Review of the U.S. Department of the Interior (DOI) Unmanned Aircraft Systems (UAS) Program May 30, 2021 - UNCLASSIFED - NON-SENSITIVE

 
Review of the U.S. Department of the Interior (DOI) Unmanned Aircraft Systems (UAS) Program May 30, 2021 - UNCLASSIFED - NON-SENSITIVE
UNCLASSIFED – NON-SENSITIVE

        Review of the U.S. Department of the Interior (DOI)
            Unmanned Aircraft Systems (UAS) Program

                              May 30, 2021

                                                       UNCLASSIFIED
Review of the U.S. Department of the Interior (DOI) Unmanned Aircraft Systems (UAS) Program May 30, 2021 - UNCLASSIFED - NON-SENSITIVE
Executive
                                                                          Aviation
                                                                          Subcommittee
                                                                          Signature Page
                         Digitally signed by DAVID
 DAVID                   ROSSER

 ROSSER                  Date: 2021.06.02
                         07:41:16 -06'00'                                         DATE:
(EAS Chair, Bureau of Reclamation)

                         Digitally signed by
 SUSAN                   SUSAN BATES

 BATES                   Date: 2021.06.02
                         08:33:00 -06'00'                                         DATE:
(EAS Vice Chair, Office of Aviation Services)

                        Digitally signed by Joel

Joel Kerley Kerley
            Date: 2021.06.03
                        14:57:36 -06'00'
                                                                                  DATE:
(EAS Member, Bureau of Indian Affairs)

                         Digitally signed by
BRADLEY                  BRADLEY GIBBS

GIBBS                    Date: 2021.06.02
                         10:59:30 -06'00'                                         DATE:
(EAS Member, Bureau of Land Management)

                         Digitally signed by
RICHARD                  RICHARD KNOWLES

KNOWLES                  Date: 2021.06.03
                         08:21:07 -08'00'                                         DATE:
(EAS Member, Bureau of Ocean Energy Management)

                         Digitally signed by
 ANDREW                  ANDREW WAREHAM

 WAREHAM                 Date: 2021.06.02
                         08:36:27 -08'00'                                         DATE:
(EAS Member, Bureau of Safety and Environmental Enforcement)

                         Digitally signed by
                         MANUEL LASCANO
 MANUEL LASCANO Date: 2021.06.11
                         11:51:47 -06'00'                                         DATE:
(EAS Member, U.S. Fish and Wildlife Service)

                        Digitally signed by JOHN
JOHN                    BUEHLER

BUEHLER                 Date: 2021.06.03
                        10:25:33 -06'00'                                          DATE:
(EAS Member, National Park Service)

                        Digitally signed by DAVID
DAVID                   ROSSER

ROSSER                  Date: 2021.06.02
                        07:41:51 -06'00'
                                                                                  DATE:
(EAS Member, Office of Surface Mining Reclamation and Enforcement)

                        Digitally signed by WILLIAM
WILLIAM                 CHRISTIANSEN
CHRISTIANSEN            Date: 2021.06.03 12:56:02
                        -06'00'
                                                                                  DATE:
(EAS Member, U.S. Geological Survey)

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Executive Aviation
                                                                            Subcommittee
                                                                            Signature Page

CHRISTOPHE Digitally signed by
            CHRISTOPHER BEARDSLEY

R BEARDSLEY -06'00'
            Date: 2021.07.22 10:49:39
                                                                                     DATE:
(EAC Chair, Bureau of Reclamation)

                         Digitally signed by MARK
MARK                     BATHRICK

BATHRICK                 Date: 2021.08.24
                         16:29:07 -04'00'                                            DATE:   08/24/2021
(EAC Vice Chair, Office of Aviation Services)

                        Digitally signed by PETER
                        WAKELAND
PETER WAKELAND Date: 2021.07.06
                        15:59:53 -07'00'
                                                                                     DATE:   07/06/2021
(EAC Member, Bureau of Indian Affairs)

                         Digitally signed by
GRANT                    GRANT BEEBE

BEEBE                    Date: 2021.06.28
                         11:20:31 -06'00'                                            DATE:
(EAC Member, Bureau of Land Management)

                         Digitally signed by JAMES
JAMES                    KENDALL

KENDALL                  Date: 2021.06.30
                         11:50:22 -08'00'                                            DATE:   06/30/2021
(EAC Member, Bureau of Ocean Energy Management)

                         Digitally signed by
STACEY                   STACEY NOEM

NOEM                     Date: 2021.07.01
                         15:32:10 -04'00'                                            DATE:
(EAC Member, Bureau of Safety and Environmental Enforcement)

                         Digitally signed by
 JEROME                  JEROME FORD

 FORD                    Date: 2021.07.06
                         18:13:22 -04'00'                                            DATE:
(EAC Member, U.S. Fish and Wildlife Service)

JENNIFER                Digitally signed by JENNIFER FLYNN

FLYNN
                        Date: 2021.07.21 17:01:50 -04'00'

                                                                                     DATE:
(EAC Member, National Park Service)

                        Digitally signed by
THOMAS                  THOMAS SHOPE

SHOPE                   Date: 2021.07.07
                        09:14:30 -04'00'
                                                                                     DATE:
(EAC Member, Office of Surface Mining Reclamation and Enforcement)

BRIAN                   Digitally signed by BRIAN WACHTER

WACHTER
                        Date: 2021.08.18 08:59:43 -04'00'

                                                                                     DATE:
(EAC Member, U.S. Geological Survey)

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                                                    TABLE OF CONTENTS
List of Figures ............................................................................................................................................... 5
List of Tables ................................................................................................................................................ 5
EXECUTIVE SUMMARY .......................................................................................................................... 6
SECTION ONE ............................................................................................................................................ 7
A. PURPOSE ............................................................................................................................................... 7
B. BACKGROUND..................................................................................................................................... 8
C. REVIEW SCOPE .................................................................................................................................... 9
D. DOI UAS PROGRAM HISTORY.......................................................................................................... 9
SECTION TWO.......................................................................................................................................... 11
COMPREHENSIVE DOI UAS PROGRAM REVIEW............................................................................. 11
E. PREVIOUS REVIEWS......................................................................................................................... 11
F. DOI UAS PROGRAM OBJECTIVES .................................................................................................. 13
G. AUTHORITY, LEGAL AND REGULATORY COMPLIANCE........................................................ 18
H. COLLABORATION IN PROGRAM DEVELOPMENT .................................................................... 19
I. DOI UAS REQUIREMENTS ................................................................................................................ 20
J. SECURITY ............................................................................................................................................ 24
K. SAFETY ............................................................................................................................................... 37
L. UAS PROGRAM OVERSIGHT........................................................................................................... 37
M. DOI FLEET & CONTRACTED UAS ................................................................................................. 38
N. PROGRAM COST................................................................................................................................ 39
O. MEASURED DOI UAS PROGRAM OUTCOMES 2010 - 2019........................................................ 40
P. IMPACTS OF UAS GROUNDING ON DOI MISSIONS & CURRENT ADMINISTRATION
EXECUTIVE ORDERS AND SECRETARY ORDERS........................................................................... 42
Q. ASSESSMENT OF “BLUE UAS” ALTERNATIVES ........................................................................ 51
R. FINDINGS / CONCLUSIONS ............................................................................................................. 53
T. RECOMMENDATIONS ...................................................................................................................... 56
APPENDIX A - August 13, 2012 - DAS PRE UAS Memorandum to Bureau Directors........................... 58
APPENDIX B – DOI Fleet and Contract UAS Inventory .......................................................................... 61
APPENDIX C - USGS Operational Testing............................................................................................... 66

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                                                                List of Figures

Figure 1 - Raven A/B & T-Hawk Excess DOD sUAS Obtained by DOI for Operational Test & Evaluation
in Support of DOI UAS Program Requirements Development .................................................................. 10
Figure 2 - Drones Provide Unique Safety and Productivity Opportunities in Responding to Wildfires ... 14
Figure 3 - Drone DJ article on May 27, 2018 DOI UAS-Enabled Rescue of Resident from Fast-Moving
Nighttime Lava Outbreak ........................................................................................................................... 15
Figure 4 - Examples of How Drones Support Coordinated Wildfire Operations ....................................... 16
Figure 5 - The “Four Outcome S’s” of DOI’s “Drones for Good” UAS Program ..................................... 17
Figure 6 - Legal and Regulatory Requirements for Federal Aviation Programs ........................................ 18
Figure 7 - DOI UAS Program Collaborative Network ............................................................................... 20
Figure 8 - Systems Engineering Approach to DOI UAS Requirements Development............................... 22
Figure 9 - Authority to Operate (ATO) Definition and Conditions that Require One................................ 29
Figure 10 – DOI UAS Program Cybersecurity Defense-in-Depth Strategy ............................................... 30
Figure 11 - June 2011 UAS Incident Lessons Learned Flyer ..................................................................... 37
Figure 12 - DOI Drone and Services Procurement Decision Considerations Quad-Chart ......................... 39
Figure 13 - DOI Trained and Certified UAS Operators by Bureau - FY 2020........................................... 40
Figure 14 - DOI UAS Program - Sample Outcome Metrics....................................................................... 42
Figure 15 - 2019 DOI Bureau UAS Flight Usage Projections Through 2025 ............................................ 43
Figure 16 - Impact of SO 3379 UAS Grounding, Procurement & Training Cessation on DOI Wildland
Fire Response.............................................................................................................................................. 44
Figure 17 - DOI UAS Program Flights 2010 - 2021 (Projected) ................................................................ 44
Figure 18 - Annual DOI UAS Flight Count by Primary Flight Use (2017 - 2020) .................................... 45
Figure 19 - Cliff-Side Native American Granary – Imaged by BLM UAS, Safely and Without Site
Disruption - 2017 ........................................................................................................................................ 46
Figure 20 - Hoover Dam rock face UAS data showing rock fall above visitor center and parking garage -
January 2019. Prior to UAS, obtaining this imagery necessitated rope access to the rockface. ................ 47
Figure 21 - Meshed model of Arrowrock Dam, Idaho, with a photorealistic texture captured a UAS in
1/7th the time and via safer means than via traditional methods of documenting infrastructure................. 47
Figure 22 - USGS UAS-Based Modeling of Dinosaur Ridge, CO Rockfall Hazard - 2019....................... 49
Figure 23 - USGS UAS-Based Doppler Radar Measurement of River Velocity - 2018 ............................ 50
Figure 24 - Comparison of the U.S. Army Short Range Reconnaissance (SRR) sUAS Specification
Against Master UAS Requirements for the DOI ........................................................................................ 51
Figure 25 - Comparison of Payloads Available to U.S. Army Short Range Reconnaissance (SRR) sUAS
and Various DOI UAS from the Master UAS Requirements for the DOI - DOI UAS Payload
Requirements .............................................................................................................................................. 52
Figure 26 - DOI UAS Program - Delivering Performance, Affordability, and Scalability in Compliance
with the Federal Aviation Regulations and Buy America Act.................................................................... 57

                                                                 List of Tables
Table 1 - DOD and DOI UAS Mission and Operating Environment Comparison..................................... 25
Table 2 - DHS CISA Senior Advisor Assessment of DOI Compliance with CISA Best Practices
Document.................................................................................................................................................... 33
Table 3 - Comparison of DOD and DOI Commercial UAS Waiver Policy and "Covered / Designated"
UAS Definitions.......................................................................................................................................... 36
Table 4 - DOI UAS Inventory, Manufacture & Component Country-of-Origin, and Security Protocols .. 61

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                                EXECUTIVE SUMMARY
On October 30, 2019, DOI leadership ordered the immediate cessation of all non-emergency UAS
missions, with the potential to revise or modify the cessation following the conduct of a
“comprehensive review of its drone program.” On January 29, 2020, Secretary Order 3379
reaffirmed the grounding while promising further guidance “based on completion of an ongoing
review.” A thorough study of available Federal records produced no indication that the twice-
referenced review was conducted. In accordance with its charter “to provide executive-level
aviation oversight within the bureaus and the DOI,” Interior’s Executive Aviation Committee
(EAC) and its Subcommittee (EAS) conducted a comprehensive review of the DOI UAS Program
to inform incoming leadership. This report outlines the results, findings, conclusions, and
recommendations of this review. DOI is the steward of the “people’s land;” 500M acres of diverse
natural and cultural wonders that are visited annually by hundreds of millions of foreign and U.S.
visitors. Since its initiation in 2006, the current DOI UAS program has become a recognized leader
in the safe, secure, and responsible integration of drone technology in domestic government
applications. Foundational principles of DOI’s “Drones for Good” program included security,
support for American business, safety, privacy, transparency, cost-wise management, and
disciplined requirements adherence. DOI achieved secure UAS operations through a multi-
layered, defense-in-depth strategy of publicly posted technical specifications, policy, training,
oversight, mission procedural elements that were commensurate with DOI’s unique, mostly
benign, low-risk operating environment and near-total access to the public. As a result, DOI has
completed over 33,000 UAS flights in 47 States with no data security breaches or complaints from
the public. All DOI UAS procurements have complied with Federal Acquisition Regulations
(FAR) and the Buy American Act (BAA), with nearly 60% of its UAS fleet sourced from U.S.
based companies and 100% procured from U.S. distributors. DOI has also documented
measurable outcomes of how UAS enhance science and climate change research, improve
employee and public safety, deliver recurring savings, and provide responsive service, particularly
in historically underserved mission areas and geographic regions than before. The review found
no technical basis for the previous grounding orders. Rather, it found that a country-of-origin ban
is not a recognized security strategy and one that could actually increase security risk by giving a
“free-pass” to non-designated countries. It also found documentation of federal cybersecurity
professionals who had reviewed and endorsed DOI’s multi-layered, risk-managed, requirement-
based UAS security approach. In contrast, the review found the grounding actions and the
cancellation of planned UAS procurements and operator training classes had significantly
impacted the bureaus’ ability to conduct scientific and climate change missions, ensure scientific
integrity and data transparency, safeguard employee and public safety, deliver recurring savings,
and service historically underserved missions and communities. The review also closely examined
available “Blue sUAS” alternatives, finding they failed to meet a majority of published DOI UAS
platform and payload requirements; facts evidenced in DOI bureau flight tests. The review also
discovered a DOD report to Congress that questioned the provenance of “Blue UAS” as being free
of significant components manufactured by a foreign adversary. The review determined the DOI
UAS program had, before SO 3379 complied with both the security and Buy American intent of
Executive Order (EO) 13981. Finally, the review established that if left in place, adverse impacts
of SO 3379 on DOI’s ability to meet Administration priorities on climate change, scientific

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integrity, environment justice, promoting health and safety, and providing support to historically
underserved areas will continue to increase in 2021 and beyond.
Based on the results, findings, and conclusions of this comprehensive review, the
Interior Executive Aviation Committee recommends the Secretary a) support the development
and implementation of a Secretary Order (SO) that supersedes or amends SO 3379 to restore
bureaus’ authorization to utilize current DOI UAS under Interior’s proven defense-in-depth
security risk mitigation strategy and to procure new UAS in accordance with applicable
provisions of the Federal Acquisition Regulations, the Buy American Act, and the
principles expressed in EO 13981 and b) immediately resume routine UAS flights for science
and operational missions using best practices to fly safely and cyber-secure during the
development of the new or revised SO.

                                     SECTION ONE

A. PURPOSE

1. The purpose of this report is to document the results of a comprehensive review of the U.S.
Department of the Interior (DOI) UAS program. Such a review was referenced in two prior
Interior directives (October 30, 2019 1, January 29, 2020 2) mandating the temporary cessation of
non-emergency UAS fleet operations. Similar, government-wide assessments are mentioned in a
January 18, 2021, Presidential Executive Order (EO 13981) on UAS. 3

2. This review was conducted under the auspices of the DOI Executive Aviation Committee
(EAC) and Executive Aviation Subcommittee (EAS). The EAC is comprised of Senior
Executive Service (SES) level representatives from each of the nine DOI bureaus, the Interior
Business Center Acquisition Services Directorate (IBC-AQD), and the Office of Aviation
Services (OAS). 4 Among the EAC’s chartered responsibilities is to ensure Department-wide
aviation strategies and initiatives are developed and implemented consistently and to provide
executive level consultation in the formulation of Department aviation policy. 5 Chartered by
and accountable to the EAC, the EAS serves as the Subject Matter Experts (SME’s) in all
aviation issues for the DOI. 6 The EAS serves as the primary working group for EAC, providing
expertise to the EAC in the development of DOI aviation strategies, business practices, and
policies.

In accordance with the EAC’s charter, findings, conclusions, and recommendations from this
review and contained in this report are intended to inform senior DOI leadership in making
decisions on the future of the DOI UAS program in support of Administration priorities, goals,
and objectives.

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B. BACKGROUND

1. On October 30, 2019, at the direction of the Secretary, the Principal Deputy Assistant
Secretary for Policy, Management and Budget (PDAS PMB) sent an email to all Interior Bureau
Directors directing “that effective immediately, and until further notice, all non-emergency
missions for drones owned or leased by the Department of the Interior and its bureaus are to
cease.” 7 The Interior Office of Aviation Services (OAS), the Interior Executive Aviation
Committee (EAC) or the bureau National Aviation Managers of the Interior Executive Aviation
Subcommittee (EAS) were not consulted prior to this action. Also, this direction to bureau and
office directors provided no underlying reason for this action. It did allow for the use of DOI
UAS for “emergency purposes, such as fighting wildfires, search and rescue, and dealing with
natural disasters that may threaten life or property.” In addition to the cessation of all non-
emergency missions, bureau requested UAS procurements that had not been executed to that
point were not approved and scheduled Interior UAS training courses were cancelled. PDAS
PMB further advised the bureaus: “This direction may be revised after the Department has had
the opportunity to conduct a comprehensive review of its drone program.”

2. On January 29, 2020, the Secretary issued Secretary Order (SO) 3379, the Temporary
Cessation of Non-Emergency Unmanned Aircraft Systems Fleet Operations, formalizing the
grounding order of October 30, 2019. The Order’s stated purpose was “to better ensure the
cybersecurity and supply of American technology of unmanned aircraft systems (UAS) procured
for use and operation in support of the Department of the Interior's (Department) mission.” SO
3379 directed Interior Bureau Directors and Office Heads to take the following actions:

(1)   Limit Department funds from being expended for Designated UAS.
(2)   Condition all Department contracts, grants, and cooperative agreements relying on UAS
      for achieving approved objectives on the requirement that funds will not be expended on
Designated UAS.
(3)   Condition all parties' operations pursuant to a Department contract, grant or
cooperative agreement on the requirement that Designated UAS will not be operated on
Department- managed lands.
(4)   Execute their responsibilities under this Order consistent with guidance from AS - PMB.

The Order also delegated the authority for issuing any necessary implementing guidance,
determining any required reporting, and approving any deviations or waivers from SO 3379 to
the Interior Assistant Secretary for Policy, Management and Budget (AS PMB).

3. As in the October 30, 2019, grounding email from PDAS PMB, Secretary Order 3379 alluded
to the potential for future guidance subsequent to the completion of a review: “Pending further
guidance based on completion of an ongoing review, the fleet is grounded with the exception of
emergency operations described in guidance to be issued by the Assistant Secretary - Policy,
Management and Budget (AS - PMB).”

4. On January 18, 2021, President Trump signed Executive Order (EO) 13981 – Protecting the
United States From Certain Unmanned Aircraft Systems. EO 13981 does not ban the
procurement or use of foreign UAS. However, it states “it is the policy of the United States,
therefore, to prevent the use of taxpayer dollars to procure UAS that present unacceptable risks

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and are manufactured by, or contain software or critical electronic components from, foreign
adversaries, and to encourage the use of domestically produced UAS.” The EO requires heads
of all executive departments and agencies review their respective authorities to determine
whether, and to what extent consistent with applicable law they could cease procuring, providing
grants, and entering into contracts, for covered UAS. It mandates that “within 60 days, the heads
of all agencies shall each submit a report to the Director of National Intelligence and the
Director of the Office of Science and Technology Policy describing the manufacturer, model,
and any relevant security protocols for all UAS currently owned or operated by their respective
agency, or controlled by their agency through a third party, such as a contractor, that are
manufactured by foreign adversaries or have significant components that are manufactured by
foreign adversaries.” It also directs that ”within 180 days of the date of this order, the Director
of National Intelligence, in consultation with the Secretary of Defense, the Attorney General, the
Secretary of Homeland Security, the Director of the Office of Science and Technology Policy,
and the heads of other agencies, as appropriate, shall review the reports required by subsection
(a) of this section and submit a report to the President assessing the security risks posed by the
existing Federal UAS fleet and outlining potential steps that could be taken to mitigate these
risks, including, if warranted, discontinuing all Federal use of covered UAS and the expeditious
removal of UAS from Federal service.”

C. REVIEW SCOPE
1. This comprehensive review was conducted within the context of Interior’s mission
responsibilities, operating risk environment, and published technical requirements. Within these
three broad areas there are critical elements that differentiate Interior’s program needs,
opportunities, and constraints from other UAS programs. The DOI UAS Program was assessed
against applicable Federal laws and regulations and DOI policies that govern the procurement,
management, and operation of government aircraft. Cybersecurity and American UAS
production concerns expressed in SO 3379 and EO 13981 were also assessed. Where applicable,
these will be addressed in detail to assist the reader in understanding the nature and relevance of
these differences to subsequent review findings, conclusions, and recommendations. In keeping
with the Department’s commitment to transparency, scientific integrity, and fact-based
decision making, this comprehensive DOI UAS program review makes extensive use of
endnotes and embedded links that provide access to supporting documentation of facts and
statements contained throughout this report. All information contained in this report is
unclassified and non-sensitive.

D. DOI UAS PROGRAM HISTORY

1. DOI is the largest land steward in the United States, providing access to more than 480
million acres of public lands, 700 million acres of subsurface minerals, and 1.7 billion acres of
the Outer Continental Shelf. 8 The DOI manages 20 percent of the Nation’s lands, including
national parks, national wildlife refuges, and other public lands; manages resources that supply

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30 percent of the Nation’s energy; supplies and manages water in the 17 Western States and
supplies 15 percent of the Nation’s hydropower energy; and upholds Federal trust responsibilities
to 573 federally recognized Indian tribes and Alaska Native villages. 9 The Department is
responsible for migratory bird and wildlife conservation, historic preservation, endangered
species conservation, surface mined lands protection and restoration, mapping, geological,
hydrological, and biological science for the Nation, and financial and technical assistance for the
insular areas. The “people’s land,” which DOI manages on behalf of the American Taxpayer
hosted 486M visits from foreign and U.S. guests in 2018. 10
2. In carrying out its extensive responsibilities on behalf of the American Public, DOI utilizes a
wide variety of aircraft 11. These include unmanned aircraft systems (UAS, aka drones). DOI
missions, often conducted in remote areas, severe terrain, and weather conditions can be
hazardous to personnel. These missions often require persistent presence and responsive
deployment to address emergent events (e.g., wildfires, earthquakes, volcanos, floods, animal
migrations, search and rescues, etc.). Mission goals include conducting them with no/minimal
disturbance to native species and visitors to the lands that DOI stewards, while making the best
use of appropriated funds to fulfill its chartered obligations for managing the “people’s land.”
As a result of these many factors, UAS were a natural fit for DOI. Interior’s first exploration
into the use of UAS began in 2004 when a UAS was used to acquire data during a volcanic event
on Mount Saint Helens, Washington. 12 The Department’s current UAS Program, “Drones for
Good” 13 was formalized in 2006 14 by the newly appointed OAS Director who came to Interior
with extensive military aviation and UAS experience. 15 From the outset, OAS collaborated
closely with the Department of Defense (DOD) and the Federal Aviation Administration (FAA)
in developing UAS policy and program management structure. Beginning in 2008, OAS
collaborated with the Army and Air Force to acquire at no cost, small UAS that were being
excessed by DOD. Through this effort, OAS was able to acquire over $20M in excess DOD
small UAS at no cost (Figure 1), enabling the efficient completion of hundreds of operational test
and evaluation

Figure 1 - Raven A/B & T-Hawk Excess DOD sUAS Obtained by DOI for Operational Test & Evaluation in Support
of DOI UAS Program Requirements Development

(OT&E) UAS flights across dozens of Interior mission applications from 2010-2014. 16 Using
the experience and mission data obtained during this OT&E program, over 300 Interior bureau

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and OAS SME experts came together to develop a series of Master UAS technical specification
requirements that continue to guide Interior fleet and contract UAS acquisitions. 17 Since then,
the Department has realized significant benefits from the safe and responsible integration of
drone technology. 18

                                    SECTION TWO

              COMPREHENSIVE DOI UAS PROGRAM REVIEW

E. PREVIOUS REVIEWS
1. June 21, 2012 – DOI Aviation Summit – The early years of the Interior UAS program
involved significant interagency and industry collaboration in the development of objectives,
policies, training, etc. In 2012, the Deputy Assistant Secretary Public Safety, Resource
Protection and Emergency Services (DAS PRE) convened a DOI Aviation Summit to discuss a
range of strategic Department aviation issues, including development of a DOI UAS program
strategy. 19 Attendees included the Bureau Deputy Directors from each of Interior’s nine
bureaus, their senior executive representatives responsible for aviation, each Bureau National
Aviation Manager, OAS staff, and representatives from the Interior Budget Office, Solicitor’s
Office, Office of the Chief Information Officer, and the Property and Acquisition Management
Office. 20 During the full-day summit, a detailed review of the Department’s UAS program
development was presented. Attendees reached consensus on an overarching strategic vision for
the future of the DOI UAS program, tasking OAS and Bureau aviation executives with
developing an appropriate action plan to support this strategic vision (Appendix A). The
resultant action plan led to the development of the Department of the Interior UAS Integration
Strategy (2015-2020). 21 An updated DOI UAS Strategy (2020-2025) was developed and
finalized in July 2019, but as a consequence of Department leadership’s October 30, 2019,
decision to ground the DOI UAS fleet, this update was rendered irrelevant and never posted.
2. Reviews Referenced in October 30, 2019, Grounding Directive and/or SO 3379 – The
first step in conducting this review was to obtain and review the scope, results, findings,
conclusions, and recommendations of any official review(s) conducted by the Department that
informed the initial October 30, 2019, grounding order and the subsequent January 29, 2020,
issuance of SO 3379. It was first confirmed that no members of the OAS staff, none of the
Interior Executive Aviation Committee (EAC), nor any of the nine Bureau National Aviation
Managers of the Interior Executive Aviation Subcommittee (EAS) had been engaged to
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participate in any review or consultation prior to the two grounding actions. 22 Subsequent
outreach to the Interior Solicitor’s Office 23 and officials in Policy, Management and Budget 24
produced no relevant federal records of any review conducted by the Department in support of
either the October 30, 2019, grounding order or the January 29, 2020, issuance of SO 3379.
3. Other Limited Internal DOI Reviews of the UAS Program – While no federal record of a
comprehensive review of the DOI UAS program by the Department could be found, relevant
records were located of reviews and recommendations by senior DOI officials subsequent to the
July 2, 2019, DOI Flight Test and Technical Evaluation Report on the Government Edition (GE)
UAS. 25 On July 18, 2019, the Interior Chief Information Officer (CIO) provided his official
views on Drone Security related to DOI’s UAS program to the Assistant Secretary for Policy,
Management and Budget (AS PMB) in an email: 26
“S,
Please accept these comments as my official views. I have attached the actual DOI test report
here.
            •    I believe the reports in the Press regarding the DOI use of DJI drones is seriously
                 biased. Most reports appear to cherry pick statements without regard to the
                 complete report.
             • I reviewed the DOI evaluation program. In my view, Aviation Services took all
                 steps required to comply with relevant NIST Global Supply Chain Risk
                 Management Standards, Statutes, regulations, and DHS policies that existed at the
                 time of their evaluation.
             • Detailed telemetry and operational assessment were conducted, including packet
                 inspection, software inspection, and hardware inspection;
             • The identified technical risks were mitigated via multiple technical and mission
                 controls, including:
      o   Modifying the firmware to eliminate unwanted functionality.
      o   Isolating the technology and data within a secure enclave not connected to the DOI
          infrastructure
      o   Providing additional scanning, validations, and continuous monitoring for all data and
          media collected by the drone.
      o   Conducting mission operations on over areas that are otherwise publicly accessible - I.e.,
          no restricted airspace or critical infrastructure.
             • DOI worked in coordination with multiple federal organizations to evaluate the
                 technology, including DoD, ODNI, DHS, NASA, and other drone fleet operators
It is important to remember that:
•     The DOI mission requirement of flying over unrestricted public lands in the U.S. with no
      ground-air telemetry carries considerably different risk than DoD missions flying over
      foreign battlefields with real-time data and telemetry.
•     That organizations with different mission support requirements view risk differently is moot.
      DoD mission risks cannot be conflated with DOI mission risks.

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•   DOI has considerable experience evaluating drone technology. Testing, evaluation, and
    mitigation with DJI technologies occurred during the period of 2018 - following 8 years of
    collaboration between DOI, DoD, and others.
•   USDA, NASA, and others are still operating the technology within their fleets
To be sure, using foreign technology always carries risks. That said - in my view - the DOI drone
program understands the risks they face and have taken appropriate steps to mitigate them. The
only more effective mitigation would be to use exclusively US manufactured, non-foreign
technologies.
V/r,
Bill”
As a follow-up to the OCIO’s official views, AS PMB tasked the Deputy Assistant Secretary for
Public Safety, Resource Protection, and Emergency Services (DAS PRE) with getting together
with the OCIO, Solicitor’s Office (SOL) staff, and the Directors of the Interior Business Center
and the Office of Acquisition and Property Management (PAM) to obtain their official views on
the subject. 2728 Based on positive responses from all attendees at this July 19, 2019, meeting, AS
PMB provided direction to continue “business as usual” for the DOI UAS program. 29
4. External Reviews – External reviews were limited, focused narrowly on security, and thus
will be covered in the Security section of this report.

F. DOI UAS PROGRAM OBJECTIVES
1. The DOI UAS program was developed to support Interior’s mission to conserve and manage
the Nation’s natural resources and cultural heritage for the benefit and enjoyment of the
American people, provide scientific and other information about natural resources and natural
hazards to address societal challenges and create opportunities for the American people, while
honoring the Nation’s trust responsibilities or special commitments to American Indians, Alaska
Natives, and affiliated island communities to help them prosper. 30 Strategically, UAS were
integrated into DOI’s aviation program to accomplish two overarching objectives. First, UAS
were incorporated where their attributes promised to close gaps in desired outcomes. Second,
they were integrated in areas where this new platform, payload, and processing technology held
opportunities to “leap-frog” the traditional pace of change. 31
2. UAS contributions to the fulfillment of the Department’s mission can broadly be “bucketed”
into these “Four S’s”: Science, Safety, Savings, Service (Figure 5).
         (a). Science, including its integrity and transparency with the public DOI serves is
critical to fulfilling the Department’s commitment to base its decisions on the best available data.
UAS offer incredible enhancement opportunities relative to the amount, resolution, persistence,
and analytics applied to collected data. Drones can be less disruptive to sensitive animal species
than manned aircraft. They can carry sophisticated, high resolution sensors and possess the
ability to collect real-time data that can be recorded for future analysis or shared with the public
for increased transparency. 32 Drone-borne sensors currently operated by Interior have provided

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image resolution improvements of over 1 million times the Landsat 8 satellite 30 m data and
400% better than manned aircraft acquired data 33. They are also less susceptible to mission
disruption due to cloud cover than satellites and are not subject to the constraints of orbital
mechanics. 34 These unique sensing characteristics enable drones to gather repeatable,
scientifically valid observations leading to better policy decisions, benefiting all Americans.

         (b). Safety is a priority in all DOI operations. DOI missions often expose personnel to
significant safety hazards including severe terrain, adverse weather conditions, and hazards core
to many of these missions
(fire, flood, earthquake,
landslide, etc.). From 1937
to 2000, 66% of all field
biologist fatalities in DOI
were aviation related. 35
UAS offer multiple
opportunities to enhance
employee and public safety
by reducing requirements for
manned aircraft flight in
particularly hazardous
mission situations. A prime
example of this is in the
wildland fire aerial ignition
mission (Figure 2). Aerial
ignition is an important tool
for wildland firefighters. It
reduces hazardous fuels
through prescribed burning
and helps combat wildfires
through burnouts 36, and
backfires. 37 Aerial ignition
accesses areas difficult to
reach from the ground.
Traditionally, helicopters
conduct aerial ignition
missions. This mission is
hazardous due to the need to
fly at low-level and low          Figure 2 - Drones Provide Unique Safety and Productivity Opportunities in Responding to
speed, operating in what is       Wildfires
referred to as the “dead
man’s curve.” Since 2005, three helicopters have crashed, and six people died in this mission;
three in the last five years and the most recent fatality in 2019. 38 OAS began seeking out UAS
based aerial ignition solutions in 2015. In April 2016, a joint OAS-NPS-University of Nebraska
Lincoln team conducted the first proof of concept ignition mission at the Homestead National

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Monument. 39 In 2018, Interior fielded a UAS-based aerial ignition system that greatly reduced
the need for helicopter-borne missions, while also providing the first ever night aerial ignition
capability. 40 UAS have also been used to replace ground personnel in certain missions, reducing
their risk to injury. Use of UAS can increase the level of safety for personnel on the ground by
reducing their exposure to hazardous situations. An example of this is the UAS-based water
sampling capability OAS developed and fielded in 2019. 41 This capability allows scientists to
conduct important water sampling missions in rivers and lakes without having to incur the risks
of potentially hazardous terrain at the banks or the hazards of on the water sampling from boats.
This water sampling capability has also been used in the extremely hazardous mission of
sampling water in volcanic craters. 42 Lastly, Interior has employed UAS to save lives, notably
initiating the evacuation of a neighborhood threatened by fast moving lava flows and then
helping to direct a stranded resident to safety on May 27, 2018. 43

Figure 3 - Drone DJ article on May 27, 2018 DOI UAS-Enabled Rescue of Resident from Fast-Moving Nighttime Lava Outbreak

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         (c). Savings achieved by Interior through the integration of drones has included the cost
to procure and train to, operate, support, and maintain these aircraft. As an example, the total
acquisition cost of DOI’s current fleet of 853 UAS 44 was less than the cost of several individual
DOI manned fleet aircraft. 45 Additionally, a 2019 analysis of the DOI UAS fleet found the total
acquisition cost to be less than $1.7M, with an average per aircraft cost of $2,100. 46 Small UAS
such as the Department has employed also require significantly less infrastructure support (e.g.
hangars, runways, etc.) and operator training than manned aircraft. Where drones can adequately
replace manned aircraft or significantly reduce other costs (i.e. replacing many man hours on the
ground to perform the same mission), the savings to the Department and the American taxpayer
is significant. A 2017 post-
fire report by the Bureau of
Land Management (BLM)
detailed UAS use on a fire
in southern Oregon stated
the per-hour operating cost
of using a UAS was 97%
less than that of a manned
helicopter. 47 Savings also
come from reduced loss. In
this same report, DOI UAS
were credited with saving
$50M in property and
infrastructure when one          Figure 4 - Examples of How Drones Support Coordinated Wildfire Operations
discovered an undetected
spot fire and directed firefighters to extinguish it (Figure 4). 48 Across the more than 30,000
UAS mission flights flown to date, DOI bureaus have observed a rule of thumb that a drone can
generally complete a given task in 1/7th the time and at 1/10th the cost of many traditional
means. 49 Data collected and analyzed in DOI’s 2018 and 2019 Annual UAS Summary Reports
bears this out, with annual operational savings of $14.8M and $15.7M respectively versus the
cost of traditional methods. 50 51 Significant future savings are also expected with the proposed
use of Optionally Piloted Aircraft (OPA), operated in both onboard-piloted and remote-piloted
modes in wildland fire during the ~16 hours each day when night and periods of reduced
visibility currently prevent manned aerial firefighting support. 52
        (d). Responsive, agile, and flexible Service is critical to aviation’s ability to support
Interior bureau missions. Wildfire, floods, earthquakes, wildlife migrations, injured or lost
guests, etc. don’t occur on fixed or predictable schedules or locations. UAS provide service
enhancements over traditional manned aviation. Small UAS can easily be integrated directly
with field personnel, enabling them to quickly react to emergent DOI/Bureau mission needs.
They can often be deployed more quickly than traditional manned aircraft and their lower
acquisition cost and operator training requirements provide the opportunity to deploy them more
widely than is possible with traditional manned aircraft. UAS have “democratized” the third
dimension for Interior bureaus and personnel, improving the Department’s ability to adequately
service the nearly 500 million acres of the “Peoples’ Lands” it is responsible for stewarding. 53

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Figure 5 - The “Four Outcome S’s” of DOI’s “Drones for Good” UAS Program

        (e). DOI UAS also contribute to an important supporting “S” critical to the Department’s
future vitality and one that reinforces Interior’s commitment to engaging youth, veterans,
minorities, and underserved communities. 54 Science, Technology, Engineering, and Math
(STEM) permeates every part of DOI’s mission. 55 Current trends in STEM education and
employment, along with changes in demographics and youth interests, suggest that the skilled
workforce needed by DOI to fill mission-critical positions and support the engagement of
citizens in informed decision making can best be obtained by increasing science literacy and
engagement. 56 Encouraging a new generation, and particularly those in underserved
communities to pursue STEM related education and degrees is essential to DOI’s ability to field
a competent, innovative, and professional workforce in the stewardship of the “People’s Lands.”
UAS have proven to provide a new and exciting opportunity for young people to engage in
STEM activities. 57 Through the use of UAS and in collaboration with a range of primary,
secondary, and college education centered drone programs, DOI can leverage its leadership in
UAS to inspire a new generation to embrace STEM education. Drones also provide a unique
opportunity to connect young people to their lands and the idea of public service. Stories about
DOI’s “Drones for Good” program, coupled with programs that provide young people the
opportunity to connect with the land through collaborative DOI-youth drone projects on the land
hold promise for sustaining the call to public service and stewardship of America’s public lands
by future generations.

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G. AUTHORITY, LEGAL AND REGULATORY COMPLIANCE
1. Federal Aviation Program Authority and Compliance - U.S. Code (49 U.S.C. §
40102(a)(6)) defines an “aircraft” as “any contrivance invented, used, or designed to navigate or
fly in the air.” Interior has been authorized by Congress to utilize a combination of government-
owned and contracted aircraft in support of its bureaus and missions for over 75 years. 58 UAS
are also defined as aircraft in law and in the FAA’s authorizing statutes. 59 DOI flight operations
fall under the legal definition of Public Aircraft Operations (PAO) as defined in 49 U.S.C. §
40102(a)(41), 49 U.S.C. § 40125, and FAA Advisory Circular 00-1.1B. Management and
oversight of federal aircraft are also subject to the requirements contained in Office of
Management and Budget (OMB) Circulars and General Services Administration (GSA) Federal
Management Regulations (FMR
102-33). The FAA retains no
regulatory authority over PAO.
OAS was established by
Interior to fulfill its legal and
regulatory requirements for the
management and oversight of
government aircraft (Figure 6).
OAS is responsible for
oversight of its aviation
operations, including aircraft
airworthiness and any unique
operational requirements.
Interior delegations of OAS
functions, responsibilities, and
authorities are contained within
                                     Figure 6 - Legal and Regulatory Requirements for Federal Aviation Programs
official multiple Departmental
                 60
Manuals (DM) and
Operational Procedures Memoranda (OPM). 61 For those DOI-wide aviation policy items unique
to UAS, Interior developed a specific governing OPM (OPM-11). 62 Possessing over 1,000
cumulative years of resident industry, government, and military aviation experience, OAS works
collaboratively with Interior bureau and interagency partners to develop standards, training,
certification, airworthiness, maintenance, and oversight requirements in support of Interior’s
unique and hazardous aviation operations. 63 Annually, OAS is subjected to an independent
third-party external audit to verify conformance of OAS processes with ISO 9001-2015
international quality standards. 64 DOI bureaus also provide critical end-use management and
oversight of Interior aviation operations. Through highly trained and experienced aviation and
mission leadership and field personnel, Interior bureaus carry out aviation missions critical to the
Department’s goals and Administration priorities across all 50 States and all U.S. Territories.
2. Federal Acquisition Authorities and Compliance – Procurement of Interior fleet aircraft
(including UAS) and the solicitation, awarding, and management of commercial aviation
services (CAS) contracts are governed by the Federal Acquisition Regulations (FAR) and
relevant laws such as the Buy American Act (BAA). Oversight of Interior’s acquisition program

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is carried out by the Office of Acquisition and Property Management (PAM). DOI fleet and
contract procurements are carried out by the Interior Business Center (IBC) Acquisition Services
Directorate (AQD). Warranted contracting officers (CO’s) with experience in aviation
acquisition staff the IBC-AQD office in Boise, Idaho, where OAS headquarters and the National
Interagency Fire Center (NIFC) are located. All DOI CAS contracts adhere to the provisions of
the FAR and the BAA. Specifically, with respect to DOI UAS contracts, to date no awards have
been subject to protest. Of Interior’s current fleet of 853 UAS, 59 percent (504) were purchased
from U.S.-based companies.65 Another 21% (178) DOI UAS are sourced from a French-based
company, and the remaining 20% are sourced from China-based companies. 100% of DOI UAS
were purchased through U.S.-based distributors.

H. COLLABORATION IN PROGRAM DEVELOPMENT
1. Interior’s UAS program leveraged existing relationships with DOD, FAA, and NASA, taking
advantage of their experience in UAS policy, requirements, acquisition, airworthiness, training,
operations, etc. to assist in its early development (Figure 7). Integral to this strategy was a
number of Memoranda of Understanding/Agreement (MOU/MOA) with each agency that
provided Interior with access to UAS test aircraft, airworthiness expertise, operating authorities,
training and programmatic policies that were critical to foundation of DOI’s program. 66 Interior
also leveraged the FAA designated UAS sites and the FAA UAS Center of Excellence (COE) for
technical expertise and testing capabilities. 67 As a member of the federal Interagency Committee
on Aviation Policy (ICAP), DOI works together with member agencies to develop the ICAP
subcommittee on UAS policy. 68 In recognition of the maturity and accomplishments of
Interior’s UAS program, DOI was added as a member of the Federal UAS Executive Committee
(ExCom). 69 Throughout the history of its UAS program, Interior has worked closely with
academia and industry. In 2016, DOI OAS and the National Park Service collaborated in a joint
venture to develop and field test the first-of-its-kind UAS-based aerial ignition capability. 70

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Figure 7 - DOI UAS Program Collaborative Network

2. OAS and Interior bureaus collaborated with UAS associations and were regular participants
in and keynote speakers at widely-attended UAS conferences. 71 Through this collaboration,
Interior kept abreast of the latest developments in the UAS industry while affording the industry
with important knowledge of DOI bureau UAS mission, technical, and security requirements. 72
Interior’s UAS program accomplishments and collaboration with the UAS industry was
recognized in 2017 by the Commercial Drone Alliance as their inaugural End-User Innovator of
the Year. 73 This was also recognized in 2018 by the Partnership for Public Service, nominating
OAS as a finalist for the Samuel J Heyman Service to America Medal. 74 As part of OAS’s effort
to pay forward the assistance Interior received during the early days of its UAS program, the
office has collaborated with over 20 other Federal, State, Local, Tribal, and Territorial (SLTT)
government agencies to assist them with the development of their UAS programs. 75
3. Various Departmental programs provide Federal financial assistance that can and is used for
the purchase, operation, and maintenance of UAS by non-DOI entities. The Office of Surface
Mining Reclamation and Enforcement, for example, provides Federal Abandoned Mine Land
and regulatory grant funding that has helped States and Tribes utilize UAS in their daily
operations.

I. DOI UAS REQUIREMENTS
1. One of the most important elements that determine a program’s success or failure is well
defined and adhered to requirements. 76 Further, the U.S. Government Accountability Office
(GAO) has previously reported on the importance a systems engineering approach to the
development and implementation of program requirements. 77 Interior’s commitment to a

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requirements-based approach (mission, performance, security, safety, etc.) was core founding
principle of its UAS program as reiterated in an August 13, 2012 DAS PRE memorandum to the
nine Interior Bureau Directors (Appendix A). 78 This memorandum also echoed the strategic
direction for the DOI UAS Program agreed upon by the nine Bureau Deputy Directors and DAS
PRE at the June 21, 2012 DOI Aviation Summit. 79 As illustrated in Figure 8, this was the
approach OAS applied in determining DOI UAS requirements. Bureau requirements,
particularly in the areas of gaps in desired performance with traditional aviation resources and/or
project methods were cataloged. Potential requirements with the opportunity to “leap-frog” the
traditional pace of change was also examined as part of this process. Interior’s mission and
operating environment provided important context to complete the overarching requirements
determination. These were then translated into UAS performance requirements for the platform,
payloads, and processing systems and necessary functional specifications (e.g., security,
maintainability, reliability, cost, etc.).
2. Operational Test & Evaluation (OT&E) for Requirements Determination – As was
detailed previously, OAS was able to acquire over $20M in excess DOD small UAS at no cost,
enabling the completion of hundreds of OT&E UAS flights across dozens of Interior mission
applications 80 from 2010-2014. While the excess DOD UAS were rugged and capable for the
military missions for which they were designed, the OT&E revealed limitations that made them
ill-suited for long term Interior use as configured. First, the radios operated on DOD frequencies
that are either prohibited from use within continental United States or require approval from the
National Telecommunications and Information Administration (NTIA) prior to each mission use.
This approval took anywhere from several weeks to several months to obtain and was the single
largest barrier to full employment of these aircraft during OT&E. Second, the stock sensors
available on these aircraft were not suitable for most DOI mission requirements, lacking the
necessary resolution and modularity needed for the wide range of demanding and complex
bureau science and mapping applications. The DOD aircraft also required extensive training and
required a long and expensive logistical tail for maintenance and replacement parts. Finally, the
cost to modify these military UAS was high; OAS was quoted $60K per system to modify the
radios to ones compatible with operations within the U.S.
3. Master UAS Requirements Development – Applying the experience and data obtained
during this OT&E program, over 300 Interior bureau and OAS SMEs came together to develop a
series of Master UAS Specifications that continue to guide Interior fleet and contract UAS
acquisitions. Initially finalized July 14, 2014, 81 with eight small fixed and rotary wing UAS, the
Master UAS Requirements has received four updates and added a ninth UAS type in response to
measured mission outcomes, bureau mission adjustments, and technology improvements (current
version 1.3 dated March 15, 2019). 82 These requirements have informed all subsequent DOI
UAS procurements and contracts.

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