Header photo courtesy of Carilion Life-Guard and taken from a drone. Photo includes flight crew, drone operators, and LZ Commanders following Carilion’s first open forum on drone safety with their safety campaign message #LandTheDrone
The following content was submitted by Susan Smith, Program Director; Ty Le Roy, Base Aviation Manager; Nick Mattheisen, Business Development Manager, Carilion Clinic Life-Guard
As we all know, drone use is on the rise. While we recognize the value of drones in our national air space system, we also know that the advancement of this technology and its proliferation are moving faster than regulatory bodies can keep up with. Therefore, it is up to each HEMS program to find ways to work creatively to ensure that our shared air space remains a safe air space.
We have all seen stories in the news about the lift-off / landing delays and near misses that drones have caused for helicopters. At our program alone, we have recently experienced two encounters with drones; once during daylight operations on a scene response and another at night while on approach to a hospital helipad. Even more recently, we have noted a drone directly in front of our Level One Trauma Center rooftop helipad; on one of those occasions with two helicopters in bound with patients. This issue is getting personal.
So what can we do? While we recognize that the greatest impact will be through changes in legislation, we know that will take time. Until those changes are made, we can focus our efforts in areas in which we can immediately affect through education, while we continue to press for legislation changes.
HEMS programs should work with their Governmental Affairs and General Counsel to interpret current laws, regulations, and guidance at the federal and state levels
- Section 336 of PL 112-95 (FAA Modernization and Reform Act of 2012) states that non-commercial drone operators must contact the airport operator or the airport air traffic control tower prior to flying within 5 miles of an airport.
- 49USC defines airports as “landing area(s) used regularly by aircraft for receiving or discharging passengers or cargo”
- FAA AC 91 57-A (Model Aircraft Operating Standards) references 112-95 and urges drone operators to fly in accordance with a community-based set of safety guidelines and within the programming of a nationwide community-based organization (CBO)
- Long term, our recommendations to congress are for stricter regulations, prohibiting drone flight within these areas as well as pre-designated LZ’s (vs. a simple requirement to communicate) and to require them to land when within 5 miles of an approaching / departing helicopter or a helicopter in motion (rather than to remain in flight and give right of way, or not interfere). We are also recommending restriction of hobbyist drone operators to day time flight only.
- In Virginia, VA Code 27 15.1 provides authority to Fire-EMS to keep personnel from entering the area of an incident without permission. We are seeking clarification on whether or not that includes keeping equipment (such as drones) from entering the area surrounding an incident, and (if not), recommending a language change to include that in the code.
HEMS programs should develop education for both drone operators and LZ Commanders
Key points for Drone Operators
Why this is important to us? The nature of the HEMS business naturally puts us at risk for mid-air collisions with any other low-level aircraft due to the fact that we have:
- On demand / unscheduled take-offs and landings with
- Time sensitive emergencies in
- Landing areas with limited security, resources, and communications
- Patient privacy
Rules are different, depending on the purpose for which you are flying your drone: 1) Hobbyists / Recreational, 2) Commercial (compensated), and 3) Public Use. Operators need to recognize that the same drone can be flown by the same operator for different purposes and that the rules are dependent upon the purpose of each flight.
Based on Section 336 of PL 112-95 and 49USC, we are advising the non-commercial drone operators that helipads are being considered airports with regards to the requirement to notify prior to flying within 5 miles. However, since helipads are not necessarily controlled by an ATC, drone operators are advised to contact the Flight Operations Center. This is consistent with the B4UFLY app, graphically displaying a 5 mile radius around registered helipads in addition to airports.
Stay current with the most up to date information via the knowbeforeyoufly.org and FAA websites. This info includes but is not limited to:
- Fly below 400 feet and remain clear of surrounding obstacles
- Keep the aircraft within visual line of sight at all times
- Remain well clear of and do not interfere with manned aircraft operations
- Don’t fly within 5 miles of an airport unless you contact the airport and control tower before flying
- Don’t fly near people or stadiums
- Don’t fly an aircraft that weighs more than 55 lbs
- Don’t be careless or reckless with your unmanned aircraft – you could be fined for endangering people or other aircraft
- Register your drone if it weighs more than 0.55 pounds.
Other tips include:
- Consider using apps to identify safe areas for flying your drone
- Some drones have an associated app with geofencing (DJI phantom 2 and above)
- Don’t forget to update your software!
- Some drones have an associated app with geofencing (DJI phantom 2 and above)
- FAA app B4UFly (shows safety areas around helipads)
- Hover app (does not show safety areas around helipads)
- Take the time to identify areas with TFRs
- “Eyes out of Cockpit” concept – Use a “co-pilot” (spotter) to handle distractions such as by-standers and to watch your UAV while you are watching the camera screen.
- Be aware of environmental conditions (wind) and bystanders; both of which can inhibit your ability to fly safely!
Key points for LZ Commanders
Assess: In addition to assessing scene safety around the perimeter, a 3-dimensional approach should be taken, ensuring that the area above the scene is safe as well. A standard assessment includes a review of wires and other obstacles in and around an LZ, as well as drones.
Communicate: Do not assume that the pilot has a visual on the drone. Maintain open communications with the pilot via radio so that you can report drone sightings as soon as possible to maximize reaction time, even if the drone is stationary.
Identify: Identify the drone operator if possible and engage them. Inform them of the boundaries and the requirement to communicate their intent to operate a drone prior to doing so.
Land: When in doubt, have the operator LAND THE DRONE. It is always better to err on the side of caution. No video footage is worth the potential risk of an avoidable incident.
All of the above information can be provided via social media, via PSA’s with local news outlets, or in person in an open forum for both LZ Commanders and drone operators.
HEMS programs should work with each other, industry organizations, and local municipalities to have a bigger voice and impact.
Once you have developed your generic key points, get together with neighboring HEMS programs, state medevac committees, or partner programs within your aviation vendor’s footprint. Share the same key points and materials so that your message is standardized, making it more understandable and creating a synergistic effect.
Work with municipalities on signage on their property surrounding your helipads, indicating that these areas are drone operator-free zones. They may not be able to control the airspace, but they can control the people and vehicles on their property.
Share ideas and tools on the AAMS Vision Zero on-line “toolbox” or though web-based project management tools, where individual programs could share proposed solutions, problems, and progress.
Remember to collaborate with local drone operators themselves. Reach out to both commercial and hobbyist drone operators and ask them to review your key points and materials. Co-present the material at open forums with a shared message.
How do you measure success?
During the first Life-Guard Open Forum for Drone Safety with HEMS, one of the attendees shared that he had previously experienced (what he defined as) a near miss with his drone and our helicopter while in flight. What he described was news to all of us. This example serves as a reminder that flight crew vigilance on its own is not always enough; Vision Zero = VIGILANCE in combination with EDUCATION and AWARENESS – not only for ourselves but also for others with whom we share the air space. The very next day, now armed with knowledge of rules, regulations, and best practices, that same drone operator called our Flight Ops Center to inquire about any in bound aircraft before launching his drone. While this is just one person, we call that success. We believe that Vision Zero is possible, even if it is one by one.
Join the challenge!
Key messages to drone operators: When in doubt, Save a Life and #LandTheDrone
Drone operators and HEMS working together to keep our shared air space a safe air space – #SolidarityForSafety
Susan is the AAMS Region VI Director and a member of the Vision Zero Committee. She serves as Program Director and Flight Nurse with Carilion Clinic Life-Guard. The CAMTS accredited hospital-based flight program has EC135’s based in Hardy, Radford, and Lexington, VA and is part of a ground transportation system with > 40 ambulances in multiple locations throughout the region, including two EMS divisions.
Ty is a Med-Trans Corp / Life-Guard pilot and Base Aviation Manager.
Nick is the Business Development Manager for Carilion Clinic Patient Transportation and Life-Guard.
Together, Susan, Ty, and Nick have worked towards the safe integration of drones with HEMS through the development of education for LZ Commanders and Drone Operators; through PSA’s and interviews with the news media and through open forums in their service area.