Date: 202108
Local time of day: 1201-1800
Location: ZZZ.Airport, US
Flight conditions: VMC
Weather elements / visibility: Haze / Smoke; 4
Light: Daylight
Aircraft: Small UAS (At or above 0.55 lbs and less than 55 lbs)
Operator: Commercial Operator (UAS)
Operating under: Public Aircraft Operations (UAS)
Flight plan: None
Mission: Public Safety / Pursuit (UAS)
Flight phase: Other All
Airspace: TFR ZZZ
Reporter organization: Commercial Operator (UAS)
Reporter function: Person Manipulating Controls (UAS); Remote PIC (UAS)
Reporter qualification: Flight Crew Commercial; Flight Crew Instrument; Flight Crew Multiengine; Flight Crew Private; Flight Crew Remote Pilot (UAS)
Human factors: Communication Breakdown; Training / Qualification
Anomaly: Deviation / Discrepancy - Procedural FAR; Deviation / Discrepancy - Procedural Published Material / Policy; Deviation / Discrepancy - Procedural Unauthorized Flight Operations (UAS)
Detector: Person UAS Crew
When detected: Other Post Flight
Result: General None Reported / Taken
Contributing factors: Human Factors; Procedure
Primary problem: Human Factors

Narrative: My team was supporting wildfire efforts in the Western US. I was the RPIC (Remote Pilot in Command) for the operations. We flew our UAS (unmanned aircraft system) under the authority of the appropriate state dispatch agency we were contracted to; within TFRs associated with the firefighting efforts. Operations consisted of flying within the TFR; at approximately 3;000-5;000ft AGL to provide infrared mapping; real-time video; and hot-spot location for ground firefighting personnel. Our aircraft are equipped with Mode A/C/S ADS-B (Automatic Dependent Surveillance-Broadcast) out transponders; which were operated for all flights. We maintained radio communications with both the TFR controlling entities as well as with other aircraft within the TFR on assigned air-to-air frequencies. All operations were conducted normally and safely. According to our interpretation of normal contract-type UAS procedures set up by the BLM (Bureau of Land Management) PMS-515 (Publication Management System-515) entail having a 'carded' [qualified] UAS Manager (UASM); employed by the contracting agency assigned on-site to the contractor. The UASM coordinates SGI (special government interest) Waivers for contracted Type 1 and 2 UAS platforms. The state contracted UAS for firefighting; the state was not aware of most of the federal procedures for contract UAS; and was not able to provide a qualified UASM for our operation. I reviewed our operational documents as well as NWCG (National Wildfire Coordinating Group) PMS 515 after the mission was complete. As a result of the review; I realized an ECOA (Emergency Certificate of Authorization)/ SGI Waiver for BVLOS (beyond visual line of sight) flight had not been attained for our operations. We planned operations going forward. I immediately contacted the FAA SOSC (System Operations Support Center) to obtain the necessary SGI-COA for all subsequent planned operations. A plan and alternate plans were readied for future operations in support of that wildfire. For the remainder of our mission calendar; we were not able to find a suitable Takeoff/Landing area (LRZ) within the boundaries of the TFR. Further support flights were not able to be flown. All further flights of this nature will have the proper SGI/ ECOA Waivers for BVLOS flight in place prior to launching the aircraft. This step has been added into our preparation checklist to ensure it is not missed in the future; regardless of the management/ interface assets available or assigned.




Synopsis: Remote PIC reported their commercial UAS crew was contracted to assist a public safety agency. The crew learned after the operation was complete they had operated without a required waiver.