By Jason Damman
Drone as First Responder (DFR) programs are advancing quickly. The technology is improving. Response times are shrinking. Capabilities that were experimental just a few years ago are now operational realities across the country. That progress is real and deserves to be recognized.
But there is a gap that is not being discussed enough.
I have spent 20 years as an airline pilot holding an Airline Transport Pilot certificate — the highest level of FAA pilot certification — operating inside some of the most structured, disciplined and safety-driven frameworks in any industry. For the last 10 years, I have been teaching Part 107 certification and consulting with public safety agencies on building drone programs. That combination gives me a specific lens through which I watch this industry grow.
And what I see concerns me.
Not because I doubt the commitment of the people running these programs, but because departments are scaling capability faster than they are building the operational structure to support it. In aviation, that gap has historically been measured in accidents. As someone who understands what these waivers actually authorize operationally, I want to make sure departments have a clear picture of what is required to support them safely.
While the FAA has recently made it easier for public safety agencies to secure waivers for Shielded Operations and DFR programs, that accessibility should not be mistaken for simplicity. An approved waiver means the FAA has authorized your agency to operate. It does not mean your agency is operationally ready to do so safely and consistently. The framework required to support these operations does not come with the waiver. It has to be deliberately built, staffed and sustained before the first flight takes place.
In aviation, we have a principle that has guided the industry for decades — capability and risk always scale together. This article is my attempt to explain what that looks like for DFR programs and why it matters.
| DOWNLOAD: The DFR decisions every chief faces before the first drone ever flies
DFR is not just a program — it is an aviation operation
It is easy to think of drones as tools — equipment assigned to a patrol unit and deployed when needed. At the earliest stages of a program, that framing is understandable.
But the moment an agency moves into BVLOS operations or begins incorporating automation, the margin for error shrinks and the consequences of gaps in training, procedures and oversight grow significantly — in ways that a patrol-based deployment model was never designed to manage.
Professional aviation has very clear expectations for how operations are built, scaled and sustained — expectations developed not from regulation alone, but from decades of hard lessons about what happens when structure does not keep pace with capability. The goal is not simply to satisfy FAA requirements. It is to build the kind of operational foundation that makes safe, consistent and scalable performance possible.
What a manned aviation program would require before implementing DFR or Shielded Operations
Professional aviation does not simply comply with FAA regulations and call it a day. Airlines and air carriers build layered operational systems — frameworks developed over decades, often in response to accidents — that go well beyond minimum compliance. These frameworks are what make commercial aviation one of the safest forms of transportation in the world. DFR programs should be built on the same principles.
1. Risk assessment frameworks
How aviation does it: Before any new route, aircraft type or operational procedure is introduced, aviation operators conduct formal risk assessments. These are structured, documented evaluations of hazards, likelihood of occurrence and potential consequences. Risk is not assumed away. It is identified, quantified and mitigated through specific controls. Go/no-go decision criteria are built into daily operations so individual pilots are not making those calls alone under pressure.
Why it matters: Without a formal risk framework, decisions are made reactively and inconsistently. What one operator considers acceptable, another may not. Risk accumulates quietly until it surfaces in an incident or accident.
DFR application: A DFR program should have a defined risk assessment process before any flight. This means evaluating airspace complexity, environmental conditions, communication reliability, population density along the flight path and the nature of the incident being responded to. Critically, it means establishing clear go/no-go criteria so decisions are consistent across all shifts and operators — not dependent on individual judgment in the moment.
2. Standardized operating procedures (SOPs) and checklists
How aviation does it: Commercial aviation relies on standardization. Every flight follows the same procedures regardless of which crew is flying. Checklists are used for normal operations, abnormal situations and emergencies. Nothing is left to memory. SOPs define not only what to do, but who is responsible, when it happens and how it is documented. This repeatability is what makes large-scale operations both safe and auditable.
Why it matters: When operations depend on individual experience rather than standardized procedures, quality and safety vary from person to person and shift to shift. Variability is where errors live.
DFR application: Every DFR program should have written SOPs covering preflight checks, launch authorization, inflight protocols, abnormal procedures and postflight documentation. These should not be suggestions. They should be required, followed consistently and reviewed regularly. If your program depends on operators remembering what to do rather than following a documented process, you do not yet have a scalable operation.
3. Crew resource management (CRM)
How aviation does it: Crew Resource Management was developed after investigators determined many aviation accidents were not caused by mechanical failure or lack of technical skill, but by human factors — poor communication, unchallenged authority, situational awareness failures and flawed decision-making under stress. CRM training teaches crews how to communicate clearly, share information, challenge errors respectfully and make sound decisions together.
Why it matters: Technical proficiency alone is not enough. How operators communicate and coordinate during an active incident directly affects outcomes. Stress, urgency and incomplete information are the normal operating environment for DFR — not the exception.
DFR application: DFR operators and supervisors should receive training in situational awareness, decision-making under pressure and clear communication protocols — particularly during multi-agency incidents. Command staff should understand how to support pilots without adding pressure, and pilots should have a clear, practiced process for communicating flight status and concerns.
4. Safety management systems (SMS)
How aviation does it: A Safety Management System is a formal, organization-wide approach to managing safety. It includes safety policy, risk management, assurance and promotion. Airlines use SMS to proactively identify hazards, track performance and build a culture where concerns are reported without blame.
Why it matters: Most programs wait for something to go wrong before examining safety. SMS reverses that approach. It treats safety as an ongoing management function, not an after-action response.
DFR application: A DFR program does not need full airline-level complexity to benefit from SMS principles. At a minimum, this means establishing a process for reporting near-misses, reviewing incidents for systemic issues and tracking operational data over time to identify trends. Safety should be a management responsibility, not just a pilot responsibility.
5. Recurrent training and proficiency checks
How aviation does it: In commercial aviation, certification is just the beginning. Pilots undergo recurrent training every six to twelve months, covering both normal and abnormal scenarios. Proficiency is not assumed. It is verified.
Why it matters: Skills degrade without practice. Abnormal scenarios — lost link, GPS degradation, communication failure — define operational readiness. If operators have never practiced these, certification on paper does not equal capability in the field.
DFR application: DFR programs should establish a recurrent training schedule that includes flight proficiency and scenario-based exercises. Operators should be evaluated on decision-making and procedure execution when things go wrong. Initial certification gets someone qualified. Recurrent training keeps them ready.
| WATCH: What every agency needs to know as their DFR program evolves
What the FAA already requires — and what it tells us
The five frameworks described above are not arbitrary standards imported from commercial aviation. The FAA’s own requirements for Shielded Operations and DFR waivers point directly to the same disciplines.
Before an agency can operate under a Shielded Operations waiver, the FAA requires the following — all of which must be documented:
- Agency training and certification: The FAA requires that operators are formally trained and certified before conducting DFR operations. This is the foundation of every recurrent training and proficiency framework discussed above. Certification is the starting point, not the finish line.
- Waiver familiarity: Operators must demonstrate documented familiarity with the specific conditions and limitations of their waiver. This is standardization in practice — the same principle that drives SOPs and checklists in commercial aviation. If operators do not understand the boundaries of their authorization, they cannot make sound go/no-go decisions.
- Part 91 familiarity: Operators must understand and document familiarity with FAA Part 91 rules governing flight operations. This connects directly to risk assessment — understanding the regulatory environment is a prerequisite for identifying where operational hazards exist.
- Night vision and visual illusions training: Operations conducted at night or in low-visibility conditions require specific, documented training. This is Crew Resource Management and situational awareness in direct application — recognizing that human perception under certain conditions is unreliable without deliberate preparation.
Each of these requirements reflects a known category of operational risk. The five frameworks in this article are how professional aviation addresses those same risks at an organizational level — not just for individual operators, but across every shift, every deployment and every condition your program will face.
Compliance gets you authorized. Structure gets you ready.
How DFR programs can fall short if risk management is not prioritized
The real challenge is not the technology itself. It is how easily advanced capabilities — especially Shielded Operations and BVLOS — can be adopted before the necessary operational structure and policies are in place to manage the added risk.
When capability moves faster than discipline, small gaps can quietly compound into serious exposure. Here’s how DFR programs can fall short if risk management is not deliberately built in from the start:
- Scaling hardware, launch sites and automation before establishing adequate staffing, supervision and shift coverage models, leaving operators stretched thin and forcing rushed decisions under pressure.
- Providing only initial training or inconsistent recurrent training, so crews remain proficient in routine flights but have little practice managing abnormal scenarios such as lost link, GPS degradation or communication failure.
- Operating with a weak or undefined command structure during active incidents, undermining Crew Resource Management and creating confusion when coordination is most critical.
- Relying too heavily on vendor-driven deployment models instead of developing strong internal ownership, accountability and standardized procedures.
- Treating BVLOS and Shielded Operations as a regulatory checkbox rather than recognizing them as a fundamental operational shift that requires new risk controls, policies and procedures.
- Failing to establish a robust safety reporting system, allowing potential hazards and safety concerns to go unidentified and unaddressed.
In these situations, operators may hold a valid certificate on paper, yet still lack meaningful hands-on experience with the very failure modes that test a program’s true safety margins. Those are precisely the moments that separate a paper-compliant operation from one that is genuinely ready.
Understanding the three levels of DFR through an aviation lens
Not all DFR programs carry the same level of complexity. From an aviation perspective, they represent different categories of operation and levels of risk.
Level 1: Patrol-based deployment (pilot responds to scene)
This is where many agencies begin. Drones are deployed from patrol vehicles and flown within visual line of sight after officers arrive on scene. This model builds familiarity, introduces procedures and allows agencies to develop baseline proficiency. It is a critical step in establishing operational culture. It is the stage where operational habits are formed — and where the groundwork for everything that follows should be deliberately laid.
Level 2: Forward deployment to scene (shielded operations)
At this level, drones are launched from a pilot location and can be flown beyond visual line of sight before officers arrive on scene. This introduces BVLOS considerations, dedicated operator roles and defined supervision and coordination. This is the threshold where aviation discipline becomes the difference between a program that scales safely and one that is accumulating risk it cannot see. This is where the operational framework built at Level 1 is expanded alongside the level of risk — and where the strength of that foundation determines whether the program scales safely or accumulates exposure it cannot see.
Level 3: Automated dock-based/remote launch systems (advanced operation)
Automation adds another layer of exposure. Dock-based systems allow drones to launch automatically and be monitored remotely. Response times improve. Coverage expands. Public visibility increases. But so do expectations. Automation requires reliable connectivity, communication redundancy and continuous supervisory oversight. Operators must be proficient not only in routine operations, but also in managing system failures in real time. Automation is not a technology upgrade. It is an operational shift.
Before scaling a DFR program — An aviation checklist
From an aviation standpoint, certain conditions would prevent me from scaling any DFR operation. More importantly, they should prompt every agency to ask honest questions before expanding capability.
- BVLOS operations without clearly defined SOPs: Do our policies and reporting processes actually support this level of operation?
- Expansion without a training and recurrent training program in place: Do we have enough trained personnel to sustain this safely on every shift?
- Automation without system redundancy and monitoring capability: Is our IT infrastructure reliable enough for remote or automated deployment?
- Unclear chain of command during active operations: Does everyone on every shift know exactly who is responsible for what under every condition?
- Reliance on operators without demonstrated hands-on proficiency: Do we have a long-term budget and training plan to keep operators genuinely ready — not just certified?
One additional question does not fit neatly into any of these categories, but matters just as much: Are we prepared to clearly explain this system and its use to the public?
These are not barriers to progress — they are safeguards that help manage risk. They are the questions that determine whether progress is sustainable.
The aviation standard
In aviation, capability and risk always scale together. That principle is not a preference — it is the foundation of why commercial aviation has become one of the safest forms of transportation in history. It was not built that way overnight. It was built through decades of hard lessons, honest analysis and a disciplined commitment to putting structure before speed.
Drone as First Responder programs are at an inflection point. The technology is ready. Public demand is real. The operational case is clear. But in aviation, a type rating does not make an airline. And in DFR, a pilot certificate and an approved waiver do not make an operation. Readiness is measured by the systems, people and culture built to support them.
That means building risk assessment frameworks before expanding operational scope. It means writing SOPs that operators follow by discipline, not memory. It means investing in Crew Resource Management so that human factors — communication, decision-making under pressure and situational awareness — are trained disciplines, not assumptions. It means treating safety as a management function through a Safety Management System (SMS) approach, not an afterthought that surfaces only when something goes wrong. And it means committing to recurrent training that keeps operators genuinely prepared, not just certified on paper.
These are not bureaucratic obstacles. They are the same tools that took commercial aviation from one of the most accident-prone industries of the 20th century to the safest form of mass transportation in history. They work because they are proactive, systematic and honest about where risk exists.
DFR programs that skip these steps do not eliminate risk. They simply stop managing it.
The most advanced system is not always the right one. The right system is the one your agency can operate safely, consistently and sustainably — every day, on every shift, under real-world conditions. Not just on the days when everything goes right, but on the days when it does not.
That is the aviation standard. And it is exactly the standard DFR programs deserve.
About the author
Jason Damman is the Chief Pilot and co-owner of V1DroneMedia, a drone training and services company specializing in public safety, and commercial drone applications. A former airline pilot with over 20 years of commercial aviation experience, Jason holds an Airline Transport Pilot (ATP) and Part 107 certificate, and has spent the past decade training first responders to obtain their FAA Part 107 licenses and build real-world, hands-on flight proficiency. He now works with public safety agencies to develop and implement operational frameworks for Drone as First Responder (DFR), BVLOS and tactical drone programs—helping departments build safe, scalable and sustainable aviation operations.
