sectionals (aviation map). This includes most cities and densely populated
* The FAA will consider issuing a COA for operations in unpopulated areas
as long as the agency seeking the COA can demonstrate that the operation is
safe, that sufficient risk mitigations are in place, and the operators have
sufficient training (which includes a pilot's license and medical certificate);
* Any law enforcement agency operating a UAS will be required to
establish their own airworthiness for the UAS. The airworthiness establishment
is the responsibility of the agency and not the vendor. Remember, any agency
applying for and receiving a COA assumes liability for the entire operation.
While vendor information may be used in deeming an aircraft airworthy, it should
not be the only information relied upon;
* The operation of a UAS requires a FAA certificated pilot with a current
class II medical certificate and an observer, who while not required to be a
pilot, but must have a class II medical certificate;
* A vendor approaching a law enforcement agency offering to demonstrate a
UAS to an agency must have an experimental airworthiness certificate issued by
the FAA prior to the flight. A vendor cannot rely upon an agencies COA to fly
the aircraft. COAs are only issued for aircraft that qualify as "public"
* The rules allowing the recreation use of model aircraft by hobbyist DO
NOT allow law enforcement agencies to use a UAS without a COA;
* There are currently no comprehensive studies that confirm the safety
records or vendor published data regarding the use of UASs. Problems identified
by the military's evaluation of UAS have included radio interference,
unexplained control loss, and the durability of the units for repeat flight
operations. Department of Defense UAS Program Managers expressed at a recent FAA
meeting on UAS, that they rarely get 10 or more missions accomplished with one
UAS unit due to crashes;
* It is not anticipated that the FAA will amend their position on the
operations of UAS before the year 2010. However, there are two key activities
taking place that will push the airspace access issue forward. The first is that
the FAA has agreed to conduct two test projects with major metropolitan police
departments. One is Miami/Dade, and the other is Houston. Each of these will
provide valuable insight into the difficulties that may exist in operating UAS
in urban environments. The other activity is the creation of new regulation for
small UAS to fly in the airspace. This recent development is just starting and
will be the genesis for getting small UAS flying in a majority of the U.S.
without a COA. Rulemaking can take time, however, so stick with the COA process
for the next year or two.
Through the Office of Justice Program's National Institute of Justice
(NIJ) and its Aviation Technology Program, law enforcement will have the chance
to voice their opinions regarding the use of UAS in the NAS.
NIJ is working with the FAA on rules and regulations regarding the use of
UAS by law enforcement that both enhance the mission of public safety and
provide for the safety of other aircraft in the national airspace and those on
NIJ is planning a forum on the use of UAS by law enforcement with FAA
participation during the winter of 20072008. NIJ invites interested law
enforcement agencies to participate in this process.
The preferred term at this juncture is not simply "unmanned aircraft," but "unmanned aircraft systems" (UAS), because there's so much more than just the aircraft.
Accomplishing the necessary modeling and simulation just to develop standards could take another 4-5 years.
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