Current Landscape of Unmanned Aircraft Systems at Airports (2019)

Below is the uncorrected machine-read text of this chapter, intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text of each book. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

78 Actual Survey Comments A P P E N D I X A What challenges has your airport experienced in either operating UAS/drones or accommodating the use of UAS/drones by contractors, tenants, and/or media? • Air space is controlled within 5 miles of airport from 200ʹ to the ground, so pilots must call ________ Center for clearance. • So far the Airport has not experienced challenges and most everyone is respectful of the areas surrounding the Airport. • Couple of instances where operators were not authorized and operating on the approach. • Our airport has not operated UAs nor have we been asked to accommodate the use of UAs. • Restriction by the FAA—would like to use UAs for wildlife control but FAA is taking a long time to approve. • Identifying operators who fly near the approach. • Time involved in vetting UAS use near the airport and getting operators to provide accurate info on approved flights. • Verifying certification of pilots and COAs. • Lack of understanding of airspace regulations by UA operators.

Actual Survey Comments 79 • None—the ND Air National Guard operation has had no impact to operations. • No challenges yet. We have only had one contractor use UA. All regulations were followed and cleared by the FAA. • Significant time was spent on coordination with ATC. • Lack of education on the matter for both UAS operators and airport admin/ATC/general public. • Airport with contract tower sees over 100,000 ops annually. Is not given access to LAANC. • How to handle UA that enters the airspace. • The MQ-9 operations have integrated easily with existing civilian aircraft operations. • Little to no challenges experienced other than creating a way to notify us when the UA operator requests [access] into our airspace—call ATCT. • None, because to date, no UAs have been operated from the airport. • None, as UA operations are not permitted at our airport. • None operated on the Airport. Notification from UA users in the vicinity has been good, but hard to determine if all UA users are actually notifying the Airport. • Operators who are unfamiliar with the regulatory requirements. • Operating UAs without notifying airport manager or requesting approval. • The increasing number of requests are seen a challenge. • Use of radio. • None. Our local UAS operators have been very cooperative with airport management in coordinating UAS operations.

80 Current Landscape of Unmanned Aircraft Systems at Airports • Authorization restrictions listed in the terms by FAA. • Operational impacts while operating UAS. • As a small airport, we have plenty of time between operations to conduct UAS activity. One of the challenges was to have the manufacturer unlock the UA for use around the airport. • The requirements/expectation of non-towered, GA airports is very vague and operations are nearly impossible to monitor. • We are very close to final FAA approval, but the government shutdown has put the process on hold for now. At this point, we’ve only used our UAS indoors at the airport. • We are in Class D airspace and our FAA tower personnel are not able to authorize UAV activity. The types of activity we wish to conduct—monitor, survey, PR, flight test, etc.— are not conducive to either the LAANC system or to COA/exemption procedures and are certainly not timely enough. • After explaining the process, we haven't had anyone willing to go through it. • Developing policies that protect the airport/airspace/tenants while remaining compliant with federal and state regulations. Also, getting internal buy-in for the use of UAS on and around the airport. • Safety, communications, equipment limitations, development of policies and procedures to operate the UA on the airport, approval process cumbersome. • Minimal challenges. We are a fairly small community with an uncontrolled airport. We have a handful of commercial operators in the area (photography, videography). We have a good working relationship with them as far as educating each other and

Actual Survey Comments 81 organizing times and locations for safe flights. None have operated on airport property as of yet. • Our airport is very congested airspace with lots of flight training activities. • Operational opportunities reference scheduled and non-scheduled flight activity. • Making sure the operator has the proper authorization to operate UA at the airport. • The FAA seems to be years behind the curve in guidance for integration into GA operations. • No challenges. We used it for sighting purposes in the design of our new ATCT. • UA operators calling for permission and having to refer them back to the FAA. • At this time, we have not had any challenges. Most of our local operators comply with existing regulations. • Coordination with the UAS operator and ATCT. • Understanding the UAS regulations pertaining to UAS operations within the Class D Airspace. • UAs use is prohibited. • Dissemination of FAA UA regulations and permitting procedures. • Requests from Part 107 operators who expect the airport to intervene on their behalf with the FAA, to grant approval for UA flights in controlled airspace. • The biggest challenge we see is ensuring people call the airport prior to operating near the airport. Our facility is located at the center of town, and we receive regular reports from pilots seeing UAS operating near the facility.

82 Current Landscape of Unmanned Aircraft Systems at Airports • To date, UAS vehicles have not been used in the immediate vicinity of the airport. UA have been used by academic entities and contractors within the required notification radius. • The Airport’s biggest challenge is being notified about these operations happening within our airspace so we can in turn issue NOTAMs to alert the pilots. • Primarily just learning what the airport’s role is and how best to ensure UAS operators are contacting the Tower and providing the proper information. • ATCT. • Need more education for the public concerning regs. • We have a large military presence (Air National Guard) at the airport and do not allow UA within a 5-mile radius. • The vast majority of contractors do not know how to professionally accomplish aviation operations, particularly in the areas around airports. In addition, their situational awareness within the airport vicinity tends to be poor. • UAS users are required to contact the airport; however, at a non-towered airport we have no jurisdiction to ensure safety or approve or deny. • Extended length of time it takes to get FAA approval. • Staffing airport personnel 7 days a week to handle UAS requests for use. Airport does not have staffing to provide services 7 days a week, which leaves UAS operators complaining. • As a UAS test range, we have a special operations manual for users to abide by. All overseen be highly experienced UAS range staff.

Actual Survey Comments 83 • Training and collaboration for flights. • Public not aware of regulatory restrictions. To what degree are you able to use UAS/drones on [the] airport within the context of current FAA regulations? • Easily, with prior coordination and FAA approval. • This would have to be researched. • Fairly easily. • ATCT approval required. • At this time, we cannot, but have file with FAA to allow for wildlife use. • Don’t have a valid need to use UAS on airport so have not researched FAA regs on use. • Very limited to perimeter checks away from runways. • We would work with the FAA if we wanted to use the technology on our airport. • As far as I know, however, we need to as long as regulations are met. • Few restrictions; weather is a bigger problem than traffic or operations. • [Part] 107 is still evolving but reasonable at this stage. Compliance and integration need the use of common sense. • Given the limited size of our airfield; and as a busy, single runway facility, we feel the use of UAS could potentially, and adversely, impact the safe and efficient flow of air traffic. • We were able to complete the required survey under the existing Part 107 regulations.

84 Current Landscape of Unmanned Aircraft Systems at Airports • We operate two airports. One is non-towered. The other is busy Class D under Class B airspace. Own and operate my own UAS and hold remote pilot certificate. Have not operated on either airport. No COA or other authorization. • To no degree, as our rules and regulations prohibit the use of UA. • We are not currently looking to use UA. When outside parties ask, they are directed to ATC. • We rely upon the airman. • UAS are considered an aeronautical activity. UAS operations are authorized when coordinating with the controlling body of the airport. • Within the bounds of our Class Delta authorization and daylight waiver. • Somewhat frequent, dependent on the requested location and operation. • Unlimited. However, we do not currently allow UA use or use our own within the airfield. It is only used outside the perimeter and below all Part 77 surfaces. • Unknown; rely on an on-call engineering firm to adhere to regulations. • We are very close to final FAA approval, but the government shutdown has put the process on hold for now. At this point, we've only used our UAS indoors at the airport. • Only in outlying areas. • One of the airports within our system plans to use UAS for required roof inspections. • It's been a challenge. For on-airport use, we have yet to negotiate approval with FAA. • Used UA on a limited basis under current regulations. • It would not be feasible since the operator would need a commercial UAS operator permit, permits take months if authorized, not to mention the airspace issues.

Actual Survey Comments 85 • Not sure what the FAA will allow. • We utilized NOTAMs and limited the operation well away from traffic patterns and maintained operation height well below 50ʹ. • Very limited opportunity, if any, at the present standards set forth (for good reason). • Very limited degree. • We do not use UA on airport property. The one time we did was to sight the new tower. We worked with FAA for the approval and coordination. • Contractor has to secure all approvals, certifications, and permits. • Notification to airport authority and ATC. • Currently, we are not allowed to operate UA in Class D airspace without having an LOA and a signed waiver from the ATCT. • The UA can be utilized for non-commercial purposes with the approval of the airport. If utilized for commercial purposes (government) we must receive approval from the FAA. • We have been an FAA UAS designated test site since December 2013 and facilitated numerous UAS flights at our GA Airport. We have not had any UAS flights at our Part 139 Airport yet, but was one of the pilot airports for the LAANC program and our ATCT has approved hundreds of UAS flights in proximity to the Airport. We are very familiar with the regulations and have a cooperative ATCT to support UAS activity, but we just haven’t had the need to warrant the use of UAS on airport. • To be honest, I have not kept up with the ever-changing regulations concerning UAS. For use at the Airport, I would contact someone who is FAR107 certified to assist with

86 Current Landscape of Unmanned Aircraft Systems at Airports following the appropriate procedures to have the operation cleared, notify the ATCT and issue the relevant NOTAM(s) beforehand. • Although no UA use has occurred, I am a UA pilot (commercial/government) and fully able to operate in those capacities as needed to support aerial investigation/survey work. • We would ensure any staff go through a certified UAS training program prior to being authorized to use an airport-issued UAS. • Don’t know. We would just coordinate with our ATCT. • Our airport is a Lead Applicant in the FAA’s UAS Integration Pilot Program (UAS IPP). As part of the program, our use cases are to perform perimeter fence inspections and aircraft inspections. Presently we are planning to perform these operations under Part 107. We are working directly with the FAA UAS IPP team to determine if future COA’s will be required. • Due to military presence we would not likely be able to use UA for airport operations. • The FAA regs do require a formal waiver/COA process for certain airspace and environments. However, most of what we want to do can be done if we decide that the effort is worth the reward. • While we haven't had any need to operate them, we expect that any efforts to operate UAS/UA would be possible with close coordination with FAA ATC. • Approval using LAANC system within 24 hours. Coordinate with ARTCC for use in Terminal Airspace. Use for emergency police/fire purposes (special events or responding to emergency situation).

Actual Survey Comments 87 • Our staff are experts on the rules and oversaw over 2,500 UAS operations conducted in 2018. Many UAS aircraft from a couple of pounds to well over 1,000 lb. • We can utilize then in non-controlled airspace under Part 107 rules and also by utilizing waivers in controlled airspace. • We are in contact with FAA and have a state law that permits UA usage, so long as it is not within certain areas near the ends of runways. What advice would you have for other airports intending to safely operate UAS/drones on airports (or allow their operation by tenants/contractors)? • Develop a plan with proximity parameters for UA operations, and procedures for quick discontinuation of operations. • Work with your local FAA. • Check with the FAA on the rules. • Be patient. • Establish a line of communication with ATCT and UA operators. • Communicate—get all stakeholders together to review the technology. • Train and coordinate key personnel. • Although a UAS pilot may have passed their 107 cert., if they are not experienced operating “on” an airport as a “full size” aircraft pilot, many 107 pilots do not have sufficient situational awareness about what the full-size aircraft are doing, where they are, and how to integrate smoothly. “Off” airport UAS below 400 AGL do not have the “same” level of interaction challenges as an UAS operation “on” or close to an airport.

88 Current Landscape of Unmanned Aircraft Systems at Airports Not all 107 pilots are created equal, especially near or at an airport. Care and experience are needed. Airport operators need to be careful if there is any concern that the UAS operator has limited airport experience. • Communication with all stakeholders is key. If ATC receives a LAANC request for operations on the airfield without prior notification, they may simply deny the request, leading to delays. • Know the rules, know your role. • I’ve been working in Airport Management for 15 years, a pilot for 20 years. I was an early adopter of sUAS technology and embraced it. I’ve spoken to many in the Airport industry on both sides of the fence, and some who are still sitting on it. I say to those who take an aggressive “no UA” stance that an approach of education and teaching owners and operators of the technology how to use it safety will always be a better approach. • Research airports that allow this activity to measure impacts and to learn safety protocols. • Know and follow the federal regulations. • Document all activity. • Clear communication and understanding of FAA regulations. • Keep in mind, the airport controls the surface on the airport, while FAA controls airspace. If the airport wants to use UAS they are no longer the controlling agency, they are a user.

Actual Survey Comments 89 • Do not be closed-minded to UAS. Do some research, get to know your local UAS operators, and understand that they are almost more strict in their operations than airport operators are. • Participate in education for the community in terms of sUAS regulations. Start a documented sUAS program with clear outlines and SOPs for utilization on the field. Have a dedicated person to lead this initiative. • Establish a UAS working group, and engaging local air traffic—pointing out the benefits. • Coordinate with other entities such as a fire department. Most fire departments are going to UAs for search and rescue as well as situational awareness. They can be a great resource for training and equipment familiarization. They may have other advice and for us, we were able to stipulate clearly what their limits were related to the airport. I'm sure this would apply to nearby universities, law enforcement, border patrol, and similar organizations. • Sub it out and let the contractor take on the liability, unless you have the resources to dedicate the staff, time, and funding to micromanage a program. • Have a prior good working relationship with local FAA ATC. • Work with local FSDO and FAA officials. Stay current on the regulations. Obtain the Part 107 certificate to become familiar with UAS regulations. • I need advice. • Know the rules. Know the approved airspace. Know where not to fly. • I’m told the FAA has a major backlog of UAS airspace authorization requests. So plan way ahead.

90 Current Landscape of Unmanned Aircraft Systems at Airports • Work with your local ATCT to get their buy-in first. Also, start small (low risk). Choose locations outside the AOA, the[n] inside the AOA but in proximity to non-movement areas. Allow ATC to gain some confidence in your process and procedures before moving into higher risk areas. • Have properly trained personnel, situational awareness and coordination with local tower, familiarity and compliance with current regulations. • Clearly defined operating procedures must be developed to ensure safety. • Be very careful. • This is not a practice we widely allow or would fully endorse at this time and was only done as a special operation by our state DOT for our Remote Tower project. • I would only offer a thought: contractors, yes, only for limited projects for cost-cutting efforts. Tenants NEVER. • Make sure you stay current with all FAA regulations. • Know, understand, and keep current on the rules. • Create a UAS group with the core of the group led by Airport Operations and ATC. Develop SOPs that define operational parameters. Prior to any UAS use, ensure strong communication and coordination practices are established and adhered to. • Make sure that your contractors have all requirements filled prior to giving consent. • Ensure they have the correct credentials to operate and ensure they operate within the regulations. • My advice would be dependent on the amount of daily aircraft operations. • Follow UAS regulations.

Actual Survey Comments 91 • Seek advice from airports who are currently using UA. • Develop a process for approval of these uses on/near the airport. Ensure operations staff is well educated on the approved uses. • There are plenty of resources out there that can advise airports on how to operate safely including airports that are doing it now so just reach out to colleagues and coordinate with ATCT. • Ensure that everyone than [that] needs to know about any UAS ops at an airport are contacted beforehand. The airport administration, ATC, and other entities that are involved need to be on the same page. • I would advise them to go through the online training providing by our state DOT. Furthermore, if any staff member is a private pilot, he or she should pursue getting their commercial/governmental license. That way they will be better prepared to perform UAS services or provide oversight to any entity that requests approval for such operations. • Work with your ATCT. • Make sure you know all of the risks. There may be more to it than just buying UA and calling your tower to let them know where you will be flying. • The FAA's charge for our airport in the UAS IPP is to develop a standardized, repeatable process for airport operators and other stakeholders to follow in order to safely integrate UAS into their respective environment. Safety risk management is a big piece of the puzzle as is radio frequency and electromagnetic spectrum analysis.

92 Current Landscape of Unmanned Aircraft Systems at Airports • If the airport has a tower, all operations should be thoroughly coordinated with the tower. • They need to hire UA contractors that are led by professional aviators. RPICs with only UA backgrounds tend to lack an appreciation for what could go wrong. • Share information for UAS processes for non-towered airports. • Coordinate with FAA Air Traffic in event of immediate need for UAS. LAANC is too slow for some circumstances. • Communicate intentions clearly. • Hire UAS professionals with both manned and unmanned experience to oversee operations. • Have approval process and good documentation of all flights in addition to a good risk management and safety plan to utilize the technology safely. • Coordination and clear lines of demarcation.