Regulatory Considerations – Federal Aviation Administration (FAA)- Applying for the Emergency Certificate of Authorization (eCOA)
The current regulatory criteria for the use of unmanned aircraft requires any agency that wishes to utilize UA have a standing Certificate of Authorization (COA). A Certificate of Authorization is specific to the type of aircraft that may be utilized and the area in which it operates.
Prior to this event occurring, the Wimberley Fire Department had a Certificate of Authorization (issued in December 2014) for the Spectra flying wing (a four-foot, five-pound fixed wing unmanned aerial vehicle), with an operational area of two nautical miles from the Winn Ranch Airport (closed) located in Wimberley. To operate outside these confines, the Wimberley Fire Department was required to submit an Emergency Certificate of Authorization (eCOA) application to the Federal Aviation Administration (FAA) for approval.
The eCOA contains all the parameters approved by the FAA under the original application with the inclusion of additional areas of flight operations or conditions. This application is submitted in writing, along with a statement of need, to the Washington D.C. Office of the Air Traffic Control (ATC) for Risk Assessment. Changes may be made to the application by ATC prior to the application progressing to the local Flight Service District Office (FSDO) for coordination and final approval.
The initial challenges in this process is that 1) it began after-hours, 2) was on a holiday weekend and 3) communications were compromised by the flood to the point whereby only the occasional voice contact and text message could be made via cell phone. During this event, adhering to the formal FAA process was a technical impossibility without undue delays in the issuance of the eCOA.
To their credit, the on-call individual at Air Traffic Control accepted the initial request by the Wimberley Fire Department’s unmanned aerial team pilot using a simple text message and referencing the existing COA number. The Emergency Certificate of Authorization required minimal adjustments, again via text, and the FAA strongly recommended a TFR area be established to protect the airspace over the search area. Control of Air Space - How to Manage a Temporary Flight Restriction (TFR) Area and Why
A TFR is used to protect a portion of the National Air Space (NAS) under circumstances that could endanger general aviation or the operations being conducted in a defined area.
Flood rescue operations performed by National Guard Blackhawks began early Sunday morning following the overnight flooding. These aircraft operated safely in the area. All resources were focused on locating and rescuing the individuals known to be, or presumed to be, in the water.
Texas Task Force 1 (TXTF1) arrived to begin search efforts in coordination with Incident Command. At the same time, the private search effort (see page 7) was started by an out-of-town family. At Incident Command, the Wimberley unmanned aerial flight crew was on site, but not deployed. A TFR was in place so that the Blackhawks could operate, but was cancelled at the time of their departure.
Additionally, Texas Search and Rescue (TEXSAR), an all-volunteer search organization, arrived to augment TXTF1. TEXSAR was soon deployed to Blanco to assist in the Blanco County search and rescue effort. During the next few days, the airspace became increasingly crowded as STAR Flight, Texas State Parks and Wildlife, Blackhawks, and other agency-manned assets entered the disaster zone.
On day two, the Wimberley Fire Department’s unmanned aerial team could not deploy in the Wimberley area, despite requesting and receiving the approved eCOA, as the airspace was increasingly occupied by manned aircraft.
Communication was soon established between the Wimberley Fire Department and the Blanco County Incident Command. Blanco County requested assistance from the Wimberley Fire Department’s unmanned aerial team, and they were subsequently deployed on day three. Wimberley Fire Department’s unmanned aerial team determined that Blanco County would require a separate TFR area to protect all air operations taking place in that community.