Policy and SOG

The purpose of this Standard Operating Guideline (SOG) is to provide clear and effective guidance for the operations and management of the Division of Fire Prevention and Control (DFPC) Unmanned Aerial Systems (UAS).

This SOG applies to all DFPC personnel operating UAS within the scope of their employment. Each section within DFPC may implement its own set of standard operating guidelines that further refine the process of using UAS for the section’s unique mission profile.

This SOG has been established to provide a common framework and guidelines for DFPC personnel regarding the operation of UAS in public safety operations.

1. Active Incident. Any incident, whether natural or human-caused, that requires responsive action to protect life or property. The incident is considered “active” during the response phase, as distinct from mitigation, preparedness, or recovery phases of emergency management. Specific to wildland fire this includes an uncontrolled fire.
2. COA. A Certificate of Waiver or Authorization is an authorization issued by the FAA to a public aircraft operator for a specific UA activity.
3. FAA. The Federal Aviation Administration, the Air Traffic Organization responsible for coordinating air traffic in the National Airspace System.
4. FLYAWAY. A flyaway event is when control of the aircraft is lost and the aircraft continues on or lands without active control. Flying outside visual range, but with control, is not a flyaway. Auto-landing due to battery depletion is not a flyaway.
5. NFES 2724. Interagency Standards for Fire and Fire Aviation Operations. Commonly referred to as the “Red Book.”
6. NOTAM. Notice To Airmen is a notice containing information (not known sufficiently in advance to publicize by other means) concerning the establishment, condition, or change in any component (facility, service, or procedure of, or hazard in the National Airspace System) the timely knowledge of which is essential to personnel concerned with flight operations.
7. Operating Documents. FAA Remote Pilot Certificate, any applicable waivers, COAs, and aircraft registration.
8. rPIC. Remote Pilot in Command, the person responsible for ensuring safe and appropriate operations of a particular UAS.
9. UAS. Unmanned Aircraft System and all of the associated support equipment, control station, data links, telemetry, communications, navigation equipment, etc., necessary to operate the unmanned aircraft. UAS weighing less than 55 pounds with their payload are categorized as small UAS (sUAS).
10. UAS crew member. The rPIC, and any observers, sensor operators, or other personnel directly involved in the setup, launch, recovery or manipulating the controls of the UAS while ensuring the safety and success of a UAS mission.
11. TFR. A Temporary Flight Restriction is a limitation on aviation activity applied to an area of airspace (defined both laterally and vertically) that has been temporarily or partially closed to non-participatory aircraft for a specified period of time due to a hazardous condition, a special event, or to provide a safe environment for the operation of disaster relief aircraft. A NOTAM is issued containing information on the reason for the TFR, contact information and fine points of the restriction. All aviation activity within the TFR must be approved by the airboss/operations manager assigned to managing the TFR prior entry into the specified airspace.
12. VO. Visual Observer crew member who assists a sUAS pilot in the duties associated with collision avoidance and navigational awareness by keeping visual contact with aircraft.

1. Aircraft
   1. UAS are required to be registered and marked in accordance with FAA requirements.
      
      
2. Active Incidents
   1. DFPC personnel operating as part of an organized wildland fire module shall comply with all provisions of this Division-wide SOG as well as the Section-specific DFPC WFMS SOG “Unmanned Aerial Systems” for additional guidance regarding UAS use on wildfire incidents.
   2. Other Fire-Related Incidents (structure fires, swift water rescue, HAZMAT, etc)
      1. DFPC personnel visiting incidents managed by local fire departments or other local authorities must receive the approval of the IC or chief officer responsible for the incident. Personnel must maintain situational awareness of the incident through face-to-face or radio communication with incident personnel.
      2. As all DFPC personnel are not issued structural bunker gear or other specialized PPE, they will remain a safe distance away from any hazardous locations or substances. If firefighters have designated hot, warm, and cold zones on their incidents DFPC personnel will remain outside of the hot zone at all times. If zones have not been established, the “rule of thumb” that personnel should be far enough away that the hazard should be obscured by holding their arm up and covering the hazard with their thumb.
   3. Law Enforcement
      1. DFPC personnel assisting with law enforcement incidents must receive the approval of the IC or law enforcement agency supervisor. Personnel must maintain situational awareness of the incident through face-to-face or radio communication with officers.
      2. As DFPC personnel lack law enforcement training and PPE they will remain staged away from any hazardous situations until officers on scene declare that the scene is safe.
         
         
3. Regulatory Compliance
   1. All rPICs shall comply with the requirements of the CDPS Unmanned Aerial Systems Operations Policy (1.09.001), including the UAS Training Procedures and Standards Addendum.
   2. Operating Documents must be in the rPIC’s possession at time of operating any UAS.
      
      
4. Personnel Responsibilities
   1. Unmanned Aerial Systems (UAS) Program Manager
      1. The DFPC Director may assign a DFPC member to serve as the UAS Program Manager.
      2. The Program Manager is responsible for the following:
         1. Providing all assigned personnel applicable regulatory requirements, standards, and organizational safety policies and procedures.
         2. Reviewing rPIC performance and compliance with organizational goals, objectives, and regulatory requirements.
         3. Reviewing standards and the practices of agency personnel as they impact flight safety.
         4. Assigning tasks and leadership roles on the team.
         5. Maintaining records.
   2. Remote Pilot in Command (rPIC)
      1. The rPIC is responsible for and is the final authority as to the operation of the aircraft.
   3. Visual Observer
      1. Before acting as VO, a UAS crew member will:
         1. Understand the role and responsibilities of the VO.
         2. Receive briefing in at least the following subject areas:
            1. Their role on the flight crew,
            2. Emergency procedures, and
            3. Safety.
         3. Be approved by rPIC.
            
            
5. Training and Currency
   1. The UAS Program Manager shall periodically review the current state of UAS operations within DFPC and publish a Memorandum on UAS training procedures and standards, taking into account any changes in technology, lessons learned, and updated concepts of operation.
      
      
6. General Operating Procedures
   1. Airspace and Incident Coordination
      1. When incident command has been established, the rPIC will coordinate with incident commander prior to operation. Planned or routine operations that are not part of an incident do not require such coordination.
      2. The rPIC is responsible for compliance with this policy and Federal Aviation Regulations. DFPC rPICs should be familiar with the National Airspace System and able to adequately deconflict competing flight activity with respect to safety, environmental concerns, and operational requirements. It is the rPIC’s responsibility to comply with all rules and regulations for flight through each type of airspace.
         
         
7. Emergency Procedures
   1. Injury
      1. The primary concern in the event of any injury is the health and safety of personnel. EMS shall be notified and appropriate care given. Injury notification procedures will be followed.
   2. Aircraft Flyaway
      1. rPIC shall follow FAA recommended flyaway procedure.
      2. Every effort, consistent with safety, will be made to maintain visual contact with the aircraft until it lands/crashes.
   3. Lost Visual line of Sight
      1. In the event of rPIC and VO losing sight of a UAS in flight, the rPIC shall regain their visual line of sight in the safest manner according to pilot discretion.
   4. Aircraft Automatic Landing Due to Low Battery
      1. An automatic landing due to low battery may or may not be an emergency, but it does represent a limited control of the aircraft. The rPIC should endeavor to land the aircraft before automated procedures take over.
   5. Object Avoidance
      1. The rPIC shall take whatever action is appropriate to avoid manned aircraft and other objects.
8. Accident Reporting
   1. Any unmanned aircraft event that causes injury to anyone, or $500 or more in damage to equipment or private property other than the UAS itself will be reported to the UAS Program Manager. A completed accident entry in the flight log will suffice to satisfy this requirement.
   2. Should injury occur, appropriate medical care will be the first priority. Required workplace injury reporting procedures will be followed.
   3. Current FAA mandated procedures will be followed.

1. Unmanned Aerial System Operations, Policy 1.09.001, Colorado Department of Public Safety
2. Interagency Standards for Fire and Fire Aviation Operations, Federal Fire and Aviation Task Group, National Interagency Fire Center. NFES 2724
3. DFPC SOG 5.05.001: Wildland Fire Qualifications. Division of Fire Prevention and Control Standard Operating Guidelines.
4. Federal Aviation Administration (FAA) policy is provided in 14 CFR Part 107 and/or FAA Order 8900.1, Volume 16, Unmanned Aircraft Systems (UAS), dated August 29, 2016.

Version 1, Unmanned Aerial Systems, Approved [Insert Date]

1. In accordance with Policy 1.09.001, all CDPS UAS pilots must be certified as FAA Remote Pilots.
   1. CoE can facilitate or recommend basic training to CDPS employees who are seeking to become FAA Remote Pilots. Please contact the CoE/CDPS UAS Program Manager at garrett.seddon@state.co.us or 970-665-0045 to discuss your training needs.
2. CDPS policies require training and testing beyond FAA requirements. See CDPS Policy 1.09.001 for details.
   1. It is the responsibility of every CDPS rPIC to fly each UAS to maintain proficiency on that aircraft.
   2. Initially and at least once every 12 months rPIC will complete an annual UAS proficiency flight review under the observation of the division’s UAS program manager.
      1. A proficiency flight review contains the following items as a minimum: Flight planning, mission briefing, ground procedures, takeoff, normal and emergency landings typically practiced in flight, post landing procedures, mission debriefing and other maneuvers deemed appropriate by the program manager.
      2. Program and Policy Updates
      3. Risk Management
      4. Flight Qualification Test
      5. Accident Reporting
      6. Airspace
      7. Lessons learned
      8. Aircraft/Sensor Updates/Emerging Technology discussion
      9. Flight/Mission Planning
      10. Hardware/Software/Apps

1.  In accordance with Policy 1.09.001, all CDPS UAS pilots must be certified as FAA Remote Pilots.
   1. CoE staff have no connection to any of the FAA testing facilities approved to administer the test required for FAA Remote Pilot certification. The scheduling of any tests is the responsibility of individuals seeking certification.
2. Specific testing procedures for tests required of CDPS UAS operators are set by each Division, but must meet the minimum standards established by the CoE. See CDPS Policy 1.09.001.V.b.3.
3. Minimum training and currency standards for CDPS personnel are as follows, until modified by a UAS Training Procedures and Standards memorandum in the future:
   1. In addition to a current FAA Remote Pilot Certificate, UAS operators must successfully complete the CDPS UAS Flight Qualification Test as administered by CoE staff or designees.

CDPS Policy 1.09.001.V.C. requires CoE to establish a method for logging certain UAS flight data for CDPS UAS flights. The method currently established for this purpose is a data entry form found at https://cdps-uav.org