Missouri City Police Department FAA BVLOS Case Study
The following is an overview of the set up and operations of MCPD and the results of their Drone as a First Responder (DFR) program
The FAA Process
Missouri City was an interesting case because they are centered directly in between two airports. Their city and the area they would like to cover with their DFR program does not enter a grid square (see below) that is less than 400ft. Missouri City’s JCOA allows operations within class D, E, and G airspace.
It is important to distinguish between the BVLOS authorized operating area and the JCOA operating area. Missouri City has been authorized to waive 14 CFR 91.113(b) (the regulation requiring visual line of sight [VLOS]) within a three mile radius of the launch locations specified. There are three launch locations outlined in the image below by red dots and their surrounding circles. The JCOA spans across Missouri City and includes the Sugar Land airport yet there are no BVLOS operations allowed outside of the specified areas under the JCOA. For the sake of clarity, only the three red circles outlined below may have BVLOS operations. Outside of those, Missouri City may operate under the JCOA following visual line of sight (VLOS) rules. They are using the Knighthawk as they are able to cover most of their city and maintain lots of redundancy in their operations.
Like other Paladin DFR programs, Missouri City will use see and avoid as their primary mitigation for BVLOS missions. A visual observer (VO) must have a clear view of 2 miles around the UAS. Missouri City will leverage officers on patrol as a network of VO’s. The VO’s primary function is to detect smaller obstructions and low flying aircraft. The PIC’s will have RadarBox on at all times to ensure they are aware of aircraft in the area. There does not need to be a visual observer standing on the roof at all hours. In a 24/7 model with four shifts, that eliminates the need to staff four dedicated VO’s per drone which in a three drone model would be twelve VO’s in total. Logistically and financially, using an LTE based drone affords departments the flexibility of leveraging a VO network already on patrol and is the reason why Missouri City can successfully justify and run a DFR program.
Once we submitted the CONOPS, the FAA reached out to schedule a waiver team meeting in which Detective Luis Figueiredo made a presentation summarizing the CONOPS. The focus was to explain the mitigation EPD would use in place of line of sight flying. Because of Knighthawk’s LTE connection, Paladin is able to get BVLOS waivers that do not require a VO on the rooftop such as in a radio-based DFR model. The LTE connection allows the Knighthawk to fly miles away from its home base, a distance from which no singular VO at the launch location could maintain reliable eye contact of the UAS airspace. Instead we use a network of VO’s to accomplish the same goal which drastically reduces both manpower needs and operational costs of the program. The waiver team meeting then consisted of a Q&A session in which the main focus was making sure we had thought of all the potential risks such as an unaccounted for heliport at a hospital. Elizabeth PD was granted their official waiver in May of 2022.