Guidance for Unmanned Aircraft Systems

In some instances, the use of unmanned aircraft systems (UAS) for scientific study may be allowed in units of the national park system. Outside researchers or NPS staff proposing to use UAS for scientific research or stewardship missions should consult with the NPS Park Aviation Manager (PAM) and park research coordinators as early as possible in order to comply with UAS and related requirements. Follow up may occur with Regional Aviation Manager (RAM).

This guidance is not a stand-alone document, nor will it provide all necessary information needed for conducting a UAS operation – it should be used to inform conversations with PAMs/RAMs and park research coordinators. Early consultation with PAMs/RAMs and research coordinators is important because the approval process, authorizing agency, appropriate forms, and associated timelines are functions of many factors including:

• The agency with operational control of the mission (e.g., NPS, other federal agency, outside cooperator).
• Location of takeoff, landing, and operation (e.g., within or outside of the park unit, within or over an area managed as wilderness).
• Characteristics of mission (e.g., altitude, line-of-site).
• Consideration of rules and policies for operations in the National Airspace System; e.g.:
  • Federal Aviation Regulation 14 CFR Part 107 – Operation and Certification of Small Unmanned Aircraft Systems
  • Department of Interior Manuals 350-353
  • Department of Interior Operational Procedures Memorandum (OPM) – 11, DOI Use of Unmanned Aircraft Systems (UAS)
  • NPS Reference Manual (RM) 60, Aviation Management
    • RM 60, Ch. 17 – Unmanned Aircraft Systems
    • RM 60, Appendix 7: NPS Approval Template and Guidance for the Use of Unmanned Aircraft Systems (UAS)
  • NPS Best Practices for Avoiding Impacts to Natural, Cultural, and Historic Resources when Using Unmanned Aircraft Systems
  • DOI Office of Aviation Services compliant aircraft
• Consideration of rules and policies for land-management authorities that address activities on the lands or waters managed by NPS; e.g.:
  • Scientific Research and Collecting Permits
  • National Environmental Policy Act
  • Wilderness Act (minimum requirements analysis)
  • Marine Mammal Protection Act
  • Endangered Species Act
  • Migratory Bird Treaty Act

What are the additional requirements for proposals that include use of UAS?

• The regulatory framework for UAS operations in the National Airspace System (NAS) is primarily contained within Federal Aviation Regulation 14 CFR Part 107 – Operation and Certification of Small Unmanned Aircraft Systems. Deviations from Part 107 require a Certificate of Waiver or Authorization (COA) issued by the Federal Aviation Administration. The authorization (Part 107 or COA) to operate in the NAS should always be confirmed with the respective NPS Park Aviation Manager or Regional Aviation Manager and copies of any written documents examined (e.g., COA). COAs are operation-specific and not a blanket authorization to conduct any mission at any time.
• The pilot-in-command is the final authority for operation of the UAS and responsible for compliance with all federal, state, and local aviation regulations regarding operation, regardless of who holds the SRCP or COA, if applicable.
• Operational control, with respect to a flight, means the exercise of authority over initiating, conducting or terminating a flight (14 CFR 1.1). Operational control depends on who is ordering the flight, who is directing the flight, who is benefiting from the flight, and who is paying for the flight. Ultimately, the National Transportation Safety Board has the regulatory authority to determine operational control. If NPS as an organization has operational control of a mission, U.S. Department of the Interior (DOI), Office of Aviation Services (OAS) must approve the operation pursuant to DOI Operational Procedures Memorandum (OPM) – 11, DOI Use of Unmanned Aircraft Systems (UAS).
• Regardless of who has operational control, NPS must approve the use of UAS pursuant to the procedures and approval template in NPS Approval Template and Guidance for the Use of Unmanned Aircraft Systems (UAS) (Appendix 7 of NPS Reference Manual 60, Aviation Management) for any UAS that takeoff, land, or are operated from land or waters managed by NPS. The approval template includes written demonstration of compliance with Best Practices for Avoiding Impacts to Natural, Cultural, and Historic Resources when Using Unmanned Aircraft Systems referenced in the Appendix 7 template.

What if NPS staff conduct research or administrative missions without an SRCP?

Superintendents may not authorize their staff or cooperators to use UAS for official NPS administrative or research-related duties without obtaining approval from DOI OAS pursuant to OPM – 11 and without obtaining NPS approval pursuant to the NPS approval template (i.e., Appendix 7 of NPS RM 60), including written demonstration of compliance with Best Practices for Avoiding Impacts to Natural, Cultural, and Historic Resources when Using Unmanned Aircraft Systems referenced in the approval template. Requests to Superintendents for permission to use UAS are typically routed through RAMs to the Regional Director.

NPS staff must always comply appropriately with professional standards and with conditions normally associated with SRCPs issued by the park.

What if UAS operations over areas managed as wilderness are proposed?

If some or all of the UAS operations are proposed over or within a location managed by the NPS as wilderness (e.g., designated, recommended, proposed, potential) or in the airspace above such areas, the proposal should describe how the project adheres to NPS management policies regarding “minimum requirements” for wilderness. Consult with the park’s wilderness management plan and park research coordinator for further information.