Unmanned Aerial Vehicles/Systems (UAV/UAS) may be known by a number of names, to include model aircraft, drones, or remote-piloted aircraft (RPA). UAV/UAS operators include aviation hobbyists, as well as commercial operators who wish to use new and emerging technology in more creative ways to satisfy consumer demand. In the United States, and on an international scale, aviation regulatory bodies (such as the US Federal Aviation Administration) are under increasing pressure to expedite the integration of drones into the national airspace system (NAS). Several countries, such as Canada and Australia, have already enacted regulations governing UAV/UAS operation in the interest of public and aviation safety.
In the United States, while much of the attention on UAV/UAS activity has been focused on the potential dangers drones present to commercial airlines, most notably to airliners taking off from and landing at major airports. While those dangers are real and deserve serious discussion, it is important to note there are many more segments of the aviation community that may be affected by drones (e.g., air medical transport providers, general aviation operators, law enforcement, business transportation, etc.). Those segments often operate at low-altitudes, and in many cases, well away from an airport setting. The dangers posed to low-level aviation environments are just as great, or perhaps greater, than those posed to commercial airlines that conduct flights within the confines of pre-approved flight plans, in controlled airspace, and in approved approach path and airport traffic areas, under the guidance of air traffic control.
Emergency responders, on the ground and in the air, are discovering the presence of UAV/UAS with increasing frequency, creating unique safety and operational concerns. Those encounters, during the course of emergency medical transport operations, pose a safety risk to our flight crews and our Emergency Medical Services (EMS) personnel and delay getting patients-in-need to the appropriate healthcare facilities. When adapting federal regulations to the emerging UAV/UAS enterprise, the safety of all aviation operations, the safety of emergency responders and patients, and the right to privacy of healthcare providers and patients-in-need must be paramount considerations.
The ability of piloted aircraft to see small UAV/UAS in ample time to avoid them cannot be presumed. UAV/UAS are simply too small, are often traveling too fast, and are virtually invisible. Therefore, the responsibility to see and avoid must also rest with the UAV/UAS operators and reasonable separation requirements must be established. Future legislation should require UAV/UAS be equipped with systems that maintain established separation requirements, between the UAV/UAS and any other aircraft, without operator input.
As such, the Association of Air Medical Services (AAMS) believes the following regulatory requirements would allow for integration of UAV/UAS into low-level airspace while optimizing the safety and privacy of emergency personnel and patients in need of assistance:
1) During the course of any emergency incident (i.e., EMS, search and rescue, law enforcement, fire prevention/suppression, HAZMAT management, etc.), no UAV/UAS may be operated within a 5 mile radius of the incident site. Exemptions to this are only allowed for UAV/UAS operations considered essential to incident management, and only when authorized by, and coordinated by, the specific incident command authority.
2) At any time rotary-wing or fixed-wing aviation assets are part of emergency operations (e.g., air medical transport, search & rescue, law enforcement surveillance, fire operations, etc.), UAV/UAS separation is essential to optimize safety for emergency aviation operations. No UAV/UAS will be allowed to operate within 5 miles of the perimeter of any emergency aircraft operations.
3) At any time emergency aircraft are arriving, departing, or otherwise occupying any airport, heliport, helispot, or any emergency landing zone (ELZ), UAV/UAS are prohibited from operating within a 5 mile radius of these sites.
4) In the event of an unforeseen encounter with rotary-wing or fixed-wing aircraft, the UAV/UAS operator will immediately take action to both “see and avoid” and yield right of way to said aircraft, as a component of deliberate action to create maximum separation between UAV/UAS and traditional aircraft.
5) UAV/UAS operating within Federal Aviation Administration defined controlled or uncontrolled airspace shall be operated only during Day Visual Meteorological Conditions (VMC), with a visibility minimum of 3 statute miles, cloud clearance requirements of 2,000 feet in any direction, and at no time should they operate above a cloud layer while being operated in the National Airspace System.
6) All UAV systems should be required to include technology to allow other aircraft to identify the UAV from a safe distance through Automatic dependent surveillance – broadcast (ADS-B) technology.
7) To protect a patient’s rights to privacy, at no time shall UAV/UAS be utilized to record video footage of nonemergency personnel (i.e., medical or trauma patients) without the prior written consent of these individuals.
8) Legislative bodies (e.g., the US Congress) should consider legislative action to provide for appropriate enforcement action against UAV/UAS operators who create a hazard to safe emergency operations by not following these guidelines.
As additional research is conducted to develop and implement technologies to prevent encroachment of UAV/UAS into designated sensitive airspace, the FAA (or the appropriate regulatory bodies of other countries) and UAV/UAS manufacturers and programmers should work with stakeholders to ensure these technologies are both compatible with technologies currently being used in emergency response aircraft and are inclusive of emergency management concerns.
We recognize both the utility of UAV/UAS for commercial purposes and the recreational activities of hobbyist UAV/UAS operators. By working together we can integrate UAV/UAS into the national airspace appropriately while ensuring the safety and privacy of our emergency personnel and the patients we serve.
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