HMMH holds an Indefinite-Delivery, Indefinite-Quantity (IDIQ) contract to provide Unmanned Aircraft System environmental review support to the Federal Aviation Administration (FAA). Support services covered under this contract include assessing the environmental impacts associated with introduction of new technologies to the National Airspace System (e.g., unmanned aircraft systems [UAS] and advanced air mobility [AAM] concepts and technologies), and the development of associated infrastructure (e.g., vertiports).
Many of the FAA’s actions to support UAS integration into the National Airspace System are subject to environmental review under the National Environmental Policy Act (NEPA) and must comply with the Endangered Species Act (ESA), the Migratory Bird Treaty Act (MBTA), the National Historic Preservation Act (NHPA), and other environmental laws and directives. In particular, the FAA must consider unmanned aircraft (UA) noise exposure as a key component of the environmental review process. Compliance with these environmental requirements for FAA actions requires the preparation of documentation—typically in the form of an environmental assessment—in addition to the analyses and graphics needed for consultation efforts with other agencies, tribes, and the community.
This direct experience with the FAA has enabled HMMH to develop strong relationships with FAA Environmental Protection Specialists in AFS-762 (General Aviation & Commercial Branch, Emerging Technologies Division), AUS-430 (UAS Integration Office, Strategic Programs Branch), AEE-100 (Office of Environment and Energy – Noise Division), FAA’s general counsel, and other divisions, all of which are directly involved in evaluating the impacts of UAS entrants into the national airspace. This experience provides HMMH with unique insight into the primary challenges that entrants encounter when seeking approvals from the FAA and other agencies, enabling HMMH to assist agencies and stakeholders in planning ahead.
To date, HMMH has performed work under four separate Task Orders to support FAA approvals. Specific tasks successfully accomplished under these Task Orders include:
- Conduct a noise analysis to support and justify a definition of “infrequent use” applicable to UAS for consideration under FAA Order 1050.1F Categorical Exclusion 5-6.6b (excluding operations under 14 CFR Part 135).
- Develop UAS noise analysis framework to conduct UA noise assessments in support of 14 CFR Part 135 operations.
- Create UAS noise analysis framework to conduct multi-operator programmatic UA noise analyses and to support standardized noise measurement methodology and guidance.
- Conduct noise assessments for NEPA documents for UAS Part 135 approvals issued by FAA to date.
- Analyze noise for programmatic environmental assessment for the environmental review of the proposed FAA Recognized Identification Areas based on the requirements in FAA Order 1050.1F.
- Evaluate impacts, support agency consultation, and prepare NEPA documentation for FAA approvals of UAS operations, including environmental assessments for individual operators in Texas and Utah.
- Conduct environmental analysis, agency consultation, and public involvement, and prepare NEPA documentation to obtain approval of a programmatic environmental assessment for drone package deliveries throughout the state of North Carolina.