared with

Potential Use of UAS by Airport Operators   12 others as part of certification, operational approval, or demonstrating to others the organization’s safety protections. When an airport becomes a UAS operator, the incorporation of UAS operations into the SMS represents a best practice to be adopted. Depending on airport size the parties responsible for incorporating UAS related risk into the SMS plan will change. This may mean that the airport director is responsible for this at smaller airports while the safety division or operations division may be responsible at larger airports. In some instances, airports may even have a dedicated UAS or emerging technology division that should be responsible for UAS integration. Like a traditional airport SMS, which focuses upon the airport’s routine operations, potential safety hazards of those operations, and the mitigation strategies, an SMS incorporating UAS operations serves a similar role regarding the enterprise of the airport’s UAS operation. This includes the identification of safety hazards relevant to the airport’s environment, the intended operations, technologies to be used, and mitigation strategies for each. It should also define the mechanisms and tools for a safety review board to evaluate proposed operations to determine that the operation does not present additional hazards, and when additional hazards are identified, they are appropriately mitigated to the satisfaction of a safety review board. 3.1 Components of a UAS SMS A UAS SMS plan requires an airport to conduct an analysis of UAS operations in the context of the following areas.  Safety Policy and Objectives: This section outlines the responsibilities for the implementation of the SMS. This includes an individual with overall managerial responsibility as well as potential advisory groups such as an initial review committee, safety review board, and UAS-specific oversight committees. This section should also refer to emergency response plans as well as identify operational safety factors to be considered during a UAS operation. This includes safety equipment to be used, hazard zones, local UAS operational requirements, as well as FAA requirements to operate UAS (e.g. Certificates of Waiver or Authorization that need to be filed).  Safety Risk Management: This section should report the process by which risks are identified, analyzed, and mitigated due to UAS operations. Section 3.2 covers the specifics of how to identify and analyze risk specific to UAS operations.  Safety Assurance: The safety assurance aspect of an SMS plan covers the audit and measurement methods used to monitor the quality of an SMS plan. It covers monitoring and reporting procedures and outlines the risk auditing duties of the responsible parties identified in the Safety Policy and Objectives section.  Safety Promotion: A final component of the SMS plan includes an educational factor that outlines communication methods to promote safety. UAS-specific courses can be identified here. An example of this plan used at Embry-Riddle Aeronautical University and Daytona Beach Airport can be found in Appendix 6.2. 3.2 Understanding and Assessing Risk of UAS Operations at Airports UAS present unique challenges for airport operators to uphold the no-risk approach of manned operations (National Academies of Sciences, 2018). This section will provide guidance on how

Potential Use of UAS by Airport Operators   13 airport operators can identify the risk presented by UAS operations, how they can evaluate this risk, and how to help mitigate this risk to an acceptable level. 3.2.1 Identifying Sources of Risk Due to UAS Operations 3.2.1.1 Identification Airports should create a process to help them identify which risks are associated with any UAS operation. The procedures and technologies presented by UAS operations have new risk associated with them. However, airports can also utilize past incident or accident reports to help them adapt to and identify these future risks. Additionally, airports can form a risk assessment team to help track, identify, and prevent risks associated with UAS operations as well as procedures to implement when an incident happens. Some risks include:  Collision Risk: Both commercial and general aviation operators will likely not have the primary surveillance equipment to identify sUAS in their vicinity (regardless of whether the sUAS has a detect and avoid system onboard). (Matthews, Frisbie, & Cistone, 2017)  Airspace Congestion: Additional aircraft, such as UAS, will add to the air traffic control demands of an airport. (Matthews, Frisbie, & Cistone, 2017)  Vehicle Hazards: UAS vehicles could malfunction in a multitude of ways including loss of control, lost link/communication, and failed landings/takeoff (Barr, et al., 2017). These malfunction factors could result in many impacts ranging from property damage to harms to individuals. 3.2.2 Evaluating Risk due to UAS Operations Once risks are identified, airports need to identify appropriate metrics for risk evaluation. While airports can choose from many different metrics published by the FAA, Embry Riddle Aeronautical University, and others, but it is helpful for airports to ensure that a standardized method is in place and routinely used. Standardization helps the airport understand the risk and prevent ad hoc or subjective risk evaluation scenarios. A risk evaluation, based on Embry Riddle Aeronautical University’s UAS SMS Manual, is provided below as an example of how to analyze risk and use a risk matrix (Table 3) for categorization:  Evaluate likelihood of an incident occurring and the resulting severity of that incident  Identify hazards that contribute to the risk and their associated consequences of each hazard.  Determine the Risk Assessment Code based upon likelihood and severity of identified hazards  Determine if assessed risk is suitable for approval  If not suitable, further assess hazard and implement control measure(s) to mitigate hazard  Determine the Risk Assessment Code following implementation of control measure(s)  Indicate the final code for the (now acceptable risk)

Potential Use of UAS by Airport Operators   14 Table 3: Example of a risk matrix Required Definitions: LIKELIHOOD Frequent: Likely to occur many times; Will be continuously experienced unless action is taken to change events. Likely: The activity or event is expected to occur 50-90% of the time; Will occur often if events follow a normal process or procedure and is repeatable. Occasional: infrequent or irregularly, or 25-49% of the time. Events are sporadic in nature. Seldom: Occur intermittently, or 1-25% of the time; Not likely to happen. Improbable: being almost inconceivable that the event will occur. Less than 1% chance of occurrence. SEVERITY Table 4 below breaks down Severity in 5 distinct categories: Catastrophic, Critical, Moderate, Minor, and Negligible. Table 4: Description of severity categories Severity Description Catastrophic  Equipment destroyed  Multiple deaths  System wide shut-down and negative revenue impact  Large environmental impact  Loss (or breakdown) of an entire system or sub-system  Security criminal investigations and penalties to groups or individuals  Willful violation of any safety regulation that could result in serious injury or death  Potential of suspending flight operations  Potential for uncontrollable public relations event(s) Risk Likelihood Risk Severity Catastrophic A Critical B Moderate C Minor D Negligible E 5 – Frequent 5A 5B 5C 5D 5E 4 – Likely 4A 4B 4C 4D 4E 3 – Occasional 3A 3B 3C 3D 3E 2 – Seldom 2A 2B 2C 2D 2E 1 – Improbable 1A 1B 1C 1D 1E

Potential Use of UAS by Airport Operators   15 Severity Description Critical  A large reduction in safety margins, physical distress and/or workload such that operators cannot be relied upon to perform their tasks accurately or completely  Serious injury or death, multiple long-term injuries and personal claims  Accident or Serious incident with injuries and/or major to moderate equipment damage  Potential criminal penalty  Medium environmental impact  Potential moderate damage to an aircraft (out of service >5 days)  A non-compliance finding that results in major systems, process or operational degradation  A security finding requiring immediate corrective action prior to continued operation  Reoccurring violation of any safety regulation resulting in serious injury  An employee/customer injury/broken bone. Injury resulting in hospitalization (other than observation)  Moderate Enterprise risk involving executive management involvement  Very large public relations impact requiring resources to manage information  System deficiencies leading to poor flight line performance and chronic disruption to the flight activity schedules  Potential loss (breakdown) of entire sub-system or divisional operation  Production errors containing regulatory violations that pose direct consequence to the operation Moderate  Accident or incident with minor injury and/or minor aircraft damage  Non-life-threatening employee/customer injury, with recording of Lost Time Injury  Small environmental impact  Security finding requiring a corrective action plan  Production element errors that may pose indirect consequences to the operation  Aircraft damage resulting in out of service < 5 days  Potential to cause sustained irregular operations until issue is resolved  Additional public relations efforts and resources required Minor  No regulatory action  No environmental impact anticipated  No evident security threat affected  Minor errors in completed university policy and procedures  Production errors containing quality system and/or opportunities for improvement  No equipment damage to slight damage – outcome deferrable with no operational impact

Potential Use of UAS by Airport Operators   16 Severity Description  $0 Regulatory fines  No public relations impact Negligible  No regulatory violation  No environmental impact  No security element affected  Initiative delivered against University policy and procedures  No public relations impact  No aircraft damage – no operational impact  Finding element present limited opportunities for improvement 3.2.3 Assessment of Risk Once risks are identified and evaluated, airports will need to develop how to assess risk associated with UAS integration. Figure 2 is provided as an example to help complete this assessment and risk analysis. The figure below prompts the airport user to consider the impacts (Reason for Risk Assessment), identified risks, and the initial assessment of the risk based on its likelihood and severity. The airport can then use the identified risk to inform their decision and acceptance level of the potential consequences. Additionally, airports should consider any risk controls that they have in place. Risk controls will be explained in more detail in the next section. Periodic review and use of this document will help airport iterate their risk assessment and control procedures to ensure that all risks are being captured and controlled as best possible. It is recommended airports perform another iteration of their risk assessment analysis after a major change such as number or type of operations on the airport, changes in airport design or procedures, or integration of a new technology. The ultimate purpose of this method is to provide a structure for airports to be able to transparently report and address risks. This can then be applied to UAS integration as appropriate. INITIAL OPERATIONS RISK ASSESSMENT DOCUMENTATION  Risk Assessment For: Organization & Location  Today’s Date: Click for date  Reason for Risk Assessment (select all that apply):  ☐New System Design  ☐Modification to an Existing Operation or  Procedure  ☐ Change to Existing System Design  ☐Operational Environmental Change  ☐New Operational Procedure  ☐Ineffective Risk Control  ☐Other:   PROCESS/SYSTEM ANALYSIS 

Potential Use of UAS by Airport Operators   17 Figure 2: Risk assessment documentation 3.3 Mitigating Risk Due to UAS Operations 3.3.1.1 Risk Control Risk controls involve selecting and implementing one or more control methods for mitigating risks. Selecting the most appropriate risk treatment option involves balancing the costs and efforts of implementation against the benefits derived, with regard to legal, regulatory, and other requirements such as social responsibility and the protection of the natural environment. Risk control measures such as NOTAMs and new procedures can also introduce secondary risks that need to be assessed, treated, monitored and reviewed. Some examples of secondary risks associated with mitigation are included below: Brief description of process of system to be assessed:    RISK ANALYSIS / HAZARD IDENTIFICATION    HAZARD  POTENTIAL CONSEQUENCE(S)  H1      H2      H3      H4      H5      (INITIAL) RISK ASSESSMENT  Initial Risk Assessment Code:      ‐Select‐          ‐Select‐  PROPOSED RISK CONTROL(S)  H1    H2    H3    H4    H5    (FINAL) RISK ASSESSMENT  Final Risk Assessment Code:       ‐Select‐          ‐Select‐  Risk Likelihood  Risk Severity Catastrophic (A)  Critical (B)  Moderate (C)  Minor (D)  Negligible (E)  5 – Frequent  5A  5B  5C  5D  5E  4 – Likely  4A  4B  4C  4D  4E  3 – Occasional  3A  3B  3C  3D  3E  2 – Seldom  2A  2B  2C  2D  2E  1 – Improbable  1A  1B  1C  1D  1E   

Potential Use of UAS by Airport Operators   18  Information Overload: As airports strive to make their tenants and traffic aware of any UAS operations they will publish NOTAMS, broadcast on their ATIS, and other forms of notices. However, this additional load of information is susceptible to being buried or lost within the already large amount of information pilots and operators digest prior to any mission.  New Procedures/ Complex Procedures: To help integrate UAS into normal airport operations new procedures will be introduced to help avoid conflict. However, these procedures will need to be carefully thought through and studied to ensure they are not adding a layer of complexity to an already dynamic airport environment. As well, these procedures will take time to integrate and the risk of incident/accident is greatest as they’re first introduced.  Improper/Lack of Communication: Alongside the addition of new procedures will be the communication necessary for these missions. While the communication protocol for these missions should be iterated upon and agreed upon by any parties involved there is still room for error. These secondary risks will be incorporated into the same treatment plan as the original risk and not treated as a new risk. Mitigation options are discussed in the next section. 3.3.1.2 Mitigation Airports can take several actions to help mitigate risk and safely integrate UAS operations. Some recommended actions include:  Continuing to collect empirical data to categorize and evaluate the risk associated with UAS.  Assess whether the level of acceptance and authorization of any operation is equal to or greater to the level of risk presented by the operation.  Develop training for integration of expected UAS operations. Make the training recurring and based on past performances and lessons learned.  Institute mandatory incident/accident reporting. Capture all UAS related incidents.  Perform routine safety reviews in the context of the existing SMS.  

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Airports and Unmanned Aircraft Systems, Volume 3: Potential Use of UAS by Airport Operators Get This Book
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Introduction of unmanned aircraft systems (UAS) will pose safety, economic, operational, regulatory, community, environmental, and infrastructure challenges to airports. These risks are further complicated by the dynamic nature of UAS technological development. Experiences and lessons learned from recent major aviation system changes demonstrate the critical importance of ensuring that airports have the resources needed to avoid adverse impacts and maximize benefits as early as possible.

This pre-publication draft of ACRP (Airport Cooperative Research Program) Research Report 212: Airports and Unmanned Aircraft Systems, Volume 3: Potential Use of UAS by Airport Operators provides airports with resources to appropriately integrate UAS missions as part of their standard operations. The use of UAS by airports can result in efficiency gains if implemented effectively. However, improper implementation will cause safety risks and damage effective airport operations.

Other Resources:

Volume 1: Managing and Engaging Stakeholders on UAS in the Vicinity of Airports provides guidance for airport operators and managers to interact with UAS operations in the vicinity of airports.

Volume 2: Incorporating UAS into Airport Infrastructure—Planning Guidebook provides planning, operational, and infrastructure guidance to safely integrate existing and anticipated UAS operations into an airport environment.

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