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.

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.