[POLICY APPLIES ONLY TO WEST HOLLYWOOD STATION]
NOTE: Effective immediately, this policy will only apply to West Hollywood Station. Implementation of this policy Department-wide will be forthcoming.
Purpose
To establish guidelines for the safe, authorized, and effective use of unmanned aerial systems (UAS) that are regulated under the Federal Aviation Administration’s (FAA) Part 107 or require a Certificate of Authorization. UAS can serve as a valuable resource to increase community and officer safety, act as a valuable de-escalation tool, reduce response times, provide enhanced situational awareness, and support personnel in the course of their duties, including the accurate reconstruction of complex traffic crashes and crime scenes.
The Sheriff will establish a Department-wide UAS Operations Unit, which will oversee overall management of UAS Operations, including:
Compliance with laws and policies;
Reporting usage to oversight bodies and the public website;
Establishing training standards;
Acting as the liaison with the Federal Aviation Administration and the National Transportation Safety Board (NTSB);
Developing and maintaining equipment standards;
All Department UAS shall meet technical specifications established by the UAS Operations Unit and may only be purchased, donated, or leased by organizations or contract cities in accordance with Department protocols. Donated or leased UAS equipment must be reviewed and approved by the UAS Operations Unit before acceptance or use.
All software, support systems, or ancillary equipment used in conjunction with Department UAS shall be reviewed and approved by the UAS Operations Unit before acceptance or use.
Overseeing the Safety Management System (SMS) and the UAS Management Software;
Coordinating with individual Unit Commanders and their UAS Program Coordinators to ensure compliance with Department policies and placing restrictions on unit usage because of safety or risk management concerns;
Recommending program enhancements, particularly regarding safety, information security, and privacy protection;
Tracking data for mandated reporting requirements, measuring the effectiveness of the use of UAS to successfully resolve incidents and mitigate the risk of harm to officers, suspects, or the public, as well as an analysis of any complaints received about UAS deployments;
Ensuring established protocols are followed;
Providing periodic reports on the program to the Undersheriff and Sheriff.
Conduct a yearly command inspection of all units authorized to conduct UAS operations
Any Station, Unit, or Bureau wishing to establish a UAS program shall contact the UAS Operations Unit and follow its procedures for establishing a UAS program.
Definitions
Pursuant to Department guidelines and FAA regulations, the following definitions will be used in Unmanned Aerial System operations.
Beyond Visual Line of Sight (BVLOS) - Operation of a UAS beyond the distance at which the remote pilot in command (RPIC) or visual observer (VO) can maintain unaided visual contact with the aircraft to ensure safe and effective control of the flight.
Controlled Airspace - An airspace of defined dimensions within which air traffic control (ATC) services are provided to Instrument Flight Rules (IFR) flights and to Visual Flight Rules (VFR) flights in accordance with the airspace classification (FAA Class B, C, D, or E).
Drone as First Responder (DFR) - The use of a UAS, deployed as an initial responding unit to active calls for service, providing aerial support as an initial responding resource, real-time video, and tactical overwatch to responding field personnel.
Field Deployments - Situations in which a UAS is deployed by a UAS Operator while in the field.
Flight Supervisor - The on-duty Watch Commander, Incident Commander, or Unit Commander designated supervisor responsible for approving deployments consistent with this policy and reviewing mission outcomes.
Photogrammetry - The science of making measurements from photographs, typically producing maps, drawings, measurements, or 3D models.
Remote Pilot-in-Command (RPIC) - The certified personnel responsible for the safe and lawful operation of the UAS during deployment.
Safety Management System (SMS) - A structured framework designed to promote and ensure the safe operation of the Department’s UAS Program. SMS encompasses proactive and reactive strategies to analyze, identify, and mitigate hazards.
Unmanned Aerial System (UAS) - A UAS is an unmanned aerial system, including the equipment necessary for that aircraft’s safe and efficient operation. It is defined by statute as an aircraft that is operated without the possibility of direct human intervention from within or on the aircraft.
UAS Department Program Commander – Personnel holding the rank of Lieutenant or above who is designated to oversee UAS Operations Department-wide.
UAS Program Coordinator - Personnel holding the rank of Sergeant or above who is designated to oversee the unit’s UAS operations.
UAS Operator - A trained, certified member of a patrol station or unit authorized to deploy and operate UAS for missions consistent with this policy.
UAS Management Software - Software used for managing, tracking, and maintaining the Department’s UAS fleet.
Visual Observer (VO) - A person who assists the RPIC in the duties associated with collision avoidance. These duties include, but are not limited to, avoidance of other traffic, clouds, obstructions, and terrain.
Deployments
The UAS may be utilized to enhance the Department’s mission of protecting lives, preserving property, and supporting the collection of evidence. All Department UAS deployments shall be conducted in a manner that is consistent with the requirements and protections of the United States Constitution and the California State Constitution, and pursuant to all applicable laws and regulations.
The policy authorizes the deployment of UAS as an initial responding resource for any Department unit that has an established UAS Program. All UAS programs must be approved by the UAS Operations Unit. The UAS may be launched for real-time crime scene awareness, crime scene or traffic collision documentation, and tactical assessment prior to the arrival of ground units. The authority to deploy remains with the Flight Supervisor, who shall ensure compliance with this policy, including required reporting to the UAS Operations Unit. All UAS deployments shall be documented and reported to the UAS Operations Unit within 48 hours of deployment.
Specialized units, such as the Special Enforcement Bureau (SEB), Detective Division units, Emergency Operations Bureau (EOB), Scientific Services Bureau, and other non-patrol-based bureaus, may deploy UAS to support tactical, investigative, or emergency response operations. All deployments must comply with FAA regulations, Department UAS Program guidelines, and this policy. Use of a UAS by specialized units shall be incident-driven and must be approved by the designated Incident Commander overseeing the scene. UAS missions conducted for crime scene documentation, search and rescue, surveillance during exigent operations, or support of warrant service shall be documented and reported to the UAS Operations Unit within 48 hours of deployment.
The UAS flight crew (i.e., UAS Operator, RPIC, and VO) shall take reasonable precautions to avoid inadvertently recording or transmitting images of area(s) where there is a reasonable expectation of privacy. Reasonable precautions can include, for example, deactivating or turning imaging devices away from such areas or persons during UAS operations and when recording flights pursuant to this policy. However, when exigent circumstances exist, flight crews may adjust the imaging scope and its positioning as operationally necessary to address the emergency, while continuing to minimize unnecessary intrusion into private areas.
UAS deployments shall only be conducted by trained and certified personnel with the oversight of a Flight Supervisor or the UAS Operations Unit. All operations shall meet the following standards:
All UAS operators must be FAA-certified and complete Department-approved UAS training;
All flights must adhere to regulations established by the FAA; and
Deployments to monitor a pre-planned public event must be done with the approval of the unit’s Division Chief.
The Remote Pilot in Command (RPIC) of a UAS is directly responsible for, and is the final authority as to, the operation of that UAS.
NOTE: A UAS deployment alone does not constitute a response to a call for service (see MPP section 2-06/030.05, Patrol Responsibility).
Prohibited Uses
Department UAS shall not:
Be used to unlawfully harass, intimidate, or discriminate against any individual or group;
Be used to randomly surveil any member of the Department, of the public, or an area without a nexus to Public Safety;
Be used to record or photograph any First Amendment assemblies for the purpose of identifying participants who are not engaged in unlawful conduct;
Be conducted when conditions present an unreasonable risk observed by the RPIC at the time of the mission;
Be used for any personal business;
Be equipped with weapons or any form of less-lethal munitions, or any facial recognition software; and
Be used in a manner or used with any software or added equipment that is contrary to any additional restrictions imposed by the Department-wide UAS Program Commander.
No Department member shall deploy a personally owned UAS while on duty.
Training and Certification
All UAS operators shall maintain a current FAA certification and complete the Department’s designated training course. UAS Operations Unit shall maintain records of certification, training, and flight hours for all operators. Training beyond the minimum required standards will be supported and encouraged.
Flights for the purposes of training or maintaining proficiency are allowed under this policy. All training flights must be logged.
Data Retention and Evidence
Absent exigent or unexpected circumstances, the UAS Program Coordinator shall ensure any UAS deployment and associated digital data (photos and video) are captured and retained in accordance with Department policy in the Department’s specified digital evidence management system (DEMS).
Recording
For deployments regarding real-time crime scene awareness and tactical assessment prior to the arrival of ground units, recording each incident shall begin at or near the scene of the incident and continue to record until the UAS leaves the location or the investigative or enforcement activity has ended. Unless necessary for safe operation, while in transit, UAS camera systems must be directed toward the horizon and may only be activated for recording at or near the incident scene. Safeguarding the privacy of the community is paramount. As such, RPICs are reminded that they shall take reasonable precautions to avoid inadvertently recording or transmitting images of areas where there is a reasonable expectation of privacy.
For missions where the primary purpose is photography or photogrammetry, prior to or at the completion of an incident, video recording is not required.
Field Deployments
When deploying a UAS in the field, the UAS operator should consider the use of a VO when practical. Deconfliction with manned aircraft is of paramount importance. The RPIC and VO are responsible for ensuring safe interactions.
UAS Program Coordinator Responsibilities
The UAS Program Coordinator shall:
Ensure their unit’s UAS fleet is properly maintained, and the equipment is inspected regularly, including applicable firmware and software updates to ensure privacy, security, and integrity of evidence;
Ensure all maintenance is properly documented;
Ensure any personnel operating a UAS within their unit have successfully completed and maintained the proper certification and training;
Ensure a thorough weekly report of all required UAS usage data is maintained at the unit and submitted to the UAS Operations Unit; and
Ensure all reporting requirements pursuant to Department policy and Government Code 7070 et seq. are adhered to.
Accident Reporting
In the event the UAS is involved in a collision or accident, the UAS Operator shall immediately notify the Flight Supervisor and the FAA if applicable. It shall be the responsibility of the Flight Supervisor to make notifications to Aero Bureau, and UAS Operations Unit. The UAS Operations Unit shall be responsible for coordinating with the Aero Bureau for notifications to the FAA and NTSB as applicable.
A supervisor shall respond to the scene to ensure the procedures of an aircraft collision are followed. The supervisor shall also be responsible for documenting the collision in a detailed memorandum.
The detailed memorandum shall include photographs of the UAS, the surrounding environment, and any involved property. Supervisory personnel shall ensure the collection of statements from involved members of the public and witnesses, obtain identification of any civilians affected, and ensure preservation of relevant digital flight logs and data from the UAS. The supervisor will also obtain from the RPIC a summary of the mission type, conditions at the time of the incident, contributing factors, and any operational anomalies that occurred. The UAS Program Coordinator for the unit shall conduct a review of the incident, and a memo shall be submitted to the UAS Operations Unit detailing the collision.
Personnel involved in the operation of the UAS at the time of the collision shall provide a safety statement. Including: location of collision, any potential immediate hazards (i.e., power lines or similar hazards), any potentially injured persons, and any damaged property.
**Incidents involving injury to non-employees, however minor, while on County property (owned or leased) must be reported on the Non-Employee Injury Form (SH-AD-668) and distributed as indicated on the form.
All UAS collisions that meet FAA-reportable thresholds—such as incidents involving serious injury, loss of consciousness, or property damage in excess of $500 (excluding the drone itself)—shall be reported by the RPIC to the FAA and the NTSB within ten calendar days, as required under 14 CFR Part 107. The UAS Operations Unit, in conjunction with Aero Bureau, will ensure this notification is completed by the RPIC as required. “Damage to County Property” report shall also be completed and submitted to the Risk Management Bureau, consistent with Department policy for deputy-involved vehicle crashes. All documentation, including photos, witness statements, and internal reports, shall be retained by the UAS Operations Unit.
Use of UAS Owned or Operated by an Outside Agency
Personnel may request and utilize the UAS of an outside public safety agency when the Department’s operational needs warrant support and all the following conditions are met:
The deployment must comply with the standards, restrictions, and operational expectations outlined in the MPP, including the reporting of each deployment;
The use of an outside agency’s UAS must be authorized by the on-duty Watch Commander or Incident Commander and reported to the UAS Operations Unit within 48 hours of deployment; and
A complete copy of any digital data collected by the outside agency’s UAS must be requested by LASD personnel. Any digital media must be retained in accordance with Department policy.
If the outside agency does not provide the material requested, it should be documented accordingly.
Reporting of Each Deployment
The operator of each UAS must report each deployment and use of the UAS. The reporting shall take place in the Military Equipment Management System (MEMS), the electronic UAS system log. The electronic log will provide pertinent information, including the incident number, the time, location, UAS operator’s identifying information, the type of incident, and the results of the deployment.
Military Equipment Reporting
UAS devices are considered military equipment under California Government Code Section 7070 et seq., and require annual reporting on their use and involved costs. The UAS Operations Unit is responsible for collecting all inventory, procurement, recording costs, managing training requirements, and ensuring accurate reporting in the Department’s annual military equipment report.
Public Notification and Transparency
Before a station begins use of UAS pursuant to this policy, a community outreach plan shall be developed and implemented in collaboration with local stakeholders (e.g., a station’s Community Advisory Committee (CAC) or other community groups). Metrics evaluating flight time, response time reduction, evidentiary value, community satisfaction, and complaint trends shall be collected, consistent with the Department-wide UAS data collection efforts. Stations shall report their data in a timely manner in order to ensure that the monthly Department-wide data reports can be completed in a timely manner. Each station shall evaluate its individual metrics for program effectiveness at the station or unit level.
The UAS Operations Unit shall maintain a UAS dashboard on the Department’s Transparency Page, which will be updated regularly, but not less than monthly. This dashboard shall include information, including the number of flights, locations, and types of calls on all UAS deployments except for those related to ongoing investigations.
In addition, the Department will provide the Civilian Oversight Commission with an annual report summarizing UAS usage (including the number and type of situations in which UAS devices were used), the results and effectiveness of any deployments to mitigate the risk of harm to officers, suspects, or the public, the nature and number of any complaints received, and any policy exceptions. This report will also be posted on the Department’s website.