Current Landscape of Unmanned Aircraft Systems at Airports (2019)

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17 C H A P T E R 3 The current available literature on UAS is enormous. New articles and blogs posts are daily being written about this dynamic segment of the aviation industry. From the intentional review of the literature as well as from survey responses, it was clear that most airports were not active in UAS operations. Thus, in addition to a review of the literature to set the stage for the discussion of survey responses, this chapter also attempts to provide an education to the airport operator who is interested in acquiring UAS, but not sure how to safely operate one. It is hoped that the overview presented in this chapter will be a welcome addition to the literature on this topic, assisting airport operators nationwide with the integration of this useful technology. UAS Industry Data and Trends According to a recent report by the Association for Unmanned Vehicle Systems International (2013), the cumulative economic impact of UAS integration into the National Airspace System (NAS) is projected to be $82.1 billion during 2015–2025. AUVSI projects 103,776 new jobs will be created and states will collect more than $482 million in tax revenues during that time frame. Based on this, AUVSI states that “Every year integration is delayed, the United States loses more than $10 billion in potential economic impact” (Association for Unmanned Vehicle Systems International 2013, p. 2). Yet, the FAA’s vision for fully integrating UAS into the NAS entails unmanned aircraft operating harmoniously with manned aircraft, side by side in the same air- space (Association for Unmanned Vehicle Systems International 2013). This is not without chal- lenges, however. “While significant UAS integration progress continues to be made, the FAA recognizes that much remains to be done to maintain existing operational capacity, security, and safety, while protecting airspace users, people, and property on the ground from excessive risk” (FAA 2018a, p. 13). Numerous other forecasts exist related to the UAS industry. For example, Goldman Sachs fore- casted a $100 billion UAS market for the period 2016–2020 (Steele 2018). Sales of UAS increased in excess of 500% from 2014 to 2016. Revenue from the consumer UAS market is projected to be $4 billion annually by 2020 (Branch et al. 2016). A McKinsey report highlights the rise in UA activity, from $40 million in 2012 to about $1 billion in 2017. The firm forecasts that commercial UAS (including both corporate and consumer applications) will account for $31 billion to $46 billion of the U.S. gross domestic product by 2026. Yet, as Euteneuer and Papageorgiou (2011) state: The size of the UAS market will be defined by the intersection of UAS missions, regulations and solu- tions, i.e., the intersection of end users (demand), regulators (safe operations) and industry (supply). To enable a UAS market, all three are required (p. 5C5-3). Literature Review

18 Current Landscape of Unmanned Aircraft Systems at Airports To measure the impact of UAS operations, the FAA regularly tracks various data points related to their use. The high degree of interest in UAS is reflected in the number of remote pilot certificates issued, number of LAANC airspace requests, number of waivers and authorizations, and number of UA registered (Table 2). Table 3 presents the top five Part 107 waiver categories, as of July 2018, along with number of waivers issued, according to the FAA. Remote pilot Certificates issued 98,118 Knowledge exam success rate 92% LAANCa airspace requests Auto-approved 12,451 Further coordination 1,180 Manually processed airspace waivers/authorizations Approved 23,134 In queue 12,241 Cancelled/denied 19,201 UAS registration Online hobby 934,678 Online commercial 214,438 Paper 6,722 aLow Altitude Authorization and Notification Capability access to controlled airspace near airports through near real-time processing of airspace authorizations below approved altitudes in controlled airspace. Source: FAA 2018a. Table 2. FAA statistics on unmanned aircraft systems as of July 2018. Waiver Category No. Issued Night operations 1,635 Operations over people 13 Beyond-visual-line-of-sight (BVLOS) operations 18 Operational limitation: Altitude 21 Operations from a moving vehicle 6 Source: FAA 2018a. Table 3. Top five Part 107 waiver categories and number issued.

Literature Review 19 Low Altitude Authorization and Notification Capability The FAA LAANC program began in November 2017. Structured within the FAA UAS Data Exchange umbrella, LAANC is a collaboration between the FAA and industry, directly support- ing integration of UAS into the NAS. Although 14 C.F.R. Part 107 allows for commercial use of UAS, an authorization from the FAA is required prior to operating in Class B, C, D, or surface areas of Class E airspace. There is no authorization required for sUAS operations in Class G air- space, although notification is required if within 5 miles of an airport. LAANC “provides access to controlled airspace near airports through near real-time processing of airspace authorizations below approved altitudes in controlled airspace” (FAA 2018d). The process allows for pilots to apply for approval of planned UA operations. “Requests are checked against multiple airspace data sources in the FAA UAS Data Exchange such as temporary flight restrictions, NOTAMS [Notice to Airmen] and the UAS Facility Maps. If approved, pilots receive their authorization in near-real time” (FAA 2018d). As of November 2018, the FAA had processed more than 50,000 LAANC applications. Provid- ing UA operators near instantaneous approvals to fly in controlled airspace, the LAANC system covered almost 300 air traffic facilities and including almost 500 airports as of November 2018 (FAA 2018d). There were 14 LAANC service suppliers in November 2018, and instructions on how to apply were provided by each supplier. “The reason that LAANC is so exciting is that it brings a 90 day process down to 90 seconds” (McNabb 2018). For areas not covered by LAANC, UA opera- tors may file for airspace authorizations using FAA UA Zone at https://faaUAzone.faa.gov. Applications of Unmanned Aircraft Systems “The technological improvements to hardware, software, sensors, and artificial intelligence in the UAS industry are enabling UA to fly faster, more accurately and efficiently, and for longer periods of time” (Bash 2018). According to Terwilliger et al. (2015, p. 571), “New applications for unmanned aircraft systems (UAS) are being established at an increasing rate in connection with technological advances, operational enhancements, and improved capabilities awareness.” Some of these applications are not new to aviation, because a shift is being seen in some cases from manned helicopter operations, for example, to UAS. As stated by Steele (2018), Many applications currently calling for airplanes or helicopters can be completed far more affordably with a UA. An average helicopter and pilot can cost between $600 and $1,000 per hour. That price does not include the videographer or photographer. By comparison, a UA operator will charge perhaps $100 to $200 an hour, including the actual video shooting and production (paragraph 10). UAS are known to perform missions that are categorized as either dull, dirty, or dangerous. These are tasks that humans cannot do or would prefer to avoid. With enhanced designs and technological innovation, UAS are now also performing commercial applications that “have progressed beyond the stereotype” (Oliver 2016, p. 33). As Neubauer et al. (2015, p. 1) state, “The possibilities for UAS are only limited by the imagination of the developers and users, and the continuation of the efforts to safely integrate the systems into the NAS.” This certainly includes the imagination of airport staff (Figure 10). Remote Sensing Numerous remote sensing applications are possible with UAS. Defined as “the science of gathering data on an object or area from a considerable distance, as with radar or infrared photo- graphy, to observe the earth or heavenly body,” remote sensing has vastly improved the accuracy

20 Current Landscape of Unmanned Aircraft Systems at Airports and efficiency of data collection in certain fields (Marshall et al. 2016, p. 25). The fields most conducive to UAS-enabled remote sensing include (a) photogrammetric applications, such as aerial mapping, aerial surveying (e.g., Figure 10), and volumetrics; (b) precision agriculture, including crop health assessment, stand counts, and crop damage assessments; and (c) natural resource management (Blanks 2016). Regarding precision agriculture, whether used in grain crops, vineyard applications, or organic agriculture, the agribusiness segment is experiencing significant growth. UAS allow farmers to obtain an aerial, “big-picture” view of their crops and with proper remote sensors on the aircraft, farmers can scan their crops for health problems, record growth rates and hydration, locate disease outbreaks, and discover areas of poor drainage. Even large UAS are being used by some, including farmers in the Red River Valley of North Dakota. According to one agricultural producer, “As farmers, we are constantly trying to do our best, both from an environmental standpoint as well as an economic standpoint. We produce the safest, most economical, environmentally friendly food in the world. And it’s technology like this that helps us accomplish that” (Miller 2016). Industrial Inspection Industrial inspection applications are also possible with UAS (Figure 11). Although a relatively new area in which UAS are being used, transportation departments and engineers and inspec- tors nationwide are learning how UAS can enable inspections of equipment, infrastructure, or hardware in much less time, thereby reducing impacts to travelers and enhancing safety of inspection personnel. The fields most conducive to UAS-enabled industrial inspection include (a) civil infrastructure, including bridge inspections, road condition monitoring, and levee and dam inspections; (b) electric power industry, including inspections of transmission poles, transformers, insulators, long-distance transmission lines, rights-of-way, and electrical coronas; (c) wind turbine inspections, including turbine blades, hubs, and towers; (d) towers and antennas, including radio, cell, and phone towers; and (e) oil and gas, including pipelines, flare stacks, and oil and gas exploration (Blanks 2016). Regarding inspections of civil infrastructure, consider that more than 612,000 bridges exist in the United States, with more than 54,000 having at least one element in poor or worse condition. Figure 10. Runway marking inspections by UAS, Riverside Municipal Airport in California. (Photo credit: Stephen Bossert).

Literature Review 21 Traditionally, bridges were inspected manually, requiring temporary closure of the bridge, or one directional side at a time. An inspector with hard hat and vest would visually inspect the bridge, recording discrepancies as appropriate. Yet, with UAS, these inspections can be accomplished much faster and more safely. By equipping the UAS with photogrammetry and thermal imaging cameras, the inspection goes beyond what a human eye can detect (Michigan Tech News 2018). Limitations still remain, however. For example, inspections may require physical inspection of bridges. Aerial Filming and Photography Quite possibly the most popular uses of UAS today, certainly among novices, are the applica- tions of aerial filming and photography. Although this can include still-image cameras, FMV is required for aerial filming applications. The fields most conductive to UAS-enabled filming and photography are (a) filmmaking, including movies and videos; (b) real estate, including both residential and commercial properties; (c) marketing, including banner towing; and (d) news reporting, including live video reporting of news events as they unfold (Blanks 2016). The real estate industry, in particular, is benefiting greatly from the UAS technology that is so widely available. According to Steele (2018), the real estate industry is being affected by UAS in the following ways: • As storytellers. “UAs can allow developers to tell more compelling stories through video” (Steele 2018). Whether showing construction progress on new high-rise urban lofts or simply showing aerial video of a single-family home and the surrounding neighborhood, buyers are now expecting a bird’s-eye shot. • For construction. “UAs are also helping developers build more safely and quickly” (Steele 2018). Construction crews are relying on UAs to better inventory existing supplies of lumber, steel, and other supplies to better manage delivery across multiple sites. • For location. “UAs are on a path to begin influencing the way developers think about loca- tion and infrastructure” (Steele 2018). If UAs begin delivering groceries and other products in the future, locating a housing development near retail shopping areas may no longer be a deciding factor for a buyer. • With robotics. UAs combined with robotics may be able to clean skyscraper windows or perform other tasks. Figure 11. Drainage inspection by UAS, Golden Triangle Regional Airport in Columbus, Mississippi (Photo credit: Mike Hainsey 2018).

22 Current Landscape of Unmanned Aircraft Systems at Airports • Various services. Traditional surveying is made more efficient and robust with lidar-equipped UAs. Three-dimensional maps could help prospective buyers understand topography of land, including how it might be affected during a flood, for example. Additionally, being able to analyze a roof for potential leaks would allow remediation before damage occurs (Steele 2018). UAS are acting as change agents disrupting many industries. As Steele (2018) shared, “It is also exciting to contemplate the data capture and predictive analytics opportunities UAs afford.” Intelligence, Surveillance, and Reconnaissance and Emergency Response UAS have also been used to a great degree in the fields of intelligence, surveillance, and reconnaissance (ISR), as well as emergency response (Figure 12). Although ISR applications have traditionally been the purview of the military, civilian use of ISR enables the collec- tion of information about an object or individual. Emergency response allows first respond- ers to locate missing hikers, track criminals, and more. The fields most conductive to ISR- or emergency response–enabled UAS include (a) law enforcement, such as accident and crime scene reconstruction, as well as tactical operations support, such as an active shooter scenario; (b) search and rescue, such as locating victims by identifying a heat signature with thermal imaging; (c) communications relay, such as providing temporary cell phone coverage after a natural disaster; and (d) signals intelligence, such as the ability to locate an individual by triangulating on signals radiating from a personal electronic device (Blanks 2016). According to Karsten and West (2018), as of December 2018, there were 910 local, state, and national agencies across the United States using UAS to assist in their work. Because UAS are being integrated into the toolbox of emergency responders, more UAS-appropriate missions are being realized. For example: • Search and rescue—Using high-definition video and thermal imaging, search and rescue is expedited. • Crime prevention—First sending UA in response to a 911 call has been found to decrease response times and assist in locating criminals. Figure 12. Emergency exercise video by UAS, Golden Triangle Regional Airport (Photo credit: Mike Hainsey 2018).

Literature Review 23 • Crash simulation—With 3-D simulation, models of car accident scenes can be recreated, allowing officials to more accurately determine the cause of the accident. Outdoor crime scenes may also be recreated with the help of UAS. • Disaster readiness and response—Evaluation of damage after a large-scale disaster, such as a hurricane, aids officials in developing the most effective initial response, as well as gauging when affected areas are safe to reenter. Three-dimensional mapping can also be carried out via UAS in large shopping malls or schools, thereby providing first responders greater familiarity before arriving on scene to respond to an active shooter, for example (Karsten and West 2018). Regarding communications relay, although it is often assumed that the value of UAS lies in their ability to travel from point A to point B, some applications require that the UA be tethered to the ground. Keeping them aloft and stationary meets these needs. One company is now teth- ering UA, which allows the once 20-minute endurance to become 2 weeks, because the tether also contains the power source. These tethered UA serve as instant observation towers and may be used to aid the military and first responders. They may also be used to relay radio and cell signals. In fact, this company has completed tests of cell repeaters with Sprint. The ability to restore communications after a major disaster, even albeit via UA, is certainly a use one might not have imagined for this technology (Stewart 2018). For example, Hurricane Maria knocked out numerous cell towers in Puerto Rico in Septem- ber 2017, making cellular communications next to impossible. In response, AT&T deployed their tethered “Flying COW” (Cell on Wings), which provided wireless connectivity in an area of up to 40 square miles. The UA hovers 200 feet above the ground and can provide network coverage to 8,000 users, depending on equipment and network factors (Brodkin 2017). Atmospheric Information Collection The collection of atmospheric information is challenging, and UAS have further enabled this mission. According to Blanks (2016, p. 37), “Atmospheric sampling involves the sensing or col- lection of airborne particulates or gases to identify the characteristics of the atmosphere.” What once required manned aircraft and balloons can now be conducted by UAS. The fields most con- ducive to UAS-enabled atmospheric information collection include (a) meteorology, to better understand weather phenomena and tracking of significant weather events such as hurricanes; (b) hazardous material detection, such as gas leaks and other airborne toxic substances; and (c) radioactivity detection such as measuring the amount of radioactive material after a nuclear power plant explosion (Blanks 2016). UAS have been effectively used to monitor air quality in an effort to determine the impact of a facility on the environment, or simply obtain air quality measurements for an area, even a large regional area, such as Southern California. According to a popular blog on the use of UAS, benefits of using UAS in environmental monitoring include • Improvement over outdated sampling techniques, • Providing a stable and precise platform, • Allowing adequate time for data collection, • Providing real-time data and imagery, and • Lending well to autonomous data collection (UAVLance 2016). Atmospheric information collection might be a newer application of UAS, but this applica- tion shows tremendous promise. Drones are being used in various air quality control methods for measuring particulate matter and VOCs [volatile organic compounds] as well as measurements relating to meteorology, such as temperature, humidity, pressure and winds. In addition to this, drones can be used to continuously measure gases such as ozone and others that give us an idea about environmental conditions (UAVLance 2016).

24 Current Landscape of Unmanned Aircraft Systems at Airports Physical Interactions with Substances, Materials, and Objects Although the previously discussed applications involve the process of remotely sensing, col- lecting airborne samples, or intercepting signals, UAS can also be used in applications that require the UA to physically interact with a substance, material, or object. This creates a unique set of challenges, but UAS users are known to overcome challenges. The fields most conducive to UAS-enabled physical interactions include (a) aerial chemical application, such as adding fertilizer, pesticides, and herbicides to agricultural crops; (b) water sampling, such as obtaining physical samples via tubing and a pump; and (c) cargo delivery, such as small parcels. Regarding aerial chemical application, crop dusters or agricultural aircraft have often per- formed these tasks. However, unmanned helicopters have been used for aerial chemical appli- cation since 1991. In fact, today these unmanned helicopters spray more than 2.5 million acres annually throughout the world. Approaches Used by Surface Transportation Agencies In 2018, the NCHRP conducted Domestic Scan 17-01, on “Successful Approaches for the Use of Unmanned Aerial Systems (UAS) by Surface Transportation Agencies.” It appears that surface transportation agencies are more active with UAS than airports. Although not specifi- cally airport related, the findings are insightful for airports. The project proposes seven areas for consideration in getting started with UAS: • Under executive support, successful programs – Have executive support; – Recognize the importance of planning both the initial purchase but also operations and maintenance; – Agree that UAS save resources, increase efficiency, and improve safety; and – Emphasize the benefits of UAS, but understand negative connotations related to the technology. • Under organizational structure, successful programs – Have a centralized authority and top-down support; – Leverage existing aviation experience in their state; – Utilize a variety of funding models but have a dedicated source; – Recognize that a relationship with—and understanding of—the FAA is critical; – Dedicate personnel to understanding and keeping up with federal, state, and local regulations; – Transfer knowledge across departments and encourage transparency through relation- ships; and – Increase efficiency through fleet management and resource sharing. • Under policy and regulations, successful programs – Align their policies and procedures to be consistent with federal and state regulations; – Have expertise in UAS regulations and the ability to keep up with changes; – Understand how to obtain airspace authorization and work with local airports; – Promote existing regulation within the state to prevent unneeded regulations on a state or local level; and – Develop or adopt a policy and procedures manual for UAS operations. • Under safety and risk management, successful programs – Have a system to manage safety, which includes emergency response plans (ERP) and safety policy; – Have proper personnel and equipment for each mission; – Have flight risk assessment tools and risk acceptance procedures; – Have adopted and promote an aviation safety culture; and – Have adequate insurance.

Literature Review 25 • Under training and crew qualifications, successful programs – Establish and maintain initial and recurrent training needs for proficiency; – Tailor training needs to the varied applications of UAS; – Identify expectations of UAS operations with management; – Use training to educate users on alternative methods of compliance for UAS operations such as night operations, flight over people, or complex airspace; and – Recognize that meeting Part 107 minimum requirements is not a guarantee of the UAS expertise needed in surface transportation UAS applications. • Under public relations, successful programs – Have a plan that identifies and addresses target audiences—internal (legislators, executive and technical staff, state employees); external (federal, local, university, vendors, public, and airports); – Identify existing regulations, rules, and policies and positive use of social media, videos, and outreach to educate UAS users (commercial users and hobbyists); – Include media relations, to address privacy, safety, notice for operation, and on-site inter- action during UAS flights; and – Include a communications office in their ERP. • Under application and operations, successful programs – Start small and grow with success; – Do not require a large investment to get started; – Justify UAS use with increased safety, reduced liability, money saved, greater productivity, better end product, protected environment, and reduced impact on the public; – Follow standard operating procedures; – Leverage UAS across disciplines and share UAS assets throughout the state; and – Have workflow processes for data collection, storage, usage, application development, and repurposed use of data collected (National Cooperative Highway Research Program 2018, pp. 7–14). Although it is difficult to project which markets will be the most active, AUVSI projects that precision agriculture and public safety are the most promising commercial and civil markets, “comprising approximately 90% of the known potential markets for UAS” (Association for Unmanned Vehicle Systems International 2013, p. 2). Airport Uses Based on available literature on this topic, it is clear that integration of UAS by airports remains in its infancy. As shared by Neubauer et al. (2015, p. 2), “At present, airport integration is not the focus of the UAS industry.” Although some airports have been quite innovative in this area, there are possible UAS applications that have not yet been realized by airports. Several examples highlighted in the literature include • Emergency management. The use of UAS can aid emergency responders with “more accurate scene overview to determine incident complexity and to assist in making quality determina- tions of what equipment and personnel is required in order to appropriately address an inci- dent” (Terwilliger et al. 2015, p. 576). A tethered UA, for example can enable an aerial view of an aircraft accident in parts of the airport devoid of access control camera coverage. UAS can send had high-definition video feed of an aircraft accident, fuel spill, or active shooter event directly to the airport emergency operations center (Hainsey 2018). By providing an incident commander (IC) real-time video of the scene, more effective incident management is enabled. Consider how UAS can pinpoint a fire’s origin, determine evacuation paths, locate passengers who were ejected from the aircraft, and assist the IC with planning the site of the triage area. For aircraft accidents off-airport in heavily wooded or marsh areas, UAS can provide an aerial assessment, allowing access routes to be devised (Terwilliger et al. 2015).

26 Current Landscape of Unmanned Aircraft Systems at Airports • Construction. Airports are benefiting from UAS aerial video and still imagery both during and upon completion of various construction projects. Documenting construction progress of a new runway, new ARFF station, new cargo ramp, or new terminal building is very cost- effective with UAS. Insightful time-lapse videos can be created with proper editing software. • Security. UAS may be used to perform inspections of the airport perimeter and also used to check gates and parking lots for potential security concerns. Depending on area of concern, UAS can also be on scene with video feed before law enforcement arrives (Hainsey 2018). • Engineering. UAS can support engineering functions, including GIS, aerial mapping, and line-of-sight calculations (Hainsey 2018). • Airfield inspections. UAS can be used to provide a pilot view of pavement markings and sig- nage (Figure 13). UAS can also be used to inspect runway safety areas (Figure 14) during the rainy season, checking for proper drainage (Hainsey 2018). • Facility inspections. UAS can enable an aerial view of facilities, including hangar and terminal roofs, for example (Hainsey 2018). • Wildlife mitigation. UAS can be used to harass hazardous wildlife as well as inspect hazardous wildlife attractants, including wetlands (Hainsey 2018). • Package delivery. For large airports that cover thousands of acres, UAS could be used to pick up and deliver small parcels from one side of the airport to the other or even to customers in areas surrounding the airport. In the future, it is possible that military and large air cargo carriers may be operating optionally piloted and unmanned aircraft from airports. Figure 14. Runway inspection by UAS, Centennial Airport (Photo credit: Michael Fronapfel 2018). Figure 13. Airfield inspection by UAS, Centennial Airport (Photo credit: Michael Fronapfel 2018).

Literature Review 27 • Training. UAS can capture aerial images and videos that are useful in employee training. Examples include videos of air rescue and firefighting (ARFF) exercises, aircraft servicing, driver training, and special operations. • Marketing. Prospective airport businesses and tenants now expect much more than a simple brochure. By using UAS, high-quality video can enhance the view of available airport property and enable prospective tenants to envision their use of the space (Hainsey 2018). According to Hainsey (2018), “Even the most basic drone has geosynced mapping capabilities to show properties from any angle you want.” • Community outreach. Airport expertise in UAS can enable town hall meetings and commu- nity events where UAS safety is the topic of conversation. Additionally, young people can be attracted to the field of aviation by visiting schools and introducing students to the world of UAS (Hainsey 2018). Some airports are busy attracting UAS manufacturers and operators to their airports. Accord- ing to Neubauer et al. (2015, p. 5), airport operators may realize greater success in this effort by taking multiple actions: • Engaging with an FAA UAS test site, • Engaging with area universities, • Contacting state government, • Attending UAS conferences and seminars, • Investigating complementary UAS businesses, • Determining UAS facility/infrastructure requirements, and • Reaching out to the FAA. Because there are so many potential uses of UAS at airports, greater use of UAS by airports is expected to increase in the near future. Furthermore, additional uses not yet discovered will be shared, further supporting UAS use to enhance operational efficiency at airports. Benefits of UAS Integration UAS increase human potential, allowing us to execute dangerous or difficult tasks safely and efficiently. From inspecting pipelines and surveying bridges to filming movies and providing farmers with aerial views of their crops, the applications of UAS are virtually limitless and offer a superior way to see what needs to be seen, in less time and at less expense. It’s no wonder businesses—small and large—are clamoring to use this technology (Oliver 2016, p. 33). Beside the federal requirement (dictated by Congress in 2012) to integrate UAS into the NAS, there are clear benefits to this integration. UAS have been shown to create “cost efficiencies, enhanced mission capabilities, increased safety, more education and career opportunities, and other benefits” (Oliver 2016, p. 33). Cost savings have been significant in numerous applications because UAS are allowing for aerial imagery that was once only possible with manned fixed-wing and rotary-wing aircraft at a much higher cost. Additionally, UAS typically enable task comple- tion at as much as half the time typically required. Although cost savings vary according to mis- sion, this has been one of the greatest benefits of UAS. According to Terwilliger et al. (2015, p. 572): UAS can provide significant benefit to users and the public, including enhancement of capability and reduced potential for harm, especially in those scenarios that involve removing personnel from dangerous environments or requiring performance of high-risk actions. UAS enable and support expedited response to emergency scenes; remain aloft for significant periods; capture data from dynamic and elevated per- spectives, while en-route and over scene; operate in dangerous environments; and relay critical informa- tion to those in command of coordinated efforts.

28 Current Landscape of Unmanned Aircraft Systems at Airports For airports considering the integration of UAS into normal operations but not sure how this would affect the airport’s Part 139 certificate, for example, Neubauer et al. (2015, p. 40) point out that Research for the [ACRP Report 144] primer did not identify any impacts associated with UAS on air- port certification. The introduction of UAS into or near a certified airport does not impact its certification status. The impact of introducing UAS is similar to that of any other new tenant or aircraft operator. The airport operators should ensure they continue meeting all applicable regulations and standards during and after UAS introduction. Airports currently utilizing UAS are reaping the benefits of this technology. Airport operators, as well as contractors and tenants, can expect operational improvements, such as the ability to use UAS for labor-intensive activities such as perimeter inspections, obstruction analysis, wild- life monitoring, environmental monitoring and measurement, and pavement management. As Matthews et al. (2017, p. 4) explain, “Within the terminal structures, UAS have the potential to improve security observation and surveillance, and might even perform rapid document and small package delivery.” In the future, purpose-built UAS airports or hybrid manned/unmanned airports may be built to capitalize on the benefits of UAS. In fact, the first official drone airport has already been developed on a 50-acre site in Boulder City, Nevada. Built by Aerodrome, the airport will serve as a hub for commercial drone operations in the area and will welcome hob- byists, government officials, rescue workers, and private businesses interested in operating UAS (Hodgkins 2016). While benefits are currently being realized by some airports, other benefits are being antici- pated based on new applications of UAS in the airport environment. These benefits are not without challenges, however. Challenges to UAS Integration According to Matus and Hedblom (2018, p. 2F1–11), “Large-scale UAS integration into the world’s airspace is one of the greatest challenges faced by the aviation industry.” Yet, to further the UAS industry, integration is essential. The partial integration of UAS into the NAS has already resulted in several incidents, to include a U.S. Army UH-60M that encountered a DJI Phantom 4 in midair, resulting in damage to the helicopter’s main rotor blade (Wallace et al. 2018). Additionally, there have been UAS sightings at various airports, including the March 2019 UA sighting near Frankfurt Airport in Germany, the January 2019 UA sighting near London Heathrow airport, and the December 2018 UA sight- ing near London Gatwick Airport. Accordingly, the FAA has been pursuing UAS operators not in compliance with Part 107 and safe operating procedures. In fact, during an 11-year period (June 2007–May 2018), the FAA initiated action against 518 UAS operators. Yet, according to Wallace et al. (2018, p. 1), “encounters between manned and unmanned aircraft are becoming increasingly common events.” Not surprising, “the FAA reportedly expects an elevated risk of unsafe UAS operations as more UAS platforms integrate into the NAS” (Wallace et al. 2018, p. 2). This is one of the reasons for the FAA’s very controlled and deliberate integration of UAS into the NAS. Although the FAA is moving toward full integration of UAS, to include test sites, Integration Pilot Program participants, Part 107, and more, challenges to full integration remain. Some will be solved with technology, some will be solved with training and procedures, and others will be solved with regulations. According to Oliver (2016), the following challenges remain: • Detect and Avoid—14 C.F.R. § 91.111(a), “Operating near other aircraft,” and 14 C.F.R. § 91.133(b), right-of-way rules must be complied with. Currently, the lack of an onboard

Literature Review 29 pilot makes this difficult. There is a move toward sense and avoid (SAA), and progress is being made in this area, but the FAA requires UAS to possess a human-equivalent SAA system able to reliably detect and avoid intruding aircraft within a 3-mile radius with a field of regard of 270 × 30 degrees. According to Armstrong (2010, p. 1), “Access to non-segregated airspace will require UAS to show an equivalent level of safety as manned aircraft.” • Command-and-control links—UAS must have reliable and secure command-and-control data links to ensure continued communication between the ground station and the aircraft. • Communication frequency spectrum—To ensure stable command-and-control links and proper payload communications, a frequency spectrum for UAS operations must be allocated. • Pilot operator qualifications—Pilots, sensor operators, and crew must be sufficiently trained and appropriately rated. This requires establishing minimum certification, training, currency, and testing standards. • Security—Security must be addressed by mitigating hostile UAS and threats with counter- UAS technologies and operations. • Privacy—Although privacy concerns by the general public have softened in the past few years, these concerns still exist, requiring the education of operators and the general public about the benefits and appropriate use of UAS (Oliver 2016). • Regulatory compliance—“Identifying and integrating new UAS technology and techniques into applications, such as emergency response, requires thorough review and considerations of regulatory compliance, capabilities, limitations, challenges, benefits, and environment to ascertain optimal system configuration and development of an appropriate concept of opera- tion (CONOP)” (Terwilliger et al. 2015, p. 572). Quite possibly, achieving full unmanned detect and avoid or SAA is the greatest challenge to full UAS integration. As Young and Brenton (2016, p. 2B2–1) explains, “To safely integrate UAS into civil airspace, a robust detect and avoid (DAA) capability is required.” Consider, if this challenge was solved, how quickly UAS integration might occur. To better understand this challenge, it is beneficial to define DAA in terms of two high-level functions that must occur: (a) self-separation and (b) collision avoidance. According to Euteneuer and Papageorgiou (2011, p. 5C5–5), “Self separation is intended to resolve any conflict early, so that a UAS remains ‘well clear’ of other aircraft and avoids the need for last-minute collision avoidance maneuvers.” In essence, the unmanned aircraft would remain well clear of other aircraft, just as manned aircraft do. Collision avoidance is a more drastic maneuver that is designed to prevent a midair collision. Just as manned aircraft are able to do both, so must UA. Design- ing UAS that could self-separate but not engage in collision avoidance, for example, would be insufficient. UAS must be capable of both (Euteneuer and Papageorgiou 2011). Safety is critical, as shared by Matus and Hedblom (2018, p. 2F1–6): “It is incumbent on industry to ensure that the safety-first culture of aviation is maintained while enabling safe integration of UAS into the airspace.” According to the International Civil Aviation Organization (2011, p. 16), DAA may include the ability to • Recognize and understand aerodrome signs, markings and lighting; • Recognize visual signals (e.g., interception); • Identify and avoid terrain; • Identify and avoid severe weather; • Maintain applicable distance from cloud; • Provide “visual” separation from other aircraft or vehicles; and • Avoid collisions (Figure 15). In an encouraging development, the Kansas DOT, one of 10 members of the FAA UAS integration Pilot Program, began testing DAA capabilities in late 2018. Their technology uses a

30 Current Landscape of Unmanned Aircraft Systems at Airports camera, a processor, and computer vision software to see the airspace in proximity to the UA, allowing the UA to see as a manned pilot would and enabling beyond-visual-line-of-sight operations. According to the press release, “The system acts as a high-level supervisor to the UA’s autopilot, instructing it to execute automated avoidance maneuvers where necessary and informing the remote pilot in command of emergency situations” (sUAS News 2018). Yet, even with these significant challenges, if there is not a concerted alignment of UAS and manned aviation, “industrial investment will decline, implementation timelines will move further into the future, and solutions will become less affordable resulting in a smaller market” (Euteneuer and Papageorgiou 2011, p. 5C5–11). It is understood that airports will encounter new challenges with the integration of UAS, especially large UAS. For example, how will traffic be prioritized during periods of congestion? UAS will add demand to airports currently experiencing congestion or demand management. At airports already experienced with large UAS operations, such as Syracuse Hancock Inter- national Airport (see case examples), air traffic control has successfully integrated unmanned operations with manned operations. The support of airport management has further enabled this integration. Will manned commercial aircraft operators be negatively affected by UAS integration? According to Matthews et al. (2017, p. 4), “Most will not have on board primary surveillance equipment or the maneuverability needed to detect and avoid small UAS, which will be per- ceived as a safety hazard even if the UAS themselves are capable of detecting and avoiding the manned aircraft.” Indeed, not all airports are supportive of the full integration of UAS into the NAS. In fact, there are some airports that have adopted an opposing stance to UAS use on and around the airport, possibly due to concerns about the misuse of UAS technology. Airports may consider “creating segregated, sanitized airspace and surface areas exclusively for UAS that do not conflict with routine operations of manned aircraft and ground operations” (Matthews et al. 2017, p. 4). To ensure safely integrated UAS operations, airports will benefit from considering the follow- ing safety factors: • Runway safety. Ensure that controls are in place to prevent runway incursions and manned/ unmanned aircraft ramp conflicts. Figure 15. Detect and avoid (Source: International Civil Aviation Organization 2011).

Literature Review 31 • Safety of ground operations. If the UAS operation requires access to runways or taxiways for launch and recovery, this must be coordinated with airport operations and the air traffic control tower (ATCT). Proper controls must be in place to ensure safety of ground operations in the air operations area. On airports with an ATCT, a letter of authorization should spell out the manner in which UAS operations will occur, including call signs, communications, control, etc. • Airport access. Ensure that the airfield will remain open and operational for all users, while also accommodating UAS operations. Designating specific areas for use by the UAS may enable continued manned aircraft operations while also supporting UAS and safe airport operations. • Communication. Coordinate frequencies and phraseology to be used between the UAS opera- tor and the ATCT. • Coordination with stakeholders. The UAS operation is unique and may be a concern to other users. Consider outreach and other methods to make other users aware of this new type of operation and how airport safety will be ensured (FAA n.d.). In July 2018, the FAA issued guidance on UAS detection and countermeasures technology (FAA 2018b). The letter points out that the FAA in partnership with the Department of Home- land Security, the Department of Defense, the Department of Justice, and other federal agencies have collectively evaluated various UAS detection and countermeasure technologies. Based on findings from these efforts, the FAA “does not endorse or advocate for the use of countermea- sures in the airport environment given the likely resulting impact on the safety of the NAS” (2018b, p. 2). As explained by the FAA, “The use of countermeasure technology and the poten- tial response of the targeted UAS when engaged could introduce greater hazards to the NAS than the UAS-based hazard it is intended to mitigate” (2018b, p. 2). In addition to potential electromagnetic interference, the FAA explains that Technologies used to detect or mitigate UAS could implicate various provisions of the federal crimi- nal law in title 18 U.S.C. (including but not limited to Pen/Trap Statute, the Wiretap Act, the Aircraft Sabotage Act, the Computer Fraud Act and Abuse Act, and the prohibition against interference with cer- tain satellite operations) as well as other laws, such as the prohibition on Aircraft Piracy in title 49 U.S.C. (2018b, p. 3). Furthermore, “federally obligated airports independently allowing evaluations of UAS detection and countermeasure systems could be in conflict with their grant assurances” (FAA 2018b, pp. 2–3). As such, it is beneficial for airport staff to keep an open mind regard- ing UAS. However, more recently, in October 2018, President Trump signed the FAA Reauthorization Act of 2018 into law. Of particular importance to airports interested in UAS drone detection and countermeasure technology, section 383(b)(1), of the Act requires the FAA to charter an Aviation Rulemaking Committee to develop a plan for the “certification, permitting, authoriz- ing, or allowing of the deployment of technologies or systems for the detection and mitigation of unmanned aircraft systems” (49 U.S.C. § 44810). Current detection and mitigation technologies are dual use and support integration of UAS into the airspace. Additionally, under section 383(e), “purchasing an unmanned aircraft detection and mitigation system shall be considered airport development,” which will make such systems eligible for Airport Improvement Program fund- ing. Airports considering these technologies would benefit from having a plan in place for the use of these detection and mitigation products. In summary, the federal government is moving toward full integration of UAS into the NAS. Yet, this will occur in phases and only when safety is proven to ensure that both manned and unmanned pilots operate safely in an integrated fashion. Because of the ever-changing policy landscape, it is incumbent upon airport operators to remain abreast of efforts in this area.

32 Current Landscape of Unmanned Aircraft Systems at Airports FAA Efforts The FAA Modernization and Reform Act of 2012 (Pub. L. No. 112-95) was the first federal effort to integrate UAS into the NAS. Specially, Subtitle B, Unmanned Aircraft Systems, contains the following six sections: Section 331. Definitions. Section 332. Integration of civil unmanned aircraft systems into national airspace system. Section 333. Special rules for certain unmanned aircraft systems. Section 334. Public unmanned aircraft systems. Section 335. Safety studies. Section 336. Special rule for model aircraft. This law contained three main requirements that have drastically altered the UAS landscape in the United States. First, section 332(a)(1) required a comprehensive plan developed no later than 270 days after the enactment of the law, that “safely accelerate[s] the integration of civil unmanned aircraft systems into the national airspace system.” Second, section 332(b)(1) requires the FAA to publish a “final rule on small unmanned aircraft systems that will allow for civil operation of such systems in the national airspace system.” Third, section 332 requires the establishment of “a program to integrate unmanned aircraft systems into the national airspace system at 6 test ranges.” In response to the first requirement, the FAA (2013) published Integration of Civil Unmanned Aircraft Systems (UAS) in the National Airspace System (NAS) Roadmap. This 74-page document is extremely informative and certainly makes the FAA’s stance on UAS very clear. Second, in June 2016, the FAA published 14 C.F.R. Part 107, Small Unmanned Aircraft Rule (2016c). This Rule, which became effective August 29, 2016, was the first to allow commercial use of UAS in the United States without a Certificate of Waiver or Authorization (COA). Third, in 2013, the FAA (as prescribed under the FAA Modernization and Reform Act of 2012), selected six UAS test sites (currently numbering seven). The test sites and their initial proposed area of focus are • North Dakota Department of Commerce—UAS airworthiness essential data, high reliability link technology validation, and human factors research. • State of Nevada—Air traffic control procedures required with the introduction of UAS into the civilian environment, and how these aircraft will be integrated with NextGen. • University of Alaska—Development of a set of standards for unmanned aircraft categories, state monitoring and navigation, and safety standards for UAS operations. • Texas A&M University Corpus Christi—Systems safety requirements for UAS vehicles and operations with a goal of protocols and procedures for airworthiness testing. • Virginia Polytechnic Institute and State University—UAS failure mode testing and identifica- tion and evaluation of operational and technical risk areas. • New York Griffiss International Airport—SAA capabilities for UAS, and the complexities of integrating UAS into the congested, northeast airspace (Neubauer et al. 2015; FAA 2018e). Each test site is serving as a proving ground for enhanced technologies that will enable full inte- gration of UAS into the NAS. At the Griffiss International Airport test site, for example, research is being conducted on a ground-based SAA system, which will enable routine UAS operations in the NAS (both terminal area and transition airspace). The system being tested uses Airport Surface Detection Equipment—Model X and airport surface surveillance capability, wide-area multi- lateration, lightweight surveillance and target acquisition radar, and airport surface surveillance radar. In fact, multilateration is the common element on which the other elements rest. For the uninitiated, multilateration “is the process of determining a transponder’s location by solving for

Literature Review 33 the mathematical intersection of multiple hyperbolas based on difference between arrival times of a transponder’s signal at multiple sensors” (Young and Brenton 2016, p. 8D4–4). The FAA also has a Center of Excellence for UAS Research. Known as ASSURE, this Center of Excellence is formally the Alliance for Systems Safety of UAS through Research Excellence. ASSURE comprises 23 research institutions and 100 leading industry and government partners. Members include Drexel University, Embry-Riddle Aeronautical University, Kansas State Uni- versity, Mississippi State University, Montana State University, New Mexico State University, North Carolina State University, The Ohio State University, Oregon State University, University of Alabama–Huntsville, University of Alaska Fairbanks, University of California, Davis, University of Kansas, University of North Dakota, and Wichita State University. Affiliate members include Auburn University, Concordia, Indiana State University, Louisiana Tech University, Sinclair Com- munity College, Technion–Israel Institute of Technology, Tuskegee University, and the University of Southampton. Areas of current research include (a) air traffic integration, (b) airworthiness, (c) control and communication, (d) DAA, (e) human factors, (f) low-altitude operations safety, and (g) training. One example of specific research projects includes the effect of manned/unmanned aircraft encounters (Alliance for Systems Safety of UAS through Research Excellence n.d.). As explained on the FAA UAS website, “The research we collect and analyze . . . helps us make recom- mendations to improve data quality and consistency. The data requires analysis to determine tech- nical and operational trends to derive conclusions that support critical safety decisions required to integrate UAS into the National Airspace System (NAS)” (FAA 2018e). In October 2018, the FAA Reauthorization Act of 2018 was signed into law. This provided stability to the FAA and its programs for a period of 5 years at a cost of $97 billion, representing the longest funding authorization period for FAA programs since 1982 (National Conference of State Legislatures 2018). Subtitle B, Unmanned Aircraft Systems, is very robust with 44 sections. Highlights include the following: • UAS manufacturers must know and understand FAA rules regarding UAS to lawfully make and sell UAS in the United States. Before UAS can be sold in interstate commerce, the UA must either be self-certified by the manufacturer or approved by the FAA Administrator. • The FAA must consider “UA package delivery” by developing a rule allowing UAS to carry property for compensation or hire. • The Comptroller General (head of the Government Accountability Office) must conduct a study with a subsequent report to Congress regarding the regulation of low-altitude opera- tions of small unmanned aircraft and the roles of federal, state, local, and tribal governments in regulating this UAS activity. • The FAA is authorized by Congress to manage the UAS integration pilot program until October 2020. • Section 336 of the 2012 FAA Reauthorization Act is repealed by section 349, which had lim- ited the FAA’s authority to regulate recreational UAs. Currently, if intending to operate a recreational UA within 5 miles of an airport, the operator has three options: (a) If you have a Remote Pilot Certificate and are following Part 107 rules, you must get permission from the FAA to fly in controlled airspace. The FAA can grant permission two different ways—LAANC or DroneZone; (b) If you are flying with a model aeroclub organization following the Special Rule for Model Aircraft, you must notify the airport operator and the ATCT to fly within 5 miles of the airport; (c) If you are a public entity (law enforcement or government agency), the FAA may issue you a special permission to fly in a designated location near an airport. • FAA is required to test and evaluate technologies or systems that detect and mitigate potential aviation safety risks posed by UA. FAA is required to deploy such technologies or systems at five airports, including one airport that ranks in the top 10 of the FAA’s most recent Passenger Boarding Data.

34 Current Landscape of Unmanned Aircraft Systems at Airports • FAA test sites were extended until 2023 (FAA Reauthorization Act of 2018; National Confer- ence of State Legislatures 2018). The FAA Drone Advisory Committee, established as an advisory committee under the author- ity of the U.S. DOT and in accordance with the Federal Advisory Committee Act, exists to “pro- vide independent advice and recommendations to the FAA and to respond to specific taskings received directly from the FAA . . . related to improving the efficiency and safety of integrating UAS into the NAS” (FAA 2018c, p. 65390). The Unmanned Aircraft Safety Team is an “industry-government partnership committed to ensuring the safety of UAS in the NAS” (FAA 2018a, p. 6). A team with more than 60 members, the Unmanned Aircraft Safety Team has most recently recommended three safety enhance- ments: (a) geofencing and airspace awareness, (b) flight control return-to-launch function, and (c) improved UA sighting reports (FAA 2018a, p. 7). The FAA has developed the UAS Implementational Plan. The 5-year plan was developed by the FAA UAS Integration Office across all FAA lines of business. The plan details how the FAA aims to integrate UAS within the NAS over a 5-year period. According to the plan, “The FAA’s vision for fully integrating UAS into the NAS entails unmanned aircraft operating harmoniously with manned aircraft, side-by-side in the same airspace” (FAA 2018a, pp. 8, 10). The UAS Integration Research Plan was developed by the FAA to provide a framework for managing the myriad of UAS-related research activities across the country. The FAA considers this important because “research enables the development of informed policies, procedures, and regulations” (FAA 2018a, p. 8). Although Part 107 was a large step forward, allowing commercial use of UAS, it “is just the beginning of an incremental approach to a regulatory framework for expanded UAS opera- tions” (FAA 2018a, p. 25). According to “The Path to Full UAS Integration” roadmap produced by the FAA, this path includes moving toward operations over people, beyond visual line of sight operations, small package delivery operations, nonsegregated operations, routine/schedule operations, large carrier cargo operations, and eventually, passenger transport operations (FAA 2018a, p. 21). Although that might sound far-fetched to some, the FAA is moving in that direc- tion. As the FAA (2018a, p. 13) explains: While significant UAS integration progress continues to be made, the FAA recognizes that much re- mains to be done to maintain existing operational capacity, security, and safety, while protecting airspace users, people, and property on the ground from excessive risk. . . . Working in collaboration with other federal agencies, industry partners, and research institutions, we are actively extending our culture of safety to the world of unmanned aircraft—first by normalizing low risk operations and, through systems enhancements and regulations, building the framework to support more advanced capabilities. Pointing to future U.S. policy, the FAA (2018a, p. 17) explains: As UAS operations become more fully integrated in the NAS, the FAA will mature its UAS operational requirements, develop repeatable approval processes, assess and invest in required infrastructure and systems, and continually analyze the cost and benefits for the FAA and UAS stakeholders. This future includes continued type certification of UAS. Title 14, Part 21 of the Code of Federal Regulations defines three separate certifications: type, production, and airworthiness. Specially, type certification is the approval of the design of the aircraft and all component parts (propellers, engines, control stations, etc.). It signifies that the design is in compliance with applicable airworthiness, noise, fuel venting, and exhaust emission standards. Type certification has been common for manned aircraft, but recently, the FAA has been offering type certification for unmanned aircraft. In 2013, the FAA issued the first UAS-type certificates in the restricted category to the Boeing Insitu ScanEagle X200 and AeroVironment Puma sUAS. Currently, the Los Angeles Aircraft Certification Office is the main office for UAS-type certification.

Literature Review 35 In February 2019, the FAA issued three rulemaking documents. They were • NPRM—Operation of Small Unmanned Aircraft Systems over People (FAA 2019a) • ANPRM—Safe and Secure Operations of Small UAS (FAA 2019b) • Interim Rule, External Marking Requirement for Small Unmanned Aircraft (FAA 2019c) The first of these rule makings, NPRM—Operation of Small Unmanned Aircraft Systems over People, removes the prohibition of operating UAS over people without a COA and also proposes to allow UAS operations at night. UAS manufacturers would be required to design and test their UA to certain standards to ensure safety of operation and prevent harm to people on the ground. Operators would then only be able to operate properly certified UA over people. This NPRM incorporates three categories of UAS, as proposed by the Micro UAS Aviation Rule- making Committee. Category 1 UAS would simply allow operators to fly UA weighing 0.55 lb or less over people. Category 2 UA weigh more than 0.55 lb and could be operated over people if (a) the aircraft, upon impact with a person, would not result in an injury as severe as the injury that would result from a transfer of 11 ft-lb of kinetic energy from a rigid object, (b) the aircraft does not have exposed rotating parts that could lacerate human skin, and (c) the aircraft does not have an FAA-identified safety defect that presents more than a low probability of causing a casualty when operating over people. Finally, Category 3 UAS would allow the operation of UA weighing more than 0.55 lb over people if (a) the aircraft, upon impact with a person, would not result in an injury as severe as the injury that would result from a transfer of 25 ft-lb of kinetic energy from a rigid object; (b) the aircraft does not have exposed rotating parts that could lac- erate human skin; (c) the aircraft does not have an FAA-identified safety defect that presents more than a low probability of causing a fatality when operating over people; (d) the operation does not occur over any open-air assembly of people; and (e) (i) the operations are limited to a closed site and everyone in the site is notified that a small UA may fly over him or her; or (ii) for operations outside of a closed site, the UA would transit, but not hover over people (FAA 2019b). For proposed night operations, the UA would need to be equipped with an anti-collision light illuminated and visible for at least 3 statute miles. Additionally, operators would be required to complete additional knowledge testing to perform night operations. As of April 2019, the major- ity of the 82 comments provided in response to this NPRM appear to be in favor of the proposed rule, although there was some opposition expressed about the proposed categories of UAS. The second of these rulemakings, ANPRM—Safe and Secure Operations of Small Un– manned Aircraft Systems, proposes a number of changes to the current regulatory frame- work for UAS. As explained by the FAA, “As technology continues to improve and new uses for small UAS are identified, the FAA anticipates an increased demand for flexibility in operational restrictions under part 107. These new types of operations may have public safety and national security risks that were not anticipated or envisioned” (FAA 2019a). Numerous topics are addressed in this ANPRM, including (a) standoff distances; (b) altitude, airspeed, and other performance limitations; (c) unmanned traffic management [UTM] operations; (d) pay- load restrictions; and (e) UAS critical system design requirements. The FAA is most interested in determining whether to impose additional limitations or requirements on remote pilots to reduce safety and security risks of UAS operations. As of April 2019, 1,192 comments had been received in response to the ANPRM. The comments varied widely in their view of the topics addressed in the ANPRM. The third of these rulemakings is an interim rule on External Marking Requirement for Small Unmanned Aircraft. This rule requires owners of UAS to display their unique UA registration number on an external surface of the UA. In the past, this number could be placed inside an internal compartment. As of April 2019, industry was awaiting a separate rulemaking on remote identification (ID) and tracking of UAS. According to Brian Wynne of AUVSI, remote ID will solve a lot of

36 Current Landscape of Unmanned Aircraft Systems at Airports problems. With remote ID, every UA will be identified and matched to an operator. Eliminating anonymous UA in the NAS “is a critical component of a successful UTM [UAS Traffic Man- agement] implementation and airspace security strategy” (McNabb 2018). The public safety community, along with airports, has been pushing for the ability to track and identify UAS. In September 2017, the UAS Identification and Tracking (UAS ID) Aviation Rulemaking Com- mittee (ARC) issued recommendations to the FAA regarding technologies available for remote identification and tracking of UAS. Recommendations included the collection of a unique identifier for UA, as well as tracking information, and owner and remote pilot identification. Additionally, the ARC recommended that the FAA should promote fast-tracked development of industry standards while a final remote ID and tracking rule is developed, potentially offer- ing incentives for early integration and relying on educational initiatives to pave the way to the implementation of the rule (FAA 2017b). As this situation evolves, airports will likely have much greater ability in the future to legally track UAS around airports. The FAA has been clear in that they do not intend to promulgate a final rule on UAS operations performed over people and at night, for example, until a regulation finalizes the requirements regarding remote iden- tification of small UAS. National Aeronautics and Space Administration NASA has been working with government and industry partners for the past few years in testing a system that would make it possible for unmanned aircraft to fly routine operations in U.S. airspace. NASA’s UAS traffic management (UTM) system is researching how to safely and effectively manage UAS traffic in an urban area. Technologies that NASA has been demonstrat- ing, along with industry partners, include flight Information management systems, the UAS service supplier interface for multiple independent UAS traffic management service providers, vehicle integrated DAA capabilities, vehicle-to-vehicle communication and collision avoidance, and automated safe landing technologies. As NASA explains, Urban Air Mobility, a safe and efficient system which supports a mix of onboard/ground-piloted and increasingly autonomous operations—is the new era of transportation. UAM vehicles are envisioned to be autonomous, using electric or hybrid propulsion to transport a small number of passengers and cargo from one point in an urban area to another, avoiding all ground traffic. These rotary wing vehicles would also have the capacity for vertical take-off and landing, eliminating the need for long runways (NASA 2018). Additional programs in UAS being performed by NASA include using UAS for disaster recov- ery and large UAS flights without chase planes (Figure 16). In recognition of NASA’s productivity Figure 16. NASA UAS research.

Literature Review 37 in this area, the FAA recently incorporated UAS UTM as part of the ANPRM—Safe and Secure Operations of Small UAS. National Institute of Standards and Technology The National Institute of Standards and Technology (NIST) is encouraging entrepreneurship in the field of UAS. Specially, this organization sponsors the Unmanned Aerial Systems Flight and Payload Challenge. This competition includes a three-stage challenge with prizes up to $432,000.00 (including travel and prototype builds) for the top 10 designs. This competition was designed by NIST to support field operations for first responders. In addition to this challenge, NIST produces numerous reports and publications based on research in all areas of standards and technology. ASTM International Standards organization ASTM International has established Committee F38 on Unmanned Air- craft Systems. Designed to addresses issues related to design, performance, quality acceptance tests, and safety monitoring for unmanned air vehicle systems, this committee includes manufacturers of UAS and their components, federal agencies, design professionals, professional societies, main- tenance professionals, trade associations, financial organizations, and academia. The committee has three tiers of focus: airworthiness, flight operations, and operator qualifications. The deliver- ables of the committee include standards and guidance materials for UAS. The committee cur- rently has jurisdiction over 14 standards, published in its annual book of standards (ASTM 2019). RTCA Standards organization RTCA established Special Committee (SC) 228, Minimum Opera- tional Performance Standards for Unmanned Aircraft Systems, in May 2013. This group is developing the Minimum Operational Performance Standards (MOPS) for DAA equipment and a command-and-control (C2) data link. The group has released DO-36, Minimum Opera- tional Performance Standards for Air-to-Air Radar Detect and Avoid Systems Phase 1. Addi- tionally, the group has released DO-365, Detect and Avoid Minimum Operational Performance Standards Phase I (DAA MOPS). They are currently working on phase 2 for both C2 MOPS and DAA MOPS (RTCA 2013). Association of Unmanned Vehicle Systems International Efforts AUVSI, located in Arlington, Virginia, is considered to be the world’s largest nonprofit orga- nization dedicated to the advancement of unmanned systems and robotics (Association for Unmanned Vehicle Systems International n.d.-b). Originally known as the National Associa- tion of Remotely Piloted Vehicles, the organization was founded in 1972. The Trusted Operator Program (TOP) is an initiative introduced by AUVSI in late 2018. According to AUVSI, “TOP is a professional unmanned systems community initiative aimed at supporting industry accepted remote pilot standards and protocols, which will result in the safe and sustainable advancement of the industry” (Association for Unmanned Vehicle Systems International n.d.-a). • TOP Level One “covers relatively low-risk operations for flights under Part 107.” • TOP Level Two “would be suitable for companies that want to conduct flights near expensive infrastructure, such as power lines or wind turbines, or any operation that would require an FAA waiver.”

38 Current Landscape of Unmanned Aircraft Systems at Airports • TOP Level Three “would address flights in ‘safety critical’ environments, such as near chemi- cal, oil, gas, nuclear, or mining facilities” (Association for Unmanned Vehicle Systems Inter- national 2018). Reasons for earning the TOP operator certification include (a) professional advancement, (b) recognition, (c) professional differentiation, (d) personal achievement, and (e) commitment to safety (Association for Unmanned Vehicle Systems International n.d.-a). The AUVSI may be accessed online at https://www.auvsi.org. Academy of Model Aeronautics Efforts The AMA, located in Muncie, Indiana, is considered the official national body for model avia- tion in the United States. Known as the world’s largest model aviation association, the AMA has been in existence since 1936. The AMA provides a large number of resources for model aviation operators through the AMA Flight School. Free courses tailored to the UAS operator include (a) sUAS Safety, (b) Small Unmanned Systems Information, (c) What to Know Before You Fly, and (d) Part 107 Ground School. For the UAS operator, the AMA offers various first-start resources. The AMA may be accessed online at https://www.modelaircraft.org. Registering Unmanned Aircraft In December 2015, the FAA introduced a UA registration requirement that applied to all UA weighing between 0.55 and 55 lb. However, a UA hobbyist from Washington, D.C., filed suit against the FAA and the new registration requirement, and on May 19, 2017, a federal appeals court agreed with the plaintiff and struck down the FAA UA registration requirement. Yet, on December 12, 2017, the National Defense Authorization Act for 2018 restored the FAA’s regis- tration rule for model aircraft (Vanian 2017). Today, all UAS (weighing more than 0.55 lb and less than 55 lb) must be registered with the FAA via the FAA UA Zone (https://faaUAzone.faa.gov/#). Whether the UAS will be operated in compliance with 14 C.F.R. Part 107 or Section 349 of the FAA Reauthorization Act of 2018 (49 U.S.C. § 44809), under Section 336 as a model aircraft, registration is necessary and may be done via the UA Zone website. The FAA makes it clear that, “You will be subject to civil and criminal penalties if you meet the criteria to register an unmanned aircraft and do not register” (FAA n.d.). Additionally, the FAA requires the UA to visually display the registration number. Initially, this number could be placed in the battery compartment as long as tools were not required to open it. However, since the February 2019 Interim Rule, External Marking Require- ment for Small Unmanned Aircraft, was issued, the registration number must be displayed on an external surface and visible on the outside of the UA. This allows for easier identification by first responders and law enforcement, no longer requiring these personnel to physically handle UA and avoiding the risk of an explosive device that may be concealed within a compartment. Paths for an Airport Operator Public entities, to include municipally owned and operated airports, may elect to utilize UAS in support of their operations. For those airports unsure of how to proceed, four paths are possible: 1. Conduct UAS operations in compliance with 14 C.F.R. Part 107 without a COA. 2. Apply for a 14 C.F.R. Part 107 COA. 3. Fly under statutory requirements for public aircraft and operate with a COA. 4. Hire a UAS consultant to handle applying for a COA and permits, as well as conduct UAS operations.

Literature Review 39 Regardless of the path chosen, operators will find useful information to ensure safe UA operations and avoid potential conflicts by downloading the B4UFLY Mobile App and visiting http://knowbeforeyoufly.org. Operators might consider purchasing insurance coverage for the commercial-use UAS. Several providers offer insurance coverage specifically for UAS operators which, depending on the policy, can include liability and hull insurance. Additionally, the FAA has developed a Public Safety and Law Enforcement Toolkit designed to assist law enforcement and public safety entities in operating and handling situations involv- ing drones or UAS. Resources include a video, Law Enforcement Pocket Card, Law Enforce- ment Guidance Card for Handling Drone Incidents, Drones in Public Safety: A Guide to Starting Operations, State and Local Regulation of Unmanned Aircraft Systems, Law Enforce- ment Guidance for Suspected Unauthorized UAS Operations, and Statutory Requirement to Register UAS. These resources are available at https://www.faa.gov/uas/public_safety_gov/ public_safety_toolkit. Path 1: Conduct Operations in Compliance with 14 C.F.R. Part 107 Without a Certificate of Waiver or Authorization An airport operator may decide to operate according to 14 C.F.R. Part 107, which applies to sUAS, meaning unmanned aircraft weighing less than 55 lb on takeoff, including everything that is on board or otherwise attached to the aircraft. Although Part 107 contains a number of operational restrictions, it may well satisfy the needs of an airport operator, not requiring the filing of any additional paperwork (except a LAANC waiver for operating in controlled airspace—which is quite likely for the airport operator that is operating UAS on airport). The regulation is somewhat straightforward, with the FAA having produced a Summary of the Part 107 rule (FAA 2016c). Step 1 is to learn Part 107 (what is permitted or required and what is not). Step 2 is for at least one staff member to earn the FAA Remote Pilot Certificate by successfully completing the FAA knowledge test. Once the UAS is acquired, step 3 is to register the UAS with the FAA at https:// faaUAzone.faa.gov/#. Path 2: Apply for a 14 C.F.R. Part 107 Certificate of Waiver or Authorization For a UAS operator intending to deviate from certain Part 107 provisions (such as daylight- only operations), applying for a COA is a reasonable path. Waiverable sections of Part 107 are • Section 107.25, Operation from a moving vehicle or aircraft. However, no waiver of this pro- vision will be issued to allow the carriage of property of another by aircraft for compensation or hire. • Section 107.29, Daylight operation. • Section 107.31, Visual line-of-sight aircraft operation. However, no waiver of this provi- sion will be issued to allow the carriage of property of another by aircraft for compensation or hire. • Section 107.33, Visual observer. • Section 107.35, Operation of multiple sUAS. • Section 107.37(a), Yielding the right-of-way. • Section 107.39, Operation over people. • Section 107.41, Operation in certain airspace. • Section 107.51, Operating limitations for sUA. UAS operators desiring to apply for a COA may do so online at www.faa.gov/uas.

40 Current Landscape of Unmanned Aircraft Systems at Airports Path 3: Fly Under Statutory Requirements for Public Aircraft and Operate with a Certificate of Waiver or Authorization Yet, a fourth path, which is much more involved but may be necessary to enable the airport operator to conduct UAS missions as intended, is to request a COA from the FAA to become a public aircraft operator. This would allow the public agency to self-certify pilots and UA for flights to perform governmental functions. The COA application process is completed entirely online. To view a sample COA application, visit https://bit.ly/1POkwxz. Consider the following 11 steps, specifically tailored to airports. Step 1: Entity Election A government entity has two options: operate as civil operators under Part 107 or operate as public aircraft operators under a COA. Public aircraft operators must apply for and obtain a COA. These two options allow an airport operator significant latitude in UAS operations. Specifically, if choosing to operate as a public aircraft operator, additional options to meet cer- tification and training requirements are permitted. In fact, public aircraft operators can “self- certify” airworthiness and pilot certification. However, the FAA does require the airport to detail its training and certification process in the COA application (Roper, as cited in Perlman, 2018). See http://knowbeforeyoufly.org/for-public-entities. Step 2: Formally Establish an Aviation/UAS Unit It is important to add an aviation, UAS department, division, or unit to the airport organiza- tional structure. This UAS unit should also have the financial resources and personnel allotted to it to ensure success. As Roper (as cited in Perlman 2018) explains, “You cannot just buy a UA and start operating.” Step 3: Develop a Concept of Operations and Justification Developing a Concept of Operations (CONOPS) at this preliminary stage is beneficial because it requires the airport operator to consider why UAS are being acquired. A CONOPS is a user- oriented document that “describes systems characteristics for a proposed system from a user’s perspective. A CONOPS also describes the user organization, mission, and objectives from an integrated systems point of view and is used to communicate overall quantitative and qualitative system characteristics to stakeholders” (IEEE 1998, p. 1). Part of the CONOPS should provide program or operational justification for the planned UAS operation, unit, or program. Airport operators may want to contact other airports active in UAS for advice in developing this justification. However, since most airports do not operate UAS or have metrics in place to evaluate their effectiveness, this operational justification is best developed as unique to each airport. The first part of this process includes developing metrics to determine how the UAS will benefit the airport. These metrics are often quantitative measures, but may be qualitative as well. Consider time saved or costs reduced for possible quantitative measures. Consider level of outreach to K–12 schools and level of operational impact for possible qualitative measures. Note that some metrics might be common to the industry (such as number of 14 C.F.R. Part 139 dis- crepancies) while others might be unique to a specific airport (such as number of MQ-9 opera- tions). Some of these differences will occur between commercial-service and general-aviation airports. Furthermore, “a combination of metrics is likely required to understand the issue” (Bottiger et al. 2018, p. 6). Second, classify metrics based on the flow of data. According to Bottiger et al. (2018, p. 6), performance metrics may be classified as input, output, and outcome:

Literature Review 41 • Input—“Measures that describe the resources the airport has (not a true measure of per- formance),” such as the number of UA owned by the airport. • Output—“Measures that quantify the service provided,” such as the number of perimeter inspections performed autonomously via UA. • Outcome—Serving as a ratio of input and output measures, “outcome measures provide feedback on the quality and efficiency of services or on the intended performance of the organization,” such as Part 139 discrepancies associated with the airport perimeter (14 C.F.R. § 139.335). Third, measure or estimate data related to each metric. This will be easier if a peer airport has data to share based on actual UAS experience. When an industry standard exists, peer bench- marking is quite possible and always beneficial. But even without an industry standard, an airport can perform self-benchmarking. As explained in ACRP Report 19A: Resource Guide to Airport Performance Indicators, Airport benchmarking consists of two separate activities: (1) self-benchmarking, in which the airport measures its own performance over time, and (2) peer benchmarking, in which the airport measures its performance against the performance of airports with similar characteristics (“peers”), against an indus- try standard, or against an industry “best practice” (Hazel et al. 2011, p. 8). Note that there are currently “no general metrics or commonly agreed upon definitions of what outcome should be used to define risk” (National Academies of Sciences, Engineering, and Medicine 2018, p. 32). At a minimum, the operator should estimate benefits via known opera- tional challenges that UAS will contribute toward resolving. Step 4: Purchase the UAS There are numerous UAS currently available on the market. The previously developed CONOPS will provide insight into specific missions required, which will then point the opera- tor toward certain UAS that will accomplish those missions with planned endurance, sensors, and so on. When entering the UAS space, reverse engineering is most effective, first considering what you want the UAS to be capable of, and then working backward to find a specific use that will accomplish your mission. Step 5: Register All UAS weighing greater than 0.55 lb must register with the FAA. This registration require- ment includes public aircraft operations. Registration takes place at https://faaUAzone.faa.gov/#. Step 6: Develop a UAS Policy Although possibly developed as part of CONOPS, a UAS Use Policy should be developed if it has not already been. Information to include in the policy includes • Concept of operations; • Description of the aircraft system; • Duties and responsibilities; • Maintenance and inspection; • Operations requirements and restrictions; • How data will be used; • Emergency operations, to include loss of communications, loss of control, loss of GPS, aircraft crash; • Launch and recovery; • Training and qualifications; and • Approved area of operations (Perlman 2018).

42 Current Landscape of Unmanned Aircraft Systems at Airports Step 7: Submit Declaration Letter The first step in applying for a COA requires the public entity to declare as a public entity to the FAA. A “declaration letter” must be submitted from the agency’s city, county, or state attor- ney’s office to the FAA via physical mail. Step 8: Submit E-mail Expressing Intent to Operate as Public Aircraft Operator Once the FAA provides acceptance of the declaration letter, the public entity then e-mails the FAA UAS Office at 9-AJR-36-UAS@faa.gov, expressing intent to operate as a public aircraft operator. The e-mail should contain (a) the name of the public agency requesting the COA, (b) a short description of the UAS to be used, and (c) CONOPS. Step 9: Complete Certificate of Waiver or Authorization Application Once the e-mail has been reviewed, the public entity will be provided an FAA point of contact and instructions for completing the online COA application. Information commonly required for the COA application includes • Type of mission; • Launch and recovery operation locations; • Operational altitudes; • Flight procedures; • Communications; • Emergency procedures, including lost communication; and • Pilot in command (PIC), flight crew, and observer qualifications and training requirements (Perlman 2018). The previously developed CONOPs and UAS Use Policy will be useful when completing the COA application. Step 10: Complete Phase I Operations Generally, the FAA provides a two-phase process to obtain full approval. First, Phase I is approved, which restricts all UAS operations to only training and evaluation activities at a spe- cific Class G airspace site (although exceptions may be made to the airspace requirement if safety protocols are met). During Phase I, sufficient ground and flight training take place to ensure that all crewmembers meet a high level of UAS proficiency. Prior to moving to Phase II, the FAA requires documentation of this training. To satisfy the FAA that the PIC is knowledgeable enough to safely operate the UAS in the NAS, the public entity might develop an in-house written exam, for example, based on FAA’s remote pilots UAS study guide (FAA 2016b). Step 11: Apply for Phase II Operations Although the time required to complete Phase I and move into Phase II varies greatly, once the public entity feels that flight crew members can safely operate the UAS at a level necessary to ensure safe and complete missions, the entity can apply for the second “operational” COA (Phase II). Path 4: Hire an Unmanned Aircraft Systems Consultant There are numerous consultants available to assist an airport operator with (a) UAS regula- tory compliance, to include filing paperwork to obtain necessary approvals; and (b) mission management and operations, to include operating the UAS and associated systems for surveying, lidar imagery, and GIS capture. Although using a consultant requires the least amount of knowl- edge on the part of the airport and may result in the fastest uptime, these conveniences do come

Literature Review 43 at an added expense. Airports and state DOTs active in the UAS area are often more than willing to share their expertise with an airport operator desiring to acquire and operate UAS (Figure 17). UAS Operating Guidelines Once the UA has been acquired, a path for operations has been determined, and approvals are in place, the operator should develop standard operating procedures (SOPs) to ensure the safest operations. The UAS Program Office of the North Carolina Department of Transportation has developed an excellent UAS SOP, which is useful for airports to review in developing their own unique UAS SOP. According to the North Carolina DOT, the following topics should be addressed in a UAS operator’s SOP: • Personnel: Role of UAS coordinator, remote pilot-in-command, and visual observers. • Training: Plan that includes initial and recurrent training. • Preflight operations: Planning, inspection, weather, checklist, and documentation. • In-flight operations: Outline of crew responsibilities to ensure safety and regulatory compliance. • Post-flight operations: After-landing checklist. • Emergency procedures: Specific to each manufacturer and addressing emergencies such as loss of datalink communications, loss of GPS, autopilot software error/failure, loss of engine power, ground control system failure, and intrusion of another aircraft into the UAS mission airspace. • Flight area/perimeter management. Flight boundaries (including temporary and permanent flight restrictions), primary takeoff and landing site, alternative landing sites, mission abort sites, flights over populated areas, and landing safety and ground control. • Accident reporting: Notification by the operator to FAA within 10 calendar days after an acci- dent (as defined by regulation) and before additional flights, as required by 14 C.F.R. § 107.9. • Flight crew communications: Providing for all crew to be in communication at all times. • External communications: Communication with FAA and others as appropriate (North Carolina Department of Transportation n.d.). Regardless of the extent of UAS SOP developed, safety should be priority number one. Airport operators active with UAS indicated that success is enabled when all regulations are followed, communications are maintained, and operators are trained. Needless to say, operating UAS requires a great deal more than simply taking one out of the box and turning it on. Figure 17. UAS at Gaspe Airport, Quebec, Canada (Photo credit: Catherine Cahill 2018).