Association of Air Medical Services Proposes Requirements for UAV Operations

Although there has been much attention on the potential dangers drones present to commercial airlines, there are many more segments of the aviation community that may be affected by unmanned aerial vehicle (UAV) operations, according to the Association of Air Medical Services (AAMS).

AAMS says while dangers to commercial airlines are real and deserve serious discussion, other segments such as air medical transport, general aviation, law enforcement and business transportation often operate at low altitudes – and, in many cases, well away from an airport.

Thus, says the association, the dangers posed to low-level aviation environments are just as great, or perhaps greater, than those posed to commercial airlines that conduct flights under the guidance of air traffic control, within the confines of pre-approved flight plans, in controlled airspace, and in approved approach path and airport traffic areas.

AAMS believes the following regulatory requirements would allow for integration of UAVs into low-level airspace while optimizing the safety and privacy of emergency personnel and patients in need of assistance:

  • During the course of any emergency incident, no UAV may be operated within a five-mile radius of the incident site. Exemptions to this are allowed only for UAV operations considered essential to incident management and only when authorized by, and coordinated by, the specific incident command authority.
  • Anytime rotary-wing or fixed-wing aviation assets are part of emergency operations, UAV separation is essential to optimize safety for emergency aviation operations. No UAV will be allowed to operate within five miles of the perimeter of any emergency aircraft operations.
  • Anytime emergency aircraft are arriving, departing or otherwise occupying any airport, heliport, helispot or any emergency landing zone, UAVs are prohibited from operating within a five-mile radius of these sites.
  • In the event of an unforeseen encounter with rotary-wing or fixed-wing aircraft, the UAV operator will immediately take action to both “see and avoid” and yield right of way to said aircraft, as a component of deliberate action to create maximum separation between the UAV and aircraft.
  • UAVs operating within Federal Aviation Administration (FAA)-defined, controlled or uncontrolled airspace shall be operated only during day visual meteorological conditions, with a visibility minimum of three statute miles and cloud clearance requirements of 2,000 feet in any direction, and at no time should they operate above a cloud layer while being operated in national airspace.
  • All UAVs should be required to include technology to allow other aircraft to identify the UAV from a safe distance through automatic dependent surveillance – broadcast (ADS-B) technology.
  • To protect a patient’s rights to privacy, at no time shall UAVs be used to record video footage of non-emergency personnel (e.g., medical or trauma patients) without the prior written consent of these individuals.

AAMS says legislative bodies (e.g., Congress) should consider action to provide for appropriate enforcement against UAV operators who create a hazard to safe emergency operations by not following these guidelines.

As additional research is conducted to develop and implement technologies to prevent encroachment of UAVs into designated sensitive airspace, the FAA (or the appropriate regulatory bodies of other countries) and UAV manufacturers and programmers should work with stakeholders to ensure these technologies are both compatible with technologies currently being used in emergency response aircraft and are inclusive of emergency management concerns, the association adds.


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