Police, Fire, and EMS Drone Operations: Public Safety COA Rules

Understanding Public Safety COA Authority

Public safety agencies operate under distinct regulatory frameworks that recognize the unique mission requirements and responsibilities of law enforcement, fire departments, and emergency medical services. The Certificate of Waiver or Authorization (COA) provides public safety agencies operational flexibility unavailable to commercial Part 107 operators, allowing expanded capabilities critical for emergency response, investigations, and community protection.

Unlike Part 107, which emerged from commercial drone integration needs, the COA process predates widespread civilian drone use. Originally developed for government agency operations including military and border patrol, COAs have evolved to accommodate state and local public safety agencies deploying drones for increasingly diverse missions. Understanding how COAs differ from commercial regulations and the special provisions granted to public safety agencies helps contextualize the expanding role of drones in law enforcement and emergency response.

Public Safety Certificate of Waiver or Authorization Explained

What is a COA?

A Certificate of Waiver or Authorization is FAA approval allowing public entities to operate aircraft for governmental functions outside normal Part 107 or recreational flying rules. Public safety COAs specifically authorize law enforcement, fire departments, emergency management agencies, and related entities to conduct drone operations supporting their public safety missions.

COAs are issued for specific geographic areas, time periods (typically 2-4 years), and operational parameters. Each COA details:

Geographic boundaries where operations are authorized
Altitude limitations and airspace coordination requirements
Operational scenarios covered (search and rescue, accident investigation, tactical operations, etc.)
Pilot qualification requirements
Aircraft specifications and equipment standards
Safety protocols and emergency procedures
Coordination procedures with air traffic control when operating in controlled airspace

Who Qualifies for Public Safety COAs?

Eligible agencies include:

Municipal, county, and state law enforcement agencies
Fire departments and fire districts
Emergency medical services
Emergency management and disaster response agencies
State and local government agencies with public safety responsibilities
Public universities with law enforcement or emergency response functions

Private contractors working for these agencies generally cannot operate under the agency’s COA—they must hold Part 107 certificates and operate under commercial rules even when contracted for public safety work.

How COAs Differ from Part 107

Operational Flexibility

The fundamental difference is scope of authorized operations. Part 107 establishes baseline rules applicable to all commercial operations, with waivers available for specific additional capabilities. COAs can incorporate broad operational authorities from the start based on agency mission needs.

Key operational differences include:

Altitude operations: COAs can authorize operations above 400 feet AGL when mission requirements justify it
Controlled airspace: Standing authorization for operations in controlled airspace within the COA geographic area without individual LAANC requests
Night operations: Authorized as part of the COA without individual pilot night training requirements
Beyond visual line of sight: Some COAs include limited BVLOS authority for specific scenarios
Operations over people: Greater flexibility for emergency response scenarios
Multiple simultaneous operations: Authorization for coordinating multiple drones in single incidents

Pilot Qualification Requirements

COAs establish pilot qualification requirements tailored to public safety operations rather than following Part 107 certification:

Agencies develop internal training programs meeting or exceeding FAA standards
Initial and recurrent training specific to public safety missions
Scenario-based training for emergency operations
Coordination with other aircraft and ground operations
Privacy and civil liberties awareness

Many agencies require pilots to hold Part 107 certificates as a baseline, then add agency-specific training. However, Part 107 certification is not strictly required if the agency’s training program meets FAA approval standards outlined in the COA.

Administrative Requirements

COAs involve more extensive documentation and oversight than Part 107 operations:

Detailed operations manual approved by the FAA
Maintenance and inspection programs for aircraft
Pilot qualification and training documentation
Operational logs and mission records
Incident and accident reporting procedures
Periodic reviews and COA renewal processes

This administrative burden reflects the expanded operational authorities granted. Agencies must demonstrate sophisticated safety management systems justifying the flexibility they receive.

Common Public Safety Waivers: Night Ops, BVLOS, Over People

Night Operations Authority

Nighttime operations are critical for public safety missions including:

Search and rescue operations that extend past sunset
Criminal investigations and surveillance occurring at night
Traffic accident scene documentation on roadways
Wildfire monitoring and coordination
Tactical operations where darkness provides operational advantage

Public safety COAs routinely include night operations authority without the additional training requirements imposed on Part 107 pilots. However, agencies typically require internal certification including:

Proficiency demonstrations in reduced lighting conditions
Understanding of anti-collision lighting requirements
Visual acuity assessments for night operations
Procedures for operations with artificial lighting (spotlights, vehicle lights)

Beyond Visual Line of Sight (BVLOS)

While full BVLOS operations remain difficult to obtain even for public safety, COAs often include limited BVLOS provisions such as:

Extended visual line of sight (EVLOS): Operations beyond unaided visual range using visual observers, binoculars, or other aids
Corridor operations: BVLOS along defined routes (river searches, road traffic monitoring)
Emergency response BVLOS: Limited authority during active incidents when maintaining visual line of sight is impractical
Controlled area BVLOS: Operations in secured areas where ground personnel ensure airspace separation

These provisions typically require additional safety measures including:

Visual observers positioned along the route
Coordination with local air traffic control
Restricted operating areas closed to other aircraft
Enhanced pilot monitoring and emergency procedures

Operations Over People

Public safety operations frequently involve people—bystanders at emergency scenes, suspects in tactical situations, participants in search and rescue. COAs generally provide broader authority for operations over people than Part 107, recognizing that:

Emergency operations inherently involve people on the ground
Public safety benefits may justify limited risk exposure
Professional operators employ additional safety protocols
Operational areas are often controlled by responding agencies

However, agencies must still minimize risk through:

Aircraft selection prioritizing reliability and redundancy
Operational procedures maintaining safe distances when practical
Coordination with ground personnel about overhead operations
Contingency planning for equipment failures

Controlled Airspace Operations

Public safety agencies often operate near airports within controlled airspace. COAs provide standing authorization for operations within defined geographic areas and altitude blocks, eliminating the need for individual LAANC requests that could delay emergency response.

Typical controlled airspace provisions include:

Authorization for operations below specified altitudes (often 200-400 feet AGL)
Coordination procedures with air traffic control facilities
Real-time notification protocols for active operations
Contingency procedures if manned aircraft approach the area

Training Requirements for Public Safety Pilots

Comprehensive training programs are essential to justify expanded operational authorities.

Initial Training Components

Public safety drone pilot training typically includes:

Regulatory knowledge: FAA regulations, airspace, weather, radio communications
Aircraft systems: Platform-specific operations, maintenance, troubleshooting
Flight skills: Manual control proficiency across various scenarios
Mission-specific operations: Search patterns, evidence photography, tactical support
Emergency procedures: Equipment failures, lost link, flyaways
Coordination: Integration with ground operations, manned aircraft, incident command
Privacy and civil liberties: Legal constraints, policy compliance, data management

Training duration varies but typically ranges from 40-120 hours including classroom instruction, simulator training, and supervised flight operations.

Recurrent Training

Maintaining proficiency requires ongoing training:

Annual or semi-annual recurrent training covering regulatory updates and skill maintenance
Scenario-based training for complex or unusual situations
New equipment and technology integration
After-action reviews of actual incidents
Cross-training with other public safety specialties

Specialized Training

Advanced missions require additional training:

Thermal imaging operations: Interpreting infrared imagery, optimizing camera settings
Tactical operations: High-risk warrant service, barricade situations, active threats
Hazmat and CBRNE: Operating in contaminated environments, detection equipment
Water rescue: Over-water operations, payload delivery, coordination with marine units
Wildfire operations: Coordination with aerial firefighting, smoke operations, safety protocols

Privacy and Civil Liberties Considerations

Expanded operational authorities come with heightened scrutiny regarding civil liberties.

Legal Constraints on Public Safety Drone Use

Public safety agencies face legal limitations including:

Fourth Amendment: Constitutional protections against unreasonable searches apply to drone surveillance
State privacy laws: Many states require warrants or restrict police drone surveillance
Policy limitations: Agencies often adopt policies more restrictive than legal minimums
Data retention rules: Limitations on storing and sharing drone footage
Transparency requirements: Public reporting on drone usage frequency and purposes

Best Practices for Privacy Protection

Leading public safety drone programs implement comprehensive privacy safeguards:

Clear use policies: Written guidelines defining authorized and prohibited uses
Warrant requirements: Obtaining warrants for surveillance even when not legally required
Data minimization: Limiting collection to information directly relevant to incidents
Retention limitations: Deleting non-evidentiary footage within 30-90 days
Audit trails: Logging all drone deployments and footage access
Oversight mechanisms: Civilian review boards or privacy officers reviewing usage
Community engagement: Public education about drone capabilities and limitations
Bias prevention: Training to prevent discriminatory deployment or surveillance

Balancing Public Safety and Privacy

Effective programs balance operational capabilities with community trust:

Deploy drones for specific missions with clear public safety justification
Avoid indiscriminate surveillance or “fishing expeditions”
Communicate transparently about drone usage and privacy protections
Welcome oversight and accountability mechanisms
Regularly review and update policies based on evolving technology and legal standards

Examples of Successful Public Safety Programs

Chula Vista Police Department (California)

Chula Vista operates one of the nation’s most sophisticated drone-as-first-responder programs:

Drones deployed automatically to 911 calls, arriving before ground units
Operations integrated with incident command and dispatch systems
Over 6,000 deployments since program inception
Documented reductions in response times and officer safety improvements
Comprehensive privacy policy and community oversight

The program demonstrates how expanded COA authorities enable innovative public safety applications while maintaining accountability.

Menlo Park Fire Protection District (California)

Fire service drone operations focus on size-up, hazard identification, and resource coordination:

Rapid aerial assessment of structure fires
Thermal imaging to locate fire extension and hot spots
Hazmat incident monitoring from safe distances
Documentation for investigations and training
Integration with mutual aid and regional coordination

Texas Department of Public Safety

Statewide program supporting diverse missions across vast geography:

Border security and surveillance operations
Accident reconstruction on highways
Search and rescue in remote areas
Disaster response and damage assessment
Tactical support for high-risk operations

Applying for a Public Safety COA

Agencies seeking COA authorization must navigate a detailed application process.

Application Requirements

Organization information: Agency authority, mission description, operational need
Aircraft specifications: Make, model, weight, performance characteristics
Geographic operating area: Maps and descriptions of intended operational locations
Operational scenarios: Detailed descriptions of missions and procedures
Pilot qualifications: Training program outline and qualification standards
Safety assessment: Risk analysis and mitigation strategies
Maintenance program: Inspection and maintenance procedures
Operations manual: Comprehensive procedural documentation

Processing Timeline

COA applications typically take 60-90 days for FAA review, though complex applications may require longer. Agencies should apply well in advance of intended operational dates.

Working with the FAA

Successful applications benefit from:

Early consultation with FAA regional flight standards offices
Reviewing successful applications from similar agencies
Demonstrating robust safety management systems
Leveraging industry best practices and standards
Building relationships with FAA personnel responsible for COA oversight

The Future of Public Safety Drone Operations

Public safety drone use continues expanding with several trends emerging:

Drone-as-first-responder programs: Expanding beyond pioneers to more agencies
Autonomous operations: Pre-programmed responses to specific call types
Fleet operations: Multiple simultaneous drones coordinating at large incidents
Specialized payloads: Chemical detection, cellular communications, defibrillator delivery
Integration with smart city infrastructure: Coordination with traffic systems, surveillance networks
Regional cooperation: Shared programs across multiple agencies
Standards development: National standards for equipment, training, and operations

As technology and regulations evolve, public safety agencies will gain even greater capabilities while facing ongoing pressure to demonstrate accountability and respect for civil liberties.

Conclusion

Public safety COAs provide law enforcement, fire, and EMS agencies operational flexibility essential for effective emergency response while maintaining safety standards appropriate to their professional missions. Understanding the differences between COAs and Part 107 commercial operations, the training and oversight required to justify expanded authorities, and the critical importance of privacy protections helps contextualize the growing role of drones in public safety. Successful programs balance operational capabilities with community trust, transparent policies, and robust accountability mechanisms. As drone technology continues advancing and regulatory frameworks mature, public safety applications will expand further, requiring ongoing attention to both operational effectiveness and civil liberties protection.