1. Drones at the University of California: Applications, Regulations, and Safety Management Brandon Stark, Director Unmanned Aircraft System Safety Center of Excellence University of California

2. Center of Excellence on Unmanned Aircraft System Safety One-stop shop for all things UAS Services Answer any question about drones, regulations, safety, risk management, applications or research Files permissions and requests on behalf of faculty/staff Provide reports on UAS activity UAS Safety Management System 2

3. Topics Overview of UASs in the UC System UAS Laws The UC UAS Workflow Enforcement of UAS Policies Upcoming Changes 3

4. 4 What UAS activity is already occurring in the UC system? Nearly every campus has a ‘Drone Lab’ Largely Engineering groups Increased interest in Environmental, Agricultural, Archeological, and Ecological research groups Journalism, Facility Management, Publicity/Multimedia groups

5. UAS Vocab UAS – Unmanned Aircraft System COA – Certificate of Authorization, applies for both Public Agencies or Commercial UAS flights Part 107 – New SUAS Regulations (Aug 29 th, 2016) Pilot Certificate – Pilot’s license Remote Pilot Certificate – New SUAS RPIC license RPIC – Remote Pilot in command UAS Registration – Each aircraft must have an FAA number (starts with N or FA) SUAS – Small UAS (under 55 lbs) Section 333 Exemption – Congressional exemption from the prohibition of commercial UAS flights VO – Visual observer 5

6. UAS Roadmap 6 UC Merced receives COA (2013) UC Receives Section 333 Exemption (March 2, 2016) UC Receives Section 333 Exemption (March 2, 2016) UC Receives Public Blanket COA (April 5, 2016) UC Receives Public Blanket COA (April 5, 2016) Part 107 Rules & Remote Pilot Certificate (August 29, 2016) Part 107 Rules & Remote Pilot Certificate (August 29, 2016) Online Registration (April 7, 2016) Online Registration (April 7, 2016) Flying over People Rules (2017?) Large UAS Laws (2020?) Public COAs available to Public UAS (2005) Sec 333 Exemptions Introduced (Oct 2014) DJI Starts selling Drones (2008) Drones are “Next Big Thing” (2012) 300 COAs approved in 2010 NPRM For SUAS (Feb 2015) UAS Hobby Registration (Dec 2015) UAS Registration Mandatory (Nov 2014) SUAS Recommendations Released (2009) Educational Allowance (May 2016) ~3000 Section 333 (Feb 2016) ~6000 Section 333 (June 2016) Unmanned Traffic Management (2019?) Beyond Line of Sight (2018?) Amazon announces Drone Delivery (2013)

7. Disclaimer: There is an accurate summary of the laws and a summary of the laws that can fit in a hour-long presentation. There will be some conservative simplifications! Check with me for an exact analysis of any situation 7

8. Drone, Quadrotor, UAS, UAV, RC helicopter or Model Aircraft? 8 Aircraft Unmanned Aircraft Small Model Aircraft Model Aircraft are defined as a subset of Unmanned Aircraft. Model Aircraft are differentiated from Unmanned Aircraft only by the purpose in which they are flown Sec 336 in H.R. 658 – “The FAA Modernization and Reform Act of 2012” Model Aircraft are defined as a subset of Unmanned Aircraft. Model Aircraft are differentiated from Unmanned Aircraft only by the purpose in which they are flown Sec 336 in H.R. 658 – “The FAA Modernization and Reform Act of 2012”

9. Why does purpose matter? The FAA characterizes risk depending on a variety factors including purpose, aircraft size, flight location and operators Not limited to just drones! Unfortunately, this leads to a complicated set of regulations

10. Risk Assessment UC UFlight Workflow (user perspective) Flight Request To Center (UC form) File special permission with FAA Clear Airspace Where: When: Purpose: Pilot: Aircraft: Where: When: Purpose: Pilot: Aircraft: Registered Aircraft Licensed Pilot Flight Authorized Flight Report (UC form) Fly!

11. How does the UC get flight authorizations (behind the scenes) 11 Recreation/Education Student Recreation Student Curriculum Not for research Recreation/Education Student Recreation Student Curriculum Not for research Public Agency Operations (PAO) UC-Owned Aircraft Only for public research purposes No hard-restrictions on operations International students Public Agency Operations (PAO) UC-Owned Aircraft Only for public research purposes No hard-restrictions on operations International students Section 333 Exemption UC-Owned Aircraft Only specific UAS models allowed Requires Private Pilot’s License Used for very specific cases Section 333 Exemption UC-Owned Aircraft Only specific UAS models allowed Requires Private Pilot’s License Used for very specific cases Stop Not Legal Small UAS Regulations (Part 107) Any aircraft Requires SUAS License ($150) Up to 400 ft, Line of Sight, Daylight only For Research, Commercial, University Business, Journalism, Film and Photography Small UAS Regulations (Part 107) Any aircraft Requires SUAS License ($150) Up to 400 ft, Line of Sight, Daylight only For Research, Commercial, University Business, Journalism, Film and Photography

12. UAS Regulations

13. Typical Operation of Small Unmanned Aircraft The pilot must have remote pilot certificate with a small UAS rating. No careless or reckless operations. No carriage of hazardous materials, but other material or items may be carried. Maximum altitude of 400 ft and maximum groundspeed of 100 mph. May fly only during daylight and within visual line of sight, or close enough to see the aircraft clearly without additional vision aids. No flying over people unless they are part of the operation or are under a covered structure. Flights near airports will require prior airport authorization. A visual observer may be used however it is not required for flights. Records of all flights must be made available to the UC and the FAA. Certain provisions or restrictions may be waived on a conditional basis. Details in a separate presentations New with Part 107

14. Remote Pilot Certificate with SUAS Rating Operators must pass an Aeronautical Knowledge Test at an FAA-approved knowledge testing center. Knowledge exam is $150 and is allotted for 2 hours Make available to the FAA, upon request, the small UAS for inspection or testing, and any associated documents/records required. Report an accident to the FAA within 10 days of any operation that results in injury or property damage. All flights must include a preflight inspection. Details in a separate presentations

15. Not Allowed Does not permit flying over people or near people in a manner that puts them at risk No flying above 400 ft without additional FAA authorization No flying beyond line of sight or at night International students may not operate for commercial gain or for employment Certain research projects are allowed (see cheat sheet) New with Part 107

16. Recreation/Education “Model Aircraft” A person may operate an unmanned aircraft as model aircraft for hobby or recreation at educational institutions and community-sponsored events. A student may conduct model aircraft operations in furtherance of his or her education at an accredited educational institution. Details in a separate presentations

17. 17 Recreational/Class Curriculum Recreational Cannot receive money or compensation Cannot be used in furtherance with a business or official duty Must be operated within a community-based set of safety guidelines and within the programming of a nationwide community-based organization Education Students may build and fly a UAS as a component of a course curriculum or senior project UAS flights by students must be in accordance with Campus oversight. UAS flights in pursuit of research projects or university business are not considered recreational

18. Examples Recreation/Education A student club is considered recreational A student that flies a UAS as part of a class on remote sensing techniques is considered recreational A student building and flying a UAS as part of a class on aerodynamics is considered recreational A student building and flying a UAS for a senior project is considered recreational Part 107 A student club that is paid to perform at an event is not recreational A student flying a UAS under the direction of a faculty’s research is not recreational. A course where the primary objective is learning how to fly is not considered recreational. A student conducting sponsored research (faculty, company, student gov’t) is not recreational 18

19. Recreational vs Part 107 Recreational Individual recreation Coursework Includes Senior Projects* Recreational club activities Drone Racing Drone Demos Drone Photography Part 107 Research projects University business Promotional Filming Facility Management Commercial activity Club activity where SUAS is providing a service Drone filming a club event Drone delivery See the Cheat Sheet for more examples If it is plausible that someone would pay for a UAS to do it, then it is not recreational

20. What about Section 333 or Public COAs Section 333 Exemptions and Public COAs are still available Existing authorizations are valid until they expire, typically within 2 years of authorizations Provisions are unchanged The majority of Section 333 Exemptions and Public COAs should transition to Part 107 regulations

21. 21 Future Drone Laws The FAA recently released the recommendations for the next major regulation change on flying over people (for licensed SUAS operators) Performance-Based Standard for the Classification of UAS Operated over People Classification based on kinetic energy of a falling drone Low risk flights would be enabled for flights over people and crowds Higher risk flights must include a risk mitigation plan Flying over People Rules (2017?) Large UAS Laws (2020) Unmanned Traffic Management (2019) Beyond Line of Sight (2018)

22. 22 Future Drone Laws Beyond Line of Sight The next big target, especially for long-range inspections, agriculture, and delivery services Unmanned Traffic Management How do we keep all the drones from crashing into each other? Currently a major NASA project Large UAS For platforms over 55lbs The Ubers of the sky? Flying over People Rules (2017?) Large UAS Laws (2020) Unmanned Traffic Management (2019) Beyond Line of Sight (2018)

23. UAS Enforcement or How to stop the UAS Invasion

24. How do drones cause problems for Universities? Improperly used drones are a hazard Drones flying over or near people Injuries range from superficial to severe Annoyance or a distraction to drivers Damage to personal property Cars are frequent targets Damage to University property Air conditioning units, power lines Harassment of wildlife or sensitive ecosystems Accidents happen! But not everyone is a willing target 24

25. How do drones cause problems for Universities? Drones can be used inappropriately Trespass Invasion of Privacy Harassment Insurance and Exposure Issues The UC has UAS insurance to limit exposure But only on properly registered or approved by the insurance underwriter 3 rd party UAS user commonly do not have insurance Interference with UC business Medical helicopters Wildfire Support Campus Events Authorized UC UAS activity 25

26. UAS Enforcement The FAA claims sole jurisdiction of airspace Universities may not regulate FAA airspace, but they may put in place policies regarding use of UAS on their campuses Laws and Policies traditionally related to state/local police power – including land use, zoning, privacy, trespass can be implemented. Some examples A University may install a policy that states no one may operate a UAS on UC property A University may state that no aircraft is allowed to take off or land on University property (National Parks use this) State of California has put into law that laws against invasion of privacy is extended to the use of aircrafts 26

27. Word of Caution A full-ban on UAS activity has unintended consequences Recommend oversight to enable university uses and minimize outside use Education and outreach is key Most people will understand that there are certain boundaries Work with constituents for compromise

28. What to do if you suspect unauthorized UAS activity? 1.Locate the operator 2.Ask for registration and verify markings on the UAS 3.Ask operator for the type of operation and to present appropriate documentation 4.Interview operator and collect the following information 1.Name, address and positive ID of owner 2.Record registration number and the Exemption or COA 3.Document time, place and details of flight 5.Take action based on local Laws, Ordinances, Directives 6.Contact the FAA 1.General Inquiries – Regional Operations Center 2.Investigative Support – Contact FAA Law Enforcement Assistance Program 28 Hint: People always fly drones back to them Details in a separate handout

29. What are the most common violations? Model Aircraft The aircraft must not interfere with manned aviation (101.41(d)) No person may operate model aircraft so to endanger the safety of the national airspace system (101.43) Shall avoid flying directly over unprotected people, vessels, vehicles or structures (AMA Safety Code) Shall avoid endangerment of life and property of others (AMA Safety Code) No powered model may be flown outdoors closer than 25 feet to any individual except for the pilot and pilot helpers. (AMA Safety Code) The pilot shall (a) maintain control during the entire flight, maintaining visual contact without enhancement (AMA Safety Code)

30. What are the most common violations? Part 107 The RPIC, owner or person manipulating the flight controls must make available (1) the remote pilot certificate and (2) any other document, record, or report required to be kept (107.7) No person may operate a SUAS unless it is in a safe condition for flight. Prior to each flight, the RPIC must check the SUAS condition (107.15) The RPIC must ensure that the SUAS will pose no undue hazard to other people, other aircraft, or other property in the event of a loss of control of the aircraft for any reason (107.19 (c)) No person may (a) operate a SUAS in a careless or reckless manner so as to endanger the life or property of another or (b) allow an object to be dropped from a small unmanned aircraft in a manner that creates an undue hazard to persons or property.

31. What are the most common violations? Part 107 The RPIC, VO, and person manipulating the flight controls must be able to see the SUAS throughout the entire flight in order to: (107.31) Know the unmanned aircraft’s position Determine the unmanned aircrafts attitude, altitude and direction of flight Observe the airspace for other air traffic or hazards and Determine that the unmanned aircraft does not endanger the life or property of another No person may operate an unmanned aircraft over a human being (107.39)

32. Types of Authorized UAS Ops and Required Documentation Commercial (Part 107) Aircraft Registration and Markings Remote Pilot Certificate with SUAS Rating FAA UAS Registration only is not accepted Approved Waiver from ATC (if near airport) Public/Government Certificate of Authorization (COA) Aircraft Registration and Markings 32 Details in a separate handout

33. Back to the UC

34. UC UAS Activity How many UAS does the UC system have? According to UCOP Risk Services – 73 According to my list – 130 The true number ~ 200-300 Where are the UASs flown? According to the FAA – only in Davis and Merced since 2009 According to the news media – All over the US and the world How many illegal UAS flights are being done by our UC students/faculty and staff? 34 The UC has a UAS problem!

35. What’s going wrong? Lack of knowledge of UAS regulations Don’t blame recent changes! – UAS have been heavily regulated since 2005 Recent changes have only decreased the number restrictions (by adding more alternative process with new rules) Affects both for end-users and the campus administrators Lack of value-added oversight Current reporting mechanisms offer no improvement to regular use Hard to encourage buy-in 35

36. “Legal” ≠ “Safe” Just because you follow the letter of the law does not mean that you are guaranteed to be safe

37. Aviation Safety Management FlyCrashFix Risk Index Historical Data Incident Severity Even in model-building analysis, we still utilize statistics and probability to derive our risk management analytics

38. Aviation Safety Management FlyCrashFix Risk Index Historical Data Incident Severity Even in model-building analysis, we still utilize statistics and probability to derive our risk management analytics Unmanned Aircrafts have no historical data and technology developments far outpaces data collection effectiveness

39. Introduction to Safety Management Systems Ensuring safety with Unmanned Aircrafts requires a different approach that 1.Incorporates a dynamic risk management systems 2.Has built in mechanisms for improvement and 3.Scales appropriately to risk The FAA has spent the past decade developing what is now known as Safety Management Systems (2006)

40. UAS Safety Management System Safety Policies Policies establish the organizational hierarchy and responsibilities at each level. They establish oversight requirements and processes to meet safety goals Safety Risk Management Provides a workflow for a formal process to describe the system, identify hazards, assess risk, and control/minimize risk. Safety Assurance Enable the evaluation of the effectiveness of risk management strategies and ensure compliance with other oversight entities, including the FAA, the Center, and OPRM. Safety Promotion Educational outreach on UAS policies and FAA regulations, training on UAS Risk Management and Safety Assurance. Developing a safety culture at all levels of UAS operations. Details in a separate presentations

41. Effective Policies System-wide Policies Campus Policies Department Policies Minimum Standards for Authorizations and Reporting Advisory Board for reviews and audits Use of campus grounds, resources Training and usage requirements Policy enforcement Equipment use Reporting compliance

42. Safety Risk Management Safety requires effective practices in managing risk from The Aircraft The Environment The Human Details in a separate presentations

43. Safety Assurance Safety Risk Management and Safety Assurance are two separate processes But they must be able to share information We need a tool to make this effective

44. Introducing the UC UAS Fleet Management System 44

45. UC UAS Fleet Management System UAS Infrastructure to enable UC flights Students, Researchers, Staff Recreational and Education Administrative Oversight Organized/Consistent interpretation of UAS regulations Automated systems for keeping track of UASs, pilots and flights Built-in safety metric analysis 45

46. End-User Value-Added Experience Having to figure out new laws Where can I fly? Keeping track of the condition of aircraft Keeping track of hours of flight time Remembering what the correct operating procedure is Checklists! Forgot to arm the plane before launching it  Reporting to the FAA Reporting to administrators Did I charge the batteries? Why did it crash? Forgetting to pack all the things Cows! How many flight hours do I need before I’m qualified? Who do I call if something goes wrong? Do I need to tell the FAA is the UAS crashes? What do I need to tell the FAA? Too much air traffic 46 Common Issues of End-Users

47. Common Themes Keeping track of things Automating the workflow Providing clarity on regulations 47 Providing a system that does these things will eliminate 90% of all UAS issues

48. UC UAS Fleet Management System Single portal system for all UAS activity 1.Enter the aircraft and pilot 2.Check airspace 3.Fly 4.Report Aircraft/Pilot/Crew hours are automatically updated Airspace, weather, air traffic and other conditions can be checked instantaneously Can automatically prepare necessary checklists and flight instructions 48 Integrated into the UC’s Safety Training System

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50. End-User Benefits Clear workflow guides all (new and experienced) users into the correct process Minimize processing dead-ends, missing approvals, improve planning efficiency Federal laws, UC policies built into the workflow Researchers can focus on their research and projects, and not have to figure out laws Automatic tracking of UAS usage and crew operation Enables accurate maintenance scheduling, documented crew qualifications Enables customizable processes for improved planning Automated weather planning Automated generation of in-field checklists, planning checklists, flight logs Simple generation of usage reports Fulfills FAA reporting mandates, painless reporting to administrators Integrated into the UC’s Safety Application system Tied into system authentication – Use your own UC log-in information Enables privacy control or transparency 50 A little bit of data analytics can go a long way What are the most common UAS platforms? Who does the majority of the flying? How many tests flights are typically taken before mission flights? What are the most common UAS issues? A little bit of data analytics can go a long way What are the most common UAS platforms? Who does the majority of the flying? How many tests flights are typically taken before mission flights? What are the most common UAS issues?

51. Improving UAS Safety in the UC System The UC system must be organized and forward thinking for UAS safety Build an infrastructure in management and safety The UC will have students, researchers and staff all actively looking to do UAS flights both on their campuses and all over the state The airspace around all UC campuses are complex Each campus will have a multitude of activities and large crowds 51

52. Safety Risk Management Flight Planning/Request analyzes input data for initial risk assessments Airspace considerations Weather alerts Aircraft/Crew assessments Reminds operators to be mindful of other hazards Reminds operators to take required documentation, including registrations and preflight checklists

53. Safety Assurance Effortless compliance with FAA regulations and UC policies Promotes effective record-keeping End-users will monitor wear on components Administrators will monitor UAS activity and safety risks Analyze trends in real-time Helps build a better understanding of UAS activity and risks

54. 54 UAS Management with AIRMAP Integration of Airspace class layers into Flight Request Enables automatic flight request authorizations depending on airspace Removes the potential for misreading VFR charts Improves awareness of operators

55. Total UAS Safety Solution (Under Development) 55 UC Fleet Management UAS Monitoring Service UAS Monitoring Service Airport Notification UC Operators UC Campus & Public Safety Non-UC Operators UC Risk Management Enables UC Campus & Public Safety with improved awareness of all UAS activity on their campuses

56. 56 The problem isn’t that this is going to be difficult…. The problem is that this is coming to our campuses very soon The problem isn’t that this is going to be difficult…. The problem is that this is coming to our campuses very soon

57. In 10 years! How many drone deliveries are you going to allow simultaneously? Who will decide who has authorization to record football practices? What happens when the police want to use a UAS to monitor a crowd? What are all the drone startups going to do? Will the drones crash into each other in flight? Will there be an airborne Uber or Lyft? 57

58. Questions? 58 Email: bstark2@ucmerced.edubstark2@ucmerced.edu UASSafety@ucmerced.edu http://tinyurl.com/UC-UAS-COE http://uassafety.ucmerced.edu/ Phone: (209) 201 - 2051 Facebook page: https://www.facebook.com/UC.UAS.Safety/ Please sign up for the UC UAS Listserves if you’d like to be kept in the loop of the latest developments Other Presentations: UAS Safety Management System SUAS Remote Pilot Certificate Exam Drones for Student Clubs Drones for Researchers Drones for Staff