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Chief Administrative Officer Section 136.0
Policy and Procedures Page 1
136.0 SUBJECT: UNMANNED AIRCRAFT SYSTEMS (DRONE) USAGE
1. OBJECTIVE:
Establish a uniform policy for the usage of unmanned aircraft systems (UAS), also known as drones, by
departments within the City of Orlando.
2. AUTHORITY:
This procedure enacted by City Council on March 19, 2018.
3. DIRECTION:
Chief Administrative Officer, as an appointed official, serves at the pleasure of, and receives direction from
the Mayor or the Mayor’s designee.
4. METHOD OF OPERATION:
A. Policy Approval Required
Any department wishing to utilize a UAS for City business must submit a department wide policy governing
that department’s use of drones to the CAO for approval. No UAS operation, including training, may be
conducted until the CAO, or the CAO’s designee, has approved the department’s policy. Any substantive
changes to a department’s policy must be resubmitted to the CAO for approval. No UAS operations may
be conducted except as permitted by policy.
B. Definitions
(1) UNMANNED AIRCRAFT SYSTEMS (UAS): An unmanned aircraft of any type capable of
directed flight, with the associated support equipment, control station, data links, telemetry,
communications and navigation equipment necessary to operate it. They are also known as drones,
sUAS (Small Unmanned Aircraft Systems), sUA (Small Unmanned Aircraft), or UAV (Unmanned
Aerial Vehicles).
(2) REMOTE PILOT-IN-COMMAND (RPIC): The person who is qualified and designated by the
agency who is directly responsible for and is the final authority as to the operation of the sUAS (as
described by Federal Aviation Regulations (14 CFR Part 91.3)); and holds the appropriate FAA
sUAS airman certificate (if applicable) for the conduct of the flight.
(3) SURVEILLANCE: With respect to an owner, tenant, occupant, invitee, or licensee of privately
owned real property, the observation of such persons with sufficient visual clarity to be able to
obtain information about their identity, habits, conduct, movements, or whereabouts.
(4) VISUAL LINE-OF-SIGHT (VLOS): The ability of the RPIC and/or VO(s) to be able to see and
determine the trajectory of the UAS throughout the entire flight with vision that is unaided other
than by corrective lenses or sunglasses or both, and to determine its movement relative to intruding
aircraft, obstacles, and terrain and observe the airspace for other air traffic or hazards to determine
that the UAS does not endanger the life or property of another.
(5) VISUAL OBSERVER (VO): A person who is designated by the agency and/or RPIC to assist the
RPIC (or the person manipulating the flight controls) to maintain VLOS with the UAS.
Administrative Offices
Chief Administrative Officer Section 136.0
Policy and Procedures Page 2
C. Operation as Public or Civil Aircraft
Any UAS flown by a City department shall be operated as a Public Aircraft Operation (PAO) pursuant to
a Certificate of Waiver or Authorization (COA) or as a civil aircraft operation pursuant to 14 CFR Part 107.
Public Aircraft Operations must be limited to the type of flight permitted by the COA. Only such employees
or contractors who meet FAA requirements to conduct the specific fl ight will be allowed to command a
UAS owned and operated by the City of Orlando.
D. Appointment of UAS Coordinator
The head of each department that operates a UAS shall name a person to be the UAS Coordinator for that
department. The UAS Coordinator must hold a remote pilot certificate from the FAA and shall at minimum
have the following responsibilities:
(1) Apply for, and obtain, a Public Aircraft Operations COA and/or Part 107 clearance.
(2) Apply for additional FAA waivers as necessary (e.g. nighttime flights, flights over people, etc.).
(3) Develop a department specific UAS policy which must be approved by the CAO or the CAO’s
designee prior to any UAS operation.
(4) Develop a training program for UAS operators specific to the requesting City department.
(5) Ensure all UAS operators are allowed to conduct flights under the Public Aircraft Operations COA
and/or Part 107 clearance.
(6) Maintain a log of all flight information, including the location and duration of the flight, weather
conditions at time of flight, purpose for each flight, any damage to persons or property (including
the UAS) that occurred during the flight and any other information deemed necessary by the UAS
Coordinator.
(7) Submit all required information and logs to the appropriate federal, state, or local authority.
(8) Maintain UAS to ensure they remain ready for use in or are removed from use when the UAS no
longer meet manufacture’s specifications for safe operation.
E. Conformity to Federal and State Law
Each UAS Coordinator shall ensure that the department’s UAS policy and operations conforms to current
laws, regulations and best practices.
F. Operations Involving Multiple Departments
Should a UAS operation involve personnel from multiple city departments, all UAS operations must follow
the lead department’s UAS Policy and Procedure and all flights shall fall under the supervision of the lead
department’s UAS Coordinator.
G. Safety
Safety is the highest priority when conducting a UAS operation. It is the responsibility of the UAS
Coordinator and all UAS operators to assess any and all hazards within the flight path of the UAS, and to
prevent the launch or terminate a UAS flight when it is clearly unsafe to conduct the operation. If the UAS
Coordinator, the RPIC, the VO, or any other member of the UAS team objects to the UAS operation due to
safety, the UAS may not be launched, or if in flight, the operation must be terminated as safely and
efficiently as possible.
Administrative Offices
Chief Administrative Officer Section 136.0
Policy and Procedures Page 3
H. Surveillance
No UAS or UAS equipment may be used to conduct surveillance except to prevent imminent danger to life,
pursuant to a warrant issued by judge, or as otherwise expressly permitted by Florida statute.
I. Flight Restrictions
All flights, except as otherwise authorized by the FAA, must be conducted below 400 feet above ground
level (AGL) and must be operated within the VLOS of the RPIC or VO.
5. COMMITTEE RESPONSIBILITIES:
None.
6. EFFECTIVE DATE:
This procedure effective March 19, 2018.