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8900.1 CHG 468

VOLUME 16  UNMANNED AIRCRAFT SYSTEMS

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CHAPTER 4  OPERATIONAL REQUIREMENTS AND APPROVAL

Section 9  Public Certificate of Waiver or Authorization Safety Review

16-4-9-1    PURPOSE. This section provides guidance and policy to Federal Aviation Administration (FAA) aviation safety inspectors (ASI) concerning process and requirements used within the Unmanned Aircraft Systems (UAS) Integration Office (AFS-80) and the UAS Safety and Data Management Section (AFS-84), to facilitate and track the review of unmanned aircraft (UA) FAA Form 7711-1, Certificate of Waiver or Authorization (COA), requests from the FAA Air Traffic Organization (ATO) regarding public UA operations in the National Airspace System (NAS).

16-4-9-3    AUDIENCE. The audience for this section is all regional Flight Standards divisions (RFSD) and Flight Standards District Office (FSDO) ASIs, and headquarters (HQ) Flight Standards Service (AFS) policy divisions responsible for implementation.

16-4-9-5    BACKGROUND. A COA is an authorization issued by the ATO to a public operator for a specific UA activity. Approval documents are required since UA may not be compliant with applicable sections of the Code of Federal Regulations (CFR), and therefore require an alternate means of compliance (AMOC). After a public operator/applicant submits a complete application, the FAA conducts a comprehensive operational and technical review. If necessary, provisions or limitations may be imposed as part of the approval to ensure the UA can operate safely with other airspace users. In most cases, the typical COA application approval process is completed within 60 business days of receipt, provided there are no submittal errors, missing information, or safety or airspace issues. Applicants submit a package requesting UA operations in the directly into the FAA’s COA Online Web site (https://ioeaaa.faa.gov/oeaaa/Welcome.jsp). The package contains:

·    Proponent information,

·    Point of contact (POC) information,

·    Operational description,

·    Performance characteristics,

·    Airworthiness,

·    Procedures,

·    Avionics/equipment,

·    Lights,

·    Spectrum analysis approval,

·    Air traffic control (ATC) communications,

·    Electronic surveillance detection capability,

·    Visual surveillance detection capability,

·    Aircraft performance recording,

·    Flight operations area/plan, and

·    Special circumstances.

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16-4-9-7    SAFETY REVIEW.

A.    Administrative Review. ATO/AJV-115 reviews the submission to ensure it is complete. If deemed complete, the package is classified as “committed.” If it is not complete, AJV-115 “releases” the application back to the applicant for additional data. If the applicant provides the additional data, the package is termed “recommitted” back to AJV-115, which then undertakes a comprehensive review of the submission to verify it is a complete package. During this phase, ATO does both an administrative and a feasibility check of the applicant’s request. AJV-115 does the administrative check from an HQ policy perspective, checking to ensure the application is completed correctly, and that all necessary documents and details are contained within the submission. The appropriate ATO Service Area accomplishes the feasibility check from a high-level air traffic perspective. “R” or renewal COAs differ in that a renewal COA is the same exact copy of a previous COA for a different time period.

B.    Safety Risk Mitigation Assessment. If ATO deems the package complete, it is classified as a “validated” package and, depending upon the proponent, its Aviation Safety (AVS) or AFS-84 counterpart will do a safety risk mitigation assessment of the application. AFS-84 is the focal point for all AVS UAS COA activity. AFS-84 facilitates the review of COA applications from a technical analysis perspective and recommends risk mitigation provisions to AJV-115. The Flight Standards (AFS) assessment is intended to ensure that UA, regardless of size, do not compromise the high level of safety for other aviation, the public, and property on the ground. The AFS-84 process officially commences when ATO validates a COA application and requests AFS risk assessment.

Figure 16-4-9A  AFS-84 Safety Review Process

1.0    TRIGGER: ATO (UAS OFFICE) REQUESTS AFS SAFETY/RISK ASSESSMENT.

1.1    ATO validates a COA application and sends an automatic COA Online message to the AFS-84 administrative staff, notifying them that a safety/risk assessment of the COA is requested.

1.1.1    ATO does not require AFS safety reviews for COAs of the following proponents:
1.1.1.1    Department of Defense (DOD) (refer to ATO/AJV-115 March 7, 2014, and May 5, 2014, memoranda).
1.1.1.2    Department of Homeland Security (DHS), including Customs and Border Patrol; Federal Bureau of Investigation (FBI); National Aeronautics and Space Administration (NASA); National Oceanic and Atmospheric Administration (NOAA); and Department of Interior (DOE) (refer to ATO/AJV-1 October 31, 2014, memorandum).
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1.1.2    To meet ATO’s policy of completing a COA action within 60 days, AFS-84 normally assigns AFS a due date of 20 business days (note: 10 business days for a special “R” designated Renewal COA) from the date of the COA Online validation. “R” or renewal COAs differ in that a renewal COA is an exact copy of a previous COA for a different time period. AFS completion of this action occurs when AFS-84 forwards the safety assessment memorandum back to ATO.
1.1.3    Sensitive and/or emergency COAs may or may not be transmitted to AFS-84.

1.2    The AFS-84 administrative staff records the action in the branch’s UAS data file(s).

1.2.1    See AFS-84-001-W1, Administrative Processing of Unmanned Aircraft Certificates of Waiver or Authorization, for data file update procedures.

2.0    AFS-84 SENDS THE REQUEST TO THE AXX-220 REGIONAL MANAGER. The AFS-84 administrative staff sends a message to the AFS Regional NexGen Branch (AXX-220) manager requesting an ASI be assigned to do a safety review of the COA application.

2.1.1    The request is sent on the behalf of the NexGen Field Program Branch (AFS-408), which has oversight of the Part 121 Air Carrier Operations Branch (AFS-220) ASIs.
2.1.2    This notice of request for an ASI assignment should be done as soon as possible (normally on the day of its receipt).
2.1.3    The request is sent to that AXX-220 manager whose responsibility oversees the state of the proponent’s intended UA operations.
2.1.4    Message title example: “AFS Safety Review (COA 2015-WSA-240) - City of Salinas - CA (DJI Phantom 3 Professional).” (Note: If the COA is a special “R” Renewal COA, that annotation should be in the message title.)
2.1.5    Each message should contain only one COA.
2.1.6    The message should include the following:
2.1.6.1    COA number.
2.1.6.2    COA subject.
2.1.6.3    ATO comments.
2.1.6.4    ATO computed and requested AFS due dates. To meet its part of the ATO policy of completing a COA actions within 60 days, AFS-84 normally assigns ASIs a due date of 17–18 business days (Note: 8 business days for a special “R” designated Renewal COA) from the date of the COA Online validation. This allows for a 1–2 day review and processing time at AFS-84. AFS completion of this action occurs when AFS-84 forwards the safety assessment memorandum back to ATO.
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2.1.6.5    COA background and UA registration data (extracted from COA Online).

2.2    Refer to AFS-84-001-W1, Administrative Processing of Unmanned Aircraft Certificates of Waiver or Authorization, for data file update procedures.

3.0    THE AXX-220 REGIONAL MANAGER ASSIGNS AN ASI.

3.1    The AXX-220 manager may provide the ASI’s name to the AFS-84 administrative staff, who would then pass along the assignment.

3.1.1    The goal is for the ASI assignment to be made within 2 days of being notified of the COA validation.

3.2    Refer to AFS-84-001-W1 for data file update procedures.

4.0    ASI ASSIGNED (AFS-84 STAFF ASI OR REGIONAL ASI).

4.1    AFS-84 administrative staff provide the COA application package to the designated ASI, and contractor if assigned.

4.2    Refer to AFS-84-001-W1 for data file update procedures.

5.0    ASI TECHNICAL ANALYSIS. The assigned ASI will review the application for safety of operational flight concerns, risk mitigation, etc.

5.1    Refer to AFS-84-001-W2, Analyze and Document a COA Risk Mitigation Assessment, for policy on how to accomplish the analysis.

5.2    The ASI completes and forwards a draft AFS-84 memorandum detailing the result of the analysis to the AFS-84 administrative staff.

5.3    The ASI will advise if the COA safety review cannot be completed within the assigned timeframe or if a nontypical response is anticipated. Under this circumstance, AFS-84 administrative staff will coordinate with the UAS Tactical Operations Section of AJV-115.

5.4    The ASI will alert the ATO POC and AFS-84 regarding any information that is missing or needs to be revised in the proponent’s application and request the COA be “Released” back to the proponent. If the ASI only informs the AFS-84 administrative staff, the administrative staff will forward to the specific ATO/AJV-115 COA Processor for the case.

5.5    Following COA revalidation, AFS-84 administrative staff will notify the ASI to restart the review.

5.6    Refer to AFS-84-001-W1 for data file update procedures.

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6.0    AFS-84 MANAGEMENT REVIEW AND COORDINATION. The AFS-84 administrative staff processes the ASI draft safety risk assessment memorandum and ensures it is compliant with AFS-80 correspondence guidelines. Direct communications with the ASI is encouraged to resolve any administrative or technical issues with the draft memorandum.

6.1    When the COA safety memorandum is ready, AFS-84 administrative staff sends a message to the AFS‑84 manager, entitled “ACTION for AFS-84 Review and Signature: COA 2015-CSA-193.

6.2    This message requests review, electronic coordination, and attachment of the manager’s electronic signature on the grid and final memorandum. If the AFS-84 manager concurs with the COA safety memorandum, he or she electronically grids off on the memo and forwards it to the ATO/AJV-115 administrative specialist and the ATO COA Processor identified in a message, with an information copy to AFS-84 administrative staff for tracking recordation into the database.

6.3    If the AFS-84 manager does not concur, or needs additional information, he or she will either notify AFS-84 administrative staff, or contact the ASI who performed the safety review.

6.4    Refer to AFS-84-001-W1 for data file updates and correspondence tips.

6.5    The goal of this phase is 2 business days (1 day for an “R” COA).

7.0    AFS-84 PROCESSES THE SAFETY MEMORANDUM. The AFS-84 administrative staff record the action as completed in the data file.

7.1    Refer to AFS-84-001-W1 regarding update of the data file.

7.2    The goal of this phase is to obtain the AFS-84-signed memo and complete the ATO closeout within 2 business days.

7.3    AFS-84 administrative staff upload electronic copies of the safety memorandum and its grid on the applicable media storage device. Hard copies, maintained through 2015, are stored in accordance with AFS-80 policy.

8.0    POST COA ACTION CLOSEOUT. ATO/AJV-115 considers the AFS-84 safety risk mitigation provisions and may incorporate some or all of these into the approval COA issued to the requesting proponent.

8.1    Upon notification that a COA has been issued, AFS-84 administrative staff will obtain the document and compare its content to that which AFS recommended. The result of that analysis will be forwarded to the AFS-84 manager and the ASI who did the safety review.

8.2    AFS-84 administrative staff monitor COA Online and record pertinent data regarding approved COAs, such as approval date, start and stop dates for the approval, authorized visual observations distances, and areas of operation.

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9.0    PROCESS MEASUREMENT. The target to complete processing of a validated COA application by AFS‑84 is a maximum of 20 business days from the time the COA is validated as reported in COA Online (10 business days for an “R” COA). The measured time excludes any time during which:

9.1    The package was in release status. Note: Only ATO can release and revalidate a COA. AFS should request ATO to release a package when the application needs clarification, additional data, or for other reasons.

9.2    The package is put on administrative ATO hold status for further research.

9.3    AFS-84 administrative staff track the time the package is in AFS-84 control until it is completed and closed out back to ATO. Refer to AFS-84-001-W1 regarding update of the data file. The following data elements pertain specifically to the measures for this procedure:

9.3.1    Date package sent by ATO to AFS.
9.3.2    Due date back to ATO.
9.3.3    Date ASI assigned and due date.
9.3.4    ASI completion date.
9.3.5    Date AFS-84 administrative memorandum coordination complete.
9.3.6    Date action sent to AFS-84.
9.3.7    Date action AFS-84 signs and closes out the memorandum back to ATO.
9.3.8    Should ATO recall a COA action, AFS-84 will record if ATO recalls, cancels, etc. a package.

10.0    AFS-84 TIMELINE. The time in AFS-84 control can be measured by calculating the number of days between the date the package received (i.e., validated in COA Online) to the date the package is sent back to ATO, subtracting any days for administrative ATO hold or release status.

10.1    General timeline for a normal/new COA: Goal 20 business days.

10.2    ASI Assignment: 2 days.

10.3    ASI Assessment: 15 days.

10.4    AFS-84 Coordination, signature, and closeout: 3 days.

11.0    TIMELINE FOR ATO CLASSIFIED RENEWAL (CODED “R” COAs). Goal: 10 business days.

11.1    ASI Assignment: 1 day.

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11.2    ASI Assessment: 7 days.

11.3    AFS-84 Coordination, signature, and closeout: 2 days.

12.0    REVIEW CONFORMITY. AFS-84 administrative staff will assess product conformity by computing the number of Corrective Action Requests (CAR) and/or Nonconforming Product Records (NCR) submitted against the process.

13.0    FEEDBACK. Feedback of stakeholder satisfaction will be monitored and processed in accordance with Quality Management System (QMS) AVS-001-003, Stakeholder/Customer Feedback Process, and the AVS Stakeholder Feedback Processing Job Aid. Every effort will be made to incorporate changes to the processing of COAs from stakeholders. Stakeholders can make comments in the following ways:

13.1    Organizational email boxes:

13.1.1   9-AFS-UAS-Inquiries@faa.gov. The Web form tool is used to document and track UAS inquiries.
13.1.2   Comments or opinions from internal or external stakeholders received via
9-AWA-AVS-AFS-080-Unmanned-Aircraft-Systems@faa.gov, also known as the SF Mailbox.

13.2    Individual emails.

13.3    Phone conversations.

13.4    Regular postal mail.

13.5    Informal contacts.

13.6    Surveys.

Table 16-4-9A.  AFS-84 Safety Review Process Measures

Measure Type

Paragraph Reference

Measure

Process Performance

10.0–11.3

Count the number of procedures completed within the maximum of 20 business days for routine COAs (10 business days for an “R” COA).

Product Conformity

12.0

Measure the number of CARs or NCRs submitted against the process.

Stakeholder Satisfaction

13.0

Use all means available to determine whether stakeholders are satisfied with the products.

16-4-9-9 through 16-4-9-23 RESERVED.