The Responsibility of UAS Self-Certification by Charles L. Werner, EFO/CFO/CIPM
Unmanned aircraft systems (UAS) in the public safety environment have already documented some very significant use cases. These scenarios include structural firefighting, wildland firefighting, hazardous material responses, search and rescue, flood rescues, technical rescues, shark patrols, inspection of critical infrastructure, forensic traffic investigation, delivery of medicine to underserved communities and more.
Until recently, a public safety UAS operator was required by the Federal Aviation Administration (FAA) to be a certificated pilot or completed flight ground school and possesses a Class 2 medical physical. This was extremely limiting to public safety organizations, especially those that had already identified ways they could implement UAS into their emergency operations. Comparatively, a drone hobbyist had more freedom to fly than a public safety agency.
Within the past couple of months, the FAA has made some changes with respect to UAS self-certification as it relates to public aircraft operations (PAO). At recent panel discussions, personnel from the FAA’s UAS Integration Office advised that public aircraft operations can self-certify airworthiness, pilot, aircrew (observer), maintenance personnel and training as outlined in FAA document 8900.1 Volume 16 Unmanned Aircraft Systems, which states:
“FAA-Recognized Equivalent - An FAA recognition that a public agency may exercise its own internal processes regarding airworthiness and pilot, aircrew, and maintenance personnel certification and training; furthermore, the agency has determined that its UAS is capable of safe operation in the National Airspace System (NAS) when conducting public aircraft operations under Title 49 of the United States Code (49 U.S.C.) §§ 40102(a)(41) and 40125.”
While this certainly eases the limitations on public safety requirements for UAS operator certification, it comes with significant uncertainty and a tremendous level of responsibility and liability. Since public aircraft operations fall under the jurisdiction of a town, city, state or federal agency, it is imperative that the appropriate actions are taken to ensure that self-certification for airworthiness, pilot, aircrew, maintenance and training is taken seriously and that appropriate instruction and flight proficiency is in place before any UAS missions are conducted.
There are certain aspects of UAS operations which must be understood. In May 2016, I was one of the instructors that taught the first Unmanned Aircraft Vehicles for Emergency Responders course taught at Piedmont Virginia Community College. The course was broken down into 5 major areas which included FAA knowledge