On October 9, the International Association of Fire Chiefs filed comments to the Federal Aviation Administration’s (FAA) proposal. on rules for unmanned aircraft systems (UAS) operating beyond the visual line of sight (BVLOS). This proposal was intended for commercial UAS operations; however, the IAFC wanted to ensure that FAA includes the needs of public safety UAS in its new rules.
In its comments, the IAFC highlighted that the FAA’s new BVLOS rules should favor innovation and not hinder public safety operations. The IAFC requested that the FAA explicitly accommodate public safety BVLOS operations —including Drone as a First Responder (DFR) and First Responder Tactical BVLOS (TBVLOS).
To promote greater use of UAS by fire and EMS departments, the IAFC made the following recommendations:
- Create an explicit Public Safety pathway in Part 108 that accommodates Drone as a First Responder (DFR) and tactical BVLOS (TBVLOS) at ≤400’ above ground level under shielded, human-in-the-loop UAS operations.
- Preserve and integrate today’s effective waiver process for DFR/TCBVLOS operations, so public safety agencies do not lose operational gains.
- Ensure inclusivity beyond public aircraft operation (PAO) status for volunteer fire companies and non-governmental search and rescue teams.
- Provide priority handling in unmanned aircraft system traffic management (UTM)/automatic data service providers (ADSP) for authenticated emergency flights.
- Accept GIS-based operational mitigations (route/altitude constraints, ground-risk scoring, dynamic geofences) in lieu of cost-prohibitive equipment for cases where UAS are being used in low altitude operations and being protected from other air traffic by being shielded from view.
The FAA will review all comments it received in response to the proposed draft BVLOS proposal. The IAFC will keep its members informed as the FAA formulates its final rule.