Policy and SOG

The purpose of this policy is to establish a common framework for Unmanned Aerial System (“UAS”) operations for the Colorado Department of Public Safety (“CDPS” or “Department”). CDPS recognizes that each division has unique operational considerations and this policy is intended to provide a foundation on which each division may establish its own procedures and guidelines appropriately tailored to meet their mission and purpose for using UAS. To ensure that these programs meet the needs of each division while remaining compliant with regulations, CDPS policy, and that they operate in a safe, efficient, and sustainable manner, the Colorado Center of Excellence for Advanced Technology Aerial Firefighting (CoE) will coordinate the efforts of all CDPS divisions and units using UAS technology and act as the lead agency for coordinating airspace safety, training, program and policy development, and intergovernmental relations on matters related to UAS.

CDPS recognizes the value of UAS in public safety operations. UAS may be deployed in a wide range of public safety incidents to complete tasks that would be difficult, costly, hazardous, or even impossible to accomplish without their use. The Department is also conscious of the risks involved in any kind of aviation, manned or unmanned. As such, the purpose of this policy and the Department’s use of UAS is to provide a powerful tool to Department employees and cooperators while managing the risks involved.

This policy applies to all CDPS employees, volunteers, contractors, and others acting on behalf of CDPS or engaging in any UAS operations under the auspices of the Department. This policy applies to all UAS flight operations, regardless of weight or geographic location.

1. Colorado Center of Excellence for Advanced Technology Aerial Firefighting (CoE) coordinates the efforts of all CDPS divisions and units using UAS technology and acts as the lead agency for coordinating airspace safety, training, program and policy development, and intergovernmental relations on matters related to UAS.
2. Certificate of Waiver or Authorization (“COA”):  Certificate of Waiver or Authorization that permits public agencies and organizations to operate a particular aircraft, for a particular purpose, in a particular area, or waives specific requirements for operations.
3. UAS Program Manager: The program manager will be responsible for ensuring compliance with division SOGs and this policy, and coordinate the division’s UAS efforts with the CoE.
4. Remote Pilot in Command (“rPIC”): The person responsible for ensuring safe and appropriate operations of a particular UAS.
5. UAS Crew Member: The rPIC, and any observers, sensor operators, or other personnel directly involved in ensuring the safety and success of a UAS mission.
6. Unmanned Aerial System (“UAS”): Unmanned aircraft 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”).
7. Part 107: 14 CFR 107, federal regulations concerning civil operations of sUAS.

All UAS activity operated or caused to be operated on behalf of the Department must be in compliance with this Policy. Department members may deviate from this policy only if doing so is reasonably necessary to address an emergency involving significant potential for injury or death. Emergency action should be taken in such a way as to minimize injury or damage to property. Any exceptions taken must be documented in the flight log and reviewed by appointing authority.

1. Administration
   1. The use of UAS is to be coordinated at the divisional level. The CoE is the lead unit for UAS efforts within the Department and will coordinate the efforts of all CDPS divisions and units using UAS technology, will review division directives/policies/SOGs, will develop training requirements and protocols, will establish a centralized system for maintaining UAS-related records, will maintain a set of standards for approving UAS platforms for CDPS use, and will provide a periodic report to the Executive Director of the Department on the use of UAS. Each division engaging in UAS operations is responsible for implementing division directives/policies/SOGs for operational use of their UAS for public safety purposes and shall have a Program Manager who can provide the minimal oversight requirements outlined in this policy.
   2. Any CDPS division that wishes to operate UAS shall appoint a UAS Program Manager. In the event a division wishing to engage in UAS operations does not have a Program Manager within the division, a Program Manager for another division may be delegated the responsibility for managing that division’s UAS program.
   3. The CoE shall provide advice and consent to CDPS regarding UAS platforms for department use.
2. Training and Skill Currency
   1. Prior to engaging in UAS operations, any remote Pilot in Command (“rPIC”) must obtain a UAS Remote Pilot Certificate from the Federal Aviation Administration (“FAA”) under 14 CFR 107. This remote pilot certificate is required for all UAS flights regardless if the operation is considered a civil aircraft operation or public aircraft operation.
   2. A person without a Remote Pilot Certificate may only operate a UAS under the direct supervision and command of a certified UAS Remote Pilot. A certified UAS Remote Pilot may only supervise one uncertified rPIC at any given time.
   3. The CoE shall establish minimum training standards and protocols, and administer training to all CDPS personnel authorized to use UAS on  at least an annual basis.
      1. The CoE shall make available to CDPS members an initial UAS rPIC development course and a periodic refresher course to satisfy the training requirements of this policy.
      2. The CoE shall develop pilot certification standards for CDPS.
      3. The CoE shall issue credentials to pilots who successfully complete the training and meet CDPS certification standards. CDPS UAS Pilots shall have the credentials in their possession while operating UAS on behalf of CDPS.
3. Pilot Responsibilities
   1. Every rPIC has the responsibility to ensure that missions are performed within the parameters of what is safe, legal, and effective. The rPIC has the ultimate authority and responsibility to refuse a mission if they believe that such mission would fail to comply with laws and regulations, would present a risk to safety requirements, or would fail to meet best practices.
   2. The rPIC is responsible for completing all tasks required to obtain mission approval, including communication with the FAA and all nearby airports, with the Incident Commander (IC) or the Air Operations Branch Director (AOBD), and any other required notifications as applicable.
4. Data Handling and Retention
   1. Each division engaging in UAS operations must handle any collected data in accordance with CDPS and the division’s existing data or evidence handling and retention policies.
   2. In the course of performing missions, a UAS may collect sensitive data which may be inappropriate for public disclosure, or which may need to be edited or redacted before it may be released. Any such redaction or non-disclosure must be done in accordance with the Colorado Open Records Act (C.R.S. §24-72-201 to 206), the Colorado Criminal Justice Records Act (C.R.S. §24-72-301 to 309), the Children’s Code Records and Information Act (C.R.S.  19-1-301 to 309.5), or any other laws, regulations, and policies pertaining to data retention, records management, or records disclosure.
   3. Any person acting as rPIC or crew member must take reasonable precautions and conduct UAS operations in such a way as to minimize the collection of data not necessary to the object of the mission.
5. Flight records
   1. The CoE shall establish a method for logging flight information and metadata from UAS missions, as well as auditing and managing rPIC training and currency requirements. At a minimum, the log must contain each operational mission undertaken, the name of the assigned rPIC, the mission location, duration, and a brief description of the goals of the mission.
   2. The CoE shall coordinate records retention for flight records, pilot logs, training records, and aircraft maintenance records with the divisional program managers. Media recorded in UAS missions shall be retained in accordance with statute, rules, division directives/policies/SOGs, and division records retention schedules on file with the State Archivist.

1. CDPS UAS/UAV flight log, pilot flight records, training records, and aircraft management webpage
2. 14 CFR Part 107 (sUAS)
3. FAA Modernization and Reform Act of 2012. Pub. L. 112-095
4. FAA UAS Public Safety and Law Enforcement Toolkit

1. Unmanned Aerial System Operations, Version 1.0, adopted December, 2017.
2. Unmanned Aerial System Operations, Version 1.1, October 05, 2022.

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 This email address is being protected from spambots. You need JavaScript enabled to view it. 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