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https://www.wmata.com/about/news/Metro-closing-time-change-June-2-2020.cfm

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Product of the JMA iLAB small-Unmanned Aircraft System (sUAS) & UAS Traffic Management (UTM) Working Group 

March 2020 

Introduction 

JMA Solutions, LLC (JMA) through its research and development enterprise, JMA Innovation Lab (iLAB), submits these comments in response to the request for public comment for the Federal Aviation Administration’s (FAA) notice of proposed rule making action in regards to requiring remote identification of UAS. 

The accelerated growth of sUAS technology, its wider availability and growing use case portfolio has led to the adoption of sUAS by many entities, including public safety agencies, state and local governments, commercial entities and recreational flyers. Given the accelerated quantity of UAS available and flying, and questions surrounding how they can be safely integrated into the national airspace system (NAS), FAA’s efforts to propose rules on the development, deployment and regulation of remote identification in UAS is necessary. 

JMA has been a leading contributor to the Federal Aviation Administration’s (FAA) efforts to integrate UAS into the National Airspace System. JMA’s work has involved leading practices in air traffic management, UAS Traffic Management (UTM) policy, Beyond Visual Line of Sight (BVLOS) guidance, Safety Management System (SMS) development, and both internal/external communication strategies to safely and efficiently integrate UAS into the NAS. 

JMA iLAB’s public comment for the FAA’s Remote ID notice of proposed rule making is based on the aforementioned FAA air traffic management and UAS experience. In addition, JMA iLAB members have collaborated with a broad spectrum of UAS stakeholders through participation in several standard setting bodies, including CANSO, Drone Responders Public Safety Alliance, the ANSI UAS Standardization Collaborative, the National Public Safety Telecom Council, InfraGard and International Emergency Drone Organization. 



Member

ATFM WG
UAS Emerging Tech WG
UAS/UTM Task Force

 Advisor

Drone Responders Public Safety Alliance

 Member

ANSI UAS Standardization Collaborative (UASSC)

 Member

National Public Safety Telecom Council UAS & Robotics WG

 Chair

InfraGard UAS Integration into Critical Infrastructure WG

 Member

International Emergency Drone Organization

 

 

In 2019, JMA iLAB published a white paper for the public safety community titled “Application, Implementation and Management of sUAS by Fire Rescue.” Subsequently, JMA iLAB published an article in a leading fire service publication, Fire Rescue 1 magazine, called “Eyes in the sky: How firefighters can use drones during all-hazards incidents.”

The implementation and justification of remote ID for UAS is very often, and accurately, compared to that of license plates on automobiles. In this case all vehicles must be identifiable by entities including, but not limited to, law enforcement and regulatory agencies. Owners must register vehicles with a motor vehicle authority in their state of residence in order to receive a license plate, which then connect vehicle owner information to that identifier (license plate). This information is relatively well kept private and normally only accessible to law enforcement. 

Unmanned vehicles should also have an identifier announcing their presence to law enforcement, regulatory authorizes such as the FAA and other participating sUAS. Therefore, owners of specific drones should register each aircraft and have a unique identification attached to them. This is the basis for development of a UAS Traffic Management System. 

Problems and Challenges Addressed by Remote ID 

Public safety, national security and law enforcement concerns involved both the existence of two groups of aircraft operators, bad actors and unknowing actors. Bad actors wish to intentionally and negatively impact the safety and security of the homeland. In contrast unknowing actors unintentionally, through lack of technical skills or regulatory knowledge, negatively impact the safety and security of the homeland. Both require immediate attention and an appropriate official response. 

For example, during the course of several emergency responses to structural fires and natural disasters requiring the deployment of traditional aircraft, the presence of unidentified UAS have led to grounding of such air assets. This has negatively impacted rescue or suppression operations. The operators of those drones were likely unknowing actors, not realizing the significant consequences of their actions. In other examples, mysterious drone sightings have been reported over cities, with calls to law enforcement. Not having the ability to identify the purpose of these flights creates a general feeling of insecurity in communities. Remote ID adoption would allow authorities the ability to identify operators and when appropriate inform or deliver consequences. 

Bad actors may intentionally weaponize drones or simply use dangerously close flying to cause severe interruptions. There are arguments to be made that the history of drones in the United States does not point to any major breaches to national security or safety. While this is true, it does not mean that the potential does not exist. A failure of imagination was cited by the 9/11 Commission as one of the failures in preventing that attack, where no one had imagined airplanes would be hijacked and used as missiles flown into important sites. The intentions of bad actors cannot be mitigated with remote ID. However, the ability to identify assets in increasing complicated airspace through broadcast with the added possibility to connect a drone with a bad actor operator is a valuable tool for law enforcement. 

Questions to consider for improvement of the remote ID notice of proposed rule making: How will law enforcement be able to access remote ID data in order to identify drones? How quickly will the data be available? Who will be the ultimate responsibility of remote ID information (which is also shared with third parties)?

Privacy 

While there are many questions on privacy and the use of drones, remote ID and the proposed rule making does present some new aspects of privacy protection. Remote Identification UAS Service Suppliers (Remote ID USS) will be tasked with providing the services to maintain registrations and tracking of broadcast or network signals. 

Questions around privacy to consider: What information will be made available to the general public by the Remote ID USS? Will the Remote ID USS host personal and private information on aircraft owners, or will the FAA be responsible? 

Following the comparison to cars and license plates, motor vehicle authorities keep owner information and only make it available to law enforcement and other regulatory bodies with proper cause. Fellow drivers cannot identify the registration information of a vehicle, but simply reading a license plate. In aviation, there is an additional use case that flying objects should be identifiable through use of a transponder or other broadcast signal. This should be the case for other UAS operators looking at a map of active UAS. 

Remote ID as a Next Step 

Remote ID is the necessary next step in the safe integration of UAS into the NAS. It is also the next step required to enable the development, regulation and implementation of other technologies and procedures to further assist safe integration. These include detect-and-avoid technologies, beyond visual line of sight (BVLOS) operations and UAS Traffic Management.

Washington, DC, February 11, 2019: JMA Solutions, LLC, donates $3,000 to the Strategy for Mentoring Initiative and Leadership Empowering (S.M.I.L.E) Organization to support their Youth Mentoring Program and other philanthropic efforts. S.M.I.L.E’s unique program model is crafted strategically by leaders within the community to ensure youth are provided with proper learning tools and resources to ultimately transfer knowledge back into the community.

“JMA Solutions is proud to support and further our commitment to S.M.I.L.E in ensuring young leaders around the world are supported, uplifted and empowered to achieve their dreams and become agents of change.” said Jan Adams, President and CEO.

In addition to the Youth Mentoring Program, S.M.I.L.E hosts numerous programs and volunteer efforts to ensure no youth is left behind. In 2019 alone, S.M.I.L.E trained 391 young leaders across 14 secondary schools, awarded 13 college scholarships, equipped 68 youth with lucrative skills through their summer skill acquisition and digital literacy program, donated 10 desks and chairs to a school and hosted 82 organizations and 200 attendees at the International Youth Day.

About S.M.I.L.E

Strategy for Mentoring Initiative and Leadership Empowerment (S.M.I.L.E) is a youth leadership development and mentoring non-profit organization established in Lagos, Nigeria in 2011 (S.M.I.L.E) and in Maryland, United States of America in 2017 (S.M.I.L.E Initiative).

S.M.I.L.E is an Associate of the United Nations Department of Public Information/NGO, New York and in Special Consultative Status with the Economic and Social Council since 2017.

About JMA Solutions 

Headquartered in Washington, DC, JMA Solutions is an award-winning government consulting firm with over fifteen (15) years of experience delivering outstanding customer support. Since 2005, we have provided customer support for Air Traffic ManagementProgram ManagementSafety Management Systems for UASCommercial Unmanned Aircraft SystemsRadar and Communications Support and much more!

 

Washington, DC, February 3, 2020: The JMA Innovation Lab (iLAB) is proud to announce its participation as "friend of a committee” to four Transportation Research Board (TRB) Standing Committees. The four standing committees include Aviation Security and Emergency Management, Safety Data Analyst and Evaluation, Transportation Safety Management Systems and the Task Force on Transit Safety and Security.

“The JMA iLAB’s mission to provide innovative research-based solutions to solve complex challenges for government, corporations and individuals aligns perfectly with the mission of the TRB. We’re very excited to contribute to transportation safety and security research.” said Tony Tisdall, VP of Global Affairs and Aviation Solutions.

As defined by the TRB, a “friend of a committee” is someone who can attend committee meetings and participate in the same activities as committee members. Examples of committee activities include:

·      Exchange information about best practices, professional development, networking, and mentoring.

·      Peer review papers for the TRB Annual Meeting.

·      Peer review papers for the Transportation Research Record.

·      Plan lectern and poster sessions at the TRB Annual Meeting.

·      Author or contribute to TRB publications.

·      Plan TRB webinars.

·      Draft research needs statements and problem statements for TRB projects.

·      Hold committee meetings at the TRB Annual Meeting.

·      Plan specialty conferences.

For more information about this announcement and the JMA iLAB, please contact Bear Afkhami, Director of Innovation and Development, via phone 202-465-8453, or via email at mahssanThis email address is being protected from spambots. You need JavaScript enabled to view it.

About JMA Solutions Headquartered in Washington, DC, JMA Solutions is an award-winning government consulting firm with over fifteen (15) years of experience delivering outstanding customer support. Since 2005, we have provided customer support for Air Traffic Management, Program Management, Safety Management Systems for UAS, Commercial Unmanned Aircraft Systems, Radar and Communications Support and much more!

 

JMA Solutions, LLC (JMA) through its research and development enterprise, JMA Innovation Lab (iLAB), submits these comments in response to the request for public input for the next edition of the National Fire Protection Agency’s (NFPA) Standard for Small Unmanned Aircraft Systems (sUAS) Used for Public Safety Operations (NFPA 2400). 

The accelerated growth of sUAS technology, its wider availability and growing use case portfolio has led to the adoption of sUAS by many public safety agencies. At times, purchasing of sUAS for use in public safety operations has overtaken the speed at which their jurisdictions can engage the community and develop policy and regulations on safety, quality standards, training, privacy and other issues. For this reason, and a lack of broad set of standards for the integration of sUAS in public safety agencies, NFPA 2400 is a necessary tool in detailing minimum requirements for the safe operation, deployment, and implementation of sUAS in public safety. 

JMA has been a leading contributor to the Federal Aviation Administration’s (FAA) efforts to integrate UAS into the National Airspace System. JMA’s work has involved leading practices in air traffic management, UAS Traffic Management (UTM) policy, Beyond Visual Line of Sight (BVLOS) guidance, Safety Management System (SMS) development, and both internal/external communication strategies to safely and efficiently integrate UAS into the NAS.

JMA iLAB’s public input for NFPA 2400 is based on the aforementioned FAA air traffic management and UAS experience. In addition, JMA iLAB members have collaborated with a broad spectrum of UAS stakeholders through participation in several standard setting bodies, including CANSO, Drone Responders Public Safety Alliance, the ANSI UAS Standardization Collaborative, the National Public Safety Telecom Council, InfraGard and International Emergency Drone Organization.

Member

ATFM WG
UAS Emerging Tech WG
UAS/UTM Task Force

 Advisor

Drone Responders Public Safety Alliance

 Member

ANSI UAS Standardization Collaborative (UASSC)

 Member

National Public Safety Telecom Council UAS & Robotics WG

 Chair

InfraGard UAS Integration into Critical Infrastructure WG

 Member

International Emergency Drone Organization

In 2019, JMA iLAB published a white paper for the public safety community titled “Application, Implementation and Management of sUAS by Fire Rescue.” Subsequently, JMA iLAB published an article in a leading fire service publication, Fire Rescue 1 magazine, called “Eyes in the sky: How firefighters can use drones during all-hazards incidents.”

Technical Input

JMA iLAB’s public input proposes revisions and/or additions to NFPA 2400 Chapter 4 - Organizational Deployment and Chapter 6 – Maintenance of sUAS.

Chapter 4 Section 4.3.2 – Program Criteria Proposed Changes

Prior to implementing an sUAS program, public safety entities shall adopt a comprehensive Safety Management System (SMS) policy document with consideration to FAA Directives and International Civil Aviation Organization (ICAO) Standards and Recommended Practices (SARPS). The SMS policy document will address the following:

1.     Public safety organization’s objectives

2.     Methods and means of achieving objectives

3.     Reporting requirements and timelines

4.     Documentation of accident/incidents

5.     Emergency Response procedures

6.     An effective Safety Risk Management process

7.     Personnel qualifications, training, and certifications

8.  Critical Incident Safety Management program

9.  Data management

10.  Corrective action procedures

11.  Audit procedures and results reporting

12.  Promotion of safety culture through communication and training

13.  Care and maintenance of the aircraft, systems, and equipment

Statement of Problem and Substantiation of Public Input

Based on our experience in providing safety management systems and safety risk management policy assistance to the FAA, to public safety agencies, as well as in consideration of key findings published by AIRT Drone Responders, we believe that the public safety community would be more effectively served by adopting the SMS/SRM guidelines as outlined by FAA directives and ICAO practices.

The SMS process is a standard practice within the aviation community. Following the SMS process provides transparency, accountability and increased stakeholder engagement while addressing critical elements of sUAS integration as outlined in the list above.    By doing so, public safety agencies will increase public trust, establish valuable policies and procedures and overall program management standards that will result in a safe, well regulated, publically accepted sUAS program. 

A December 2019 study by Drone Responders concluded that "most agencies possess marginal bench strength with limited operational experience for their remote pilot corps." The same report went on to conclude that "a neglect of regimented firmware checks/updates is posing a potential safety risk for a sizable portion of public safety UAS operations," and that more than 1 in 10 public agencies are not officially reporting or documenting UAS-related accidents or mishaps." We firmly believe that the adoption of SMS policy documents as a requirement to operate a UAS program will address all of these problems.

An SMS is not a difficult technical document to put together and we do not believe that an excessive burden will be placed on public safety.

Chapter 4 Section 4.6 – Accident Incident Response (AIR) Proposed Addition

ACCIDENT INCIDENT RESPONSE (AIR)

The public safety agency will adopt an AIR document in cases of an accident or incident such as lost link, battery failure, pilot deviation, accidents, crashes, etc., containing the following:

           1. Procedures to immediately cease further operations

           2. Required preliminary reporting criteria

           3. Notification tree

           4. Minimum preliminary data required (e.g. date, time, locations, PIC and other crew members, mission number and description, vehicle ID, damage assessment,

           5. Meteorological conditions and verbal description of event including witnesses

           6. Preliminary reporting time parameters

           7. Process for assignment of Chief Investigator/Investigation Team

           8. Timeline for completion of investigation

           9. Timeline for completion of final report

Statement of Problem and Substantiation of Public Input

These accident reporting standards are currently mandated by FAA directives and would align public safety sUAS operations with other aircraft operations within the National Airspace System. It is important for public safety to understand that both accidents and incidents must be documented as part of a safety culture in order to improve operations.

Accidents are easily identifiable when an air asset collides or crashes. However, incidents such as lost link with an sUAS, pilot error or an sUAS deviating from a programmed flight must formally be documented. Documentation and investigation mitigates future accidents and incidents.

Chapter 6 Section 6.2.5 – Program Criteria Proposed Changes

6.2.5  

As part of the maintenance program, the public safety entity shall have procedures for service for the following:

1.     Routine cleaning

2.     Decontamination

3.     Maintenance necessary due to operational applications

4.     Maintenance necessary due to operating environment

5.     Storage requirements

6.     Firmware checks/updates

Statement of Problem and Substantiation of Public Input

According to study done by Drone Responders in December 2019, 40% of responding public safety agencies are not performing regimented firmware and cyber security updating of their sUAS fleet. This presents a risk for malfunction in operation and poses a threat to overall information technology systems of the public safety agencies.

Principal Authors

Tony Tisdall has over thirty-five years of experience in air traffic control and air traffic flow management and has served as air traffic manager at the FAA’s Air Traffic Control System Command Center (ATCSCC) in Warrenton, Virginia. He is currently Vice President of Global Affairs and Aviation Solutions at JMA Solutions.

Bear Afkhami has over 10 years of service in the emergency services sector in numerous fire service, continuity of operations planning (COOP) and military emergency management roles. He is currently Director of Innovation and Development at JMA Solutions. 

Washington, DC, October 3, 2019:  JMA Solutions, LLC, a Federal Government contractor of fourteen (14) years providing relevant unmanned aircraft systems (UAS) professional services such as safety management systems, safety risk management and UAS policy, today announced its partnership with the Drone Responders Public Safety Alliance (Drone Responders).  

 

Led by Chief Charles Werner (ret.), Drone Responders is a non-profit program created to unite aerial first responders, emergency managers, and search and rescue specialists under a unified organization to help learn, train, and test with one another. Drone Responders has the ultimate objective of maximizing drone operations for public safety. 

 

“We’re very appreciative of the efforts of JMA Solutions to help advance the mission of Drone Responders,” said Chief Werner. “With this partnership we’re able to reach more airspace decision makers and enable more sharing of knowledge, standardizing certifications, creating a global directory of emergency UAS assets and creating more professional UAS operations.” 

 

This exciting partnership takes advantages of JMA Solution’s vast experience working within the FAA as well as its expertise with national air space regulations and policies and combines it with Drone Responders’ in-depth expertise in the public safety UAS operations and advocacy. 

 

“Public Safety responders do so much for our communities and we’re proud to support the efforts of an organization such as Drone Responders,” said JMA Solutions CEO and President, Jan Adams. “JMA believes in their mission and looks forward to actively participating to achieve their goals.” 

 

The purpose of this partnership will be to help Drone Responders reach and collaborate more effectively with the Federal Aviation Administration (FAA) and other government agencies which have a hand in UAS rulemaking. As a member of the Drone Responders’ Board of Technical Experts, Tony Tisdall, VP of Global Affairs and Aviation Solutions, will lead efforts to reach key national air space decision makers. 

 

“There are so many complex issues surrounding drone operations and many more are added during emergency operations,” said Tisdall. “We look forward to working with Drone Responders to help navigate some of these complex issues.” 

 

Emerging technologies like UAS will reshape the way the aviation community will operate in the very near future.  The rapidly expanding UAS use case portfolio requires a collaborative, measured effort to integrate manned and unmanned flight into the National Airspace System.  The increased level of safety and response efficiency provided by UAS operations for our public safety professionals makes expansion of UAS a top priority 

 

 

About Drone Responders DRONERESPONDERS is a non-profit program created to unite the new aerial first responders, emergency managers, and search and rescue specialists under a unified organization to help learn, train, and test with one another with the ultimate objective of maximizing drone operations for public safety. The DRONERESPONDERS program is led by Chief Charles Werner (ret.) who serves as the director.  DRONERESPONDERS is a 501(c)3 non-profit program of AIRT, Inc. 

 

About JMA Solutions Headquartered in Washington, DC, JMA Solutions is an award-winning government consulting firm with over fourteen (14) years of experience delivering outstanding customer support. Since 2005, we have provided customer support for Air Traffic Management, Program Management, Safety Management Systems for UAS, Commercial Unmanned Aircraft Systems, Radar and Communications Support and much more! 

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