In a recent DRONERESPONDERS webinar, FAA SOSC’s Kerry Fleming explains the SGI exemptions and how they work for small UAS operators.
A Conversation About Public Safety UAS – Information You Don‘t wanna miss you
By: Dawn MK Zoldi, guest author
That year, the nonprofit DRONERESPONDERS hosted a free monthly webinar series entitled “A Conversation About Public Safety (UAS”) hosted by Director Charles Werner with Michael O’Shea, Program Manager at Unmanned Aircraft Systems Integration Bureau (UAS ) at the Federal Aviation Administration (FAA). Other FAA guests regularly join the duo.
You don’t have to be in public safety to benefit from this interactive and informative series.
This month, Kerry Fleming of the FAA System Operations Support Center (SOSC) spoke about the Special Government Interest (SGI) exemptions for small UAS operators under Part 107 and those operating under a Certificate of Waiver or Authorization (COA).
SGIs apply to time-critical life-saving operations with unmanned aerial systems (UAS) that “cannot be performed quickly or conveniently any other way”. The FAA website lists some of these emergencies, including fire fighting, search and rescue, law enforcement, restoration of utilities or other critical infrastructure, damage assessments to support insurance claims related to disaster recovery, and media coverage that provide vital information to the public . These approvals can be life or death and are always fact specific. For this reason, the SOSC operates 24 hours a day, 7 days a week, 365 days a year.
According to Kerry, his team has a “get to yes” mentality. However, there are a few operations that typically mean “no” as part of the SGI process:
- education – Exercise is almost never seen as an emergency, even if good exercise could ultimately save lives. The “time critical” and “life saving” requirements are a must.
- Routine maintenance – The pre-planned maintenance of critical infrastructures is usually not part of the SGI process. However, if a node (e.g. a power grid) is about to fail and an inspection is required to prevent it, call the SOSC for action
- Not imminent situations – When an expected event (e.g. an expected turbulent protest that could lead to a riot) is a week away, use the FAA’s DroneZone. If a fire is happening right now, that’s a different story. A good rule of thumb is to ask yourself: will this happen in the next hour, or within a few hours?
- Flat rate permits for all crime scenes – That’s a no too. The reality is that air traffic control, other National Airspace System (NAS) operators, and the FAA need to know who is where and when in the airspace. Blanket permits defeat this purpose because they are too general. For example, a rescue helicopter pilot should be sure not to run into a UAS while ascending or descending.
- Wide area approvals for longer periods – The FAA team requests that requests be appropriate. Kerry was discussing a Midwestern requester during a recent snow storm that requested 90 square miles of cover. The answer “yes and” was a common workaround for creating multiple and sequential permits for areas with smaller footprints.
The SOSC deals with problems on a case-by-case basis. Kerry advises, “Give us a call and tell us about the situation and your needs. Let’s figure out the airspace issues, talk to air traffic control and get them authorized and approved. We will try to do this as soon as possible. “In some cases, the SOSC can even get verbal approval in as little as five minutes, followed by the right documentation.
How exactly this paperwork will look depends on the situation. Kerry stated that the SOSC can facilitate emergency UAS operations over people or at night for Part 91 COA holders. They can also assist with an SGI with Tactical Line of Sight Out of Sight (TBVLOS) for Part 107 users, which allows flights up to 1,500 feet and less than 50 feet above the ground. Operations are also possible beyond the visual line of sight (BVLOS). Kerry stated, “BVLOS means it is a larger area, so we need to put in place a Temporary Flight Restriction (TFR) to protect the airspace.”
TFRs can only be requested by national defense, national security, and federal intelligence and federal agencies. However, other government or private entities may ask these agencies to sponsor a TFR in critical locations. The federal sponsor must create a threat matrix so that the FAA can determine whether a TRF is appropriate. If so, the sponsored party will need an SGI to fly within that TFR. TFRs tend to persist, as in the case of recent western forest fires and hurricanes in the south.
For more information on the SGI process, see the FAA SGI Handbook and Public Safety and Small Drones Playbook. For general UAS questions, start with FAA help. Contact the SOSC with details. Of course, the DRONERESPONDERS website is also full of information. To take advantage of these and other helpful resources, join DRONERESPONDERS. Membership is free and open to everyone.
Key references include the FAA Joint Order (JO) 7200.23B, Handling Unmanned Aircraft System Requirements, Circular (AC) 91-63D, Temporary Flight Restrictions and Restrictions, and for Public Aircraft Operators (including those who work with contractors). AC 00-1.1B, Public Aircraft Operation – Information on Manned and Unmanned Documents.
DRONERESPONDERS webinars will be videotaped for later review. Registration is required for the live events. The next will take place on April 14, 2021 at 4:00 p.m. EST US. Join this rewarding series now! If you have any questions, please contact: [email protected].
Dawn MK Zoldi (Colonel, USAF, retired) is a licensed attorney with 28 years of active military and federal service in the Air Force Department. She is an internationally recognized expert on the law and politics of unmanned aircraft systems, columnist for Law-Tech Connect ™ for Inside Unmanned Systems magazine, recipient of the Woman to Watch in UAS (Leadership) Award 2019 and CEO of P3 Tech Consulting LLC. You can find more information on their website at: https://www.p3techconsulting.com.
Miriam McNabb is editor-in-chief of DRONELIFE and CEO of JobForDrones, a marketplace for professional drone services, and a fascinating observer of the emerging drone industry and the regulatory environment for drones. Author of over 3,000 articles focusing on the commercial drone space, Miriam is an international speaker and recognized figure in the industry. Miriam graduated from the University of Chicago and has over 20 years experience in high-tech sales and marketing for new technologies.
For advice or writing in the drone industry, email Miriam.
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