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.
Drone Responders Public Safety Alliance
ANSI UAS Standardization Collaborative (UASSC)
National Public Safety Telecom Council UAS & Robotics WG
InfraGard UAS Integration into Critical Infrastructure WG
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.”
JMA iLAB’s public input proposes revisions and/or additions to NFPA 2400 Chapter 4 - Organizational Deployment and Chapter 6 – Maintenance of sUAS.
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
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.
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
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.
As part of the maintenance program, the public safety entity shall have procedures for service for the following:
1. Routine cleaning
3. Maintenance necessary due to operational applications
4. Maintenance necessary due to operating environment
5. Storage requirements
6. Firmware checks/updates
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.
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.
Washington, DC, October 3, 2019: JMA Solutions, LLC, a Federal Government contractor of fourteen (14) years providing relevantunmanned 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 andpolicies andcombines 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 AviationAdministration(FAA) and other government agencies which have a hand in UAS rulemaking. As a member of the Drone Responders’ Board of Technical Experts, Tony, 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. “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 RespondersDRONERESPONDERSis 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 SolutionsHeadquartered 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 forAir Traffic Management,Program Management,Safety Management Systems for UAS,Commercial Unmanned Aircraft Systems,Radar and CommunicationsSupportandmuch more!
Arlington, VA – June 27, 2019 – The Washington Business Journal has selected JMA Solutions’ Chief Operating Officer (COO) Avis Dillard-Bullock as an honoree of their inaugural Veterans in Business Awards. This award honors 10 individuals who are “veterans, combat veterans, retired veterans or those currently on reserve status in the U.S. military and 1 veteran owned company”, for their outstanding business and community practices. Ms. Dillard-Bullock was recognized for her dedication and commitment to serving the veteran community at the Washington Business Journal’s Veterans in Business Awards Breakfast at the Westin Arlington Gateway on June 27th.
“It is truly an honor to be recognized by the Washington Business Journal for such a prestigious award,” said COO Avis Dillard-Bullock. “As a veteran of the United States Air Force, I believe it is my duty to honor, protect, and give back to the heroic individuals who have made countless sacrifices to serve this nation.”
About JMA Solutions
Headquartered in Washington, D.C., JMA Solutions is an award-winning consulting firm with more than 14 years of experience delivering outstanding customer service to our government clients. JMA Solutions is a Service-Disabled Veteran-Owned, Certified Woman-Owned, Disadvantaged Business Enterprise company, and is proudly CMMI services level 3 appraised, ISO 9001:2015 certified and DoD NIST 800-171 verified. We offer access to a network of technical and support subject matter experts who consult with our government clients on critical short-and long-term projects. Our core capabilities include Air Traffic Management, Program and Project Management, Software Engineering, Acquisition Management, Information Technology Support and Professional and Technical Training. We pride ourselves on our earned reputation as a highly collaborative, results-oriented company that is committed to serving the community where we live and work.
Washington, DC – April 28, 2019 – JMA Solutions’ President and CEO Jan Adams, was inducted into the Washington DC Hall of Fame during the 19th Annual Legacy Awards Gala held at the Liaison Washington Capitol Hill hotel. This premier event hosted annually by the Washington DC Hall of Fame Society, honors District of Columbia residents who have had an outstanding impact on the city and have provided exemplary services in the areas of business, community development, communications, cultural arts, education and more. Ms. Adams was recognized for her outstanding achievements and long-term commitment to serving the D.C. business community.
“I am truly honored to be recognized by the Washington DC Hall of Fame Society for my contributions to the D.C. business community” said President and CEO Jan Adams. “This recognition inspires me to continue to use my platform to build a foundation and provide an example for our future generation of business leaders to follow.”
About the Washington DC Hall of Fame SocietyThe Washington DC Hall of Fame Society is a non-profit 501 (c) (3) organization widely known for its distinguished Annual Awards Program and Gala created to recognize District of Columbia residents who have had an outstanding impact on the city. This tribute to D.C. residents honors and showcases the rich history of Washington and how these individuals have enhanced our city over the past 75 years. Read more about the Washington DC Hall of Fame Society on their website here.
January 31, 2019, Washington, DC – JMA Solutions, LLC is pleased to announce that its PMO Operations have successfully been appraised at CMMI Maturity Level 3 for Services (CMMI-SVC). The appraisal was performed by Mosaic Technologies Group, Inc. This achievement indicates that JMA has detailed, consistent processes that are well characterized, understood and are described in standards, procedures, tools, and methods.
“Advancing to Maturity Level 3 for Services is a huge accomplishment for JMA Solutions” said President and CEO Jan Adams "This benchmark truly validates my team’s commitment to ensuring processes and best practices are well-defined and services are delivered to the highest quality of standards.”
Washington, DC - September 16, 2018 – The National Congress of Black Women (NCBW) has named President and CEO, Jan Adams, the recipient of the Sojourner Truth Award for Corporate Success at the 34th Annual Awards Brunch. As an entrepreneur, Ms. Adams is a prominent business figure who inspires and supports the achievement of women of color and continues to promote them to leadership positions at JMA. Ms. Adams is a recognized leader within her own community and the DC business community, which is a direct reflection of NCBW’s mission. The winners of this award were celebrated during the NCBW 34th Annual Awards Brunch at the Marriott Washington Wardman Park Hotel in Washington, DC.
“To be recognized by the National Congress of Black Women is an honor,” said Jan Adams, President and CEO of JMA Solutions. “As a leader, some of my greatest successes in life have come from helping others achieve. To be honored with such an award by my peers is truly delightful.”
About The National Congress of Black Women:
Founded in 1984, the NCBW is a nonprofit organization that serves as a nonpartisan voice of advocacy for issues affecting the appointment of women at all levels of government. With its headquarters in Washington, DC the NCBW strives to increase the participation of women of color in the educational, political, economic and social areas. NCBW’s programs benefit thousands of people annually and provides opportunities for women to attain leadership and decision-making positions in the government, non-profit organizations and in the private sector. Read more about the NCBW on the NCBW website.