Policy
606
Santa Ana Police Department
Santa Ana PD Policy Manual
Copyright Lexipol, LLC 2026/01/05, All Rights Reserved.
Published with permission by Santa Ana Police Department ***DRAFT*** Unmanned Aerial System - 1 Unmanned Aerial System
606.1 PURPOSE AND SCOPE
This policy establishes guidelines for the use of Unmanned Aerial Systems (UAS), and for the storage, retrieval, and dissemination of images and data captured by the UAS. Our mission to enhance public safety while protecting the rights and privacy of the general public. 606.1.1 DEFINITIONS
Certificate of Authorization (COA) - Given by the Federal Aviation Administration (FAA) and grants permission to fly the UAS within specific boundaries and parameters.
Certificate of Waiver (COW) - Given by the Federal Aviation Administration (FAA) and allows UAS operators to deviate from certain operational limitations outlined in Part 107 of the Federal Aviation Regulations.
Part 107
- A set of standards set by the FAA that regulates the operations of uncrewed aircraft operated by commercial and public operators.
Unmanned Aerial System (UAS) - An unmanned aircraft of any type that is capable of sustaining directed flight, whether preprogrammed or remotely controlled (commonly referred to as an unmanned aerial vehicle (UAV)), and all of the supporting or attached systems designed for gathering information through imaging, recording or any other means.
Federal Aviation Administration (FAA) – The agency of the United States Department of Transportation responsible for the regulation and oversight of civil aviation within the U.S., as well as operation and development of the National Airspace System. Its primary mission is to ensure safety of civil aviation.
Remote Pilot in Command (RPIC) – A person who holds a remote pilot certificate with a UAS rating and has the final authority and responsibility for the operation and safety of the UAS operation conducted under FAA Part 107 or Certificate of Authorization, whether or not physically piloting the UAS.
UAS Pilot
– A person who is piloting (physically) the flight of the UAS.
UAS Visual Observer – Ground-based observers who assist with operations and will assist the remote pilot in command to utilize the "see and avoid" technique by scanning the area for air traffic or possible hazards.
UAS Team – Team of assigned and authorized personnel associated with the operation of the UAS.
Drone as a First Responder (DFR) - The use of UAVs to respond to emergency calls, providing real-time video feeds and information to first responders in the field and in a command center.
EXHIBIT 2
Santa Ana Police Department
Santa Ana PD Policy Manual
Unmanned Aerial System
Copyright Lexipol, LLC 2026/01/05, All Rights Reserved.
Published with permission by Santa Ana Police Department ***DRAFT*** Unmanned Aerial System - 2 606.2 POLICY
It is the policy of the Santa Ana Police Department to use unmanned aerial systems to enhance the Department's ability to protect lives and property, document crime/collision scenes, and perform a variety of flights that promote public safety and public service. UAS Unit flights will be accomplished efficiently and safely while respecting the law and the privacy of the public. All UAS applications will obey Federal, State, and City laws, and shall respect Constitutional rights, privacy rights, search and seizure regulations, and Federal Aviation Administration (FAA) regulations. 606.3 FAA REGULATIONS AND PRIVACY CONSIDERATIONS
The use of a UAS requires considering the community's privacy. Personnel involved in the deployment of a UAS will consider the protection of individuals' civil rights and reasonable expectation of privacy as a key component of any decision made prior to deploying the UAS. UAS RPIC, pilots, and VOs will ensure operations of the UAS intrude as little as possible upon those who live, work, and visit the area of deployment.
Absent a warrant or exigent circumstances, UAS RPIC and VO who operate a UAS shall adhere to all FAA regulations, including altitude regulations, and will obtain the proper authorization for flight.
Operators and observers shall not intentionally record or transmit images of any location where a person would have a reasonable expectation of privacy and shall take reasonable precautions to avoid inadvertent recording or transmitting images of areas where there is a reasonable expectation of privacy. Reasonable precautions may include, for example, deactivating or turning imaging devices away from such areas or persons during UAS operations to minimize inadvertent video or still images of uninvolved persons. The need, availability, and use of the UAS will not supersede the issuance of a warrant when otherwise required. 606.4 UAS UNIT PERSONNEL
The UAS Unit is a collateral assignment that includes both sworn and civilian personnel from the City. Regardless of which City department the personnel belong to, all UAS Unit personnel shall abide by this policy.
606.4.1 UAS UNIT COMMANDER
The Chief of Police will appoint a UAS Commander, who will be responsible for managing the UAS program. The UAS Commander will ensure that policies and procedures conform to current laws, regulations, and best practices and will have the following additional responsibilities:
(a) Coordinating the FAA Certificate of Waiver or Authorization (COA) application process and ensuring the COA is current, and/or coordinating compliance with FAA Part 107 Remote Pilot Certificate, as appropriate for department operations. (b) Ensuring that all authorized operators and required observers have completed all required FAA and department-approved training in the operation, applicable laws, policies, and procedures regarding use of the UAS.
(c) Developing uniform protocol for submission and evaluation of requests to deploy a UAS, including urgent requests made during ongoing or emerging incidents.
Santa Ana Police Department
Santa Ana PD Policy Manual
Unmanned Aerial System
Copyright Lexipol, LLC 2026/01/05, All Rights Reserved.
Published with permission by Santa Ana Police Department ***DRAFT*** Unmanned Aerial System - 3 (d) Coordinating the completion of the FAA Emergency Operation Request Form in emergency situations, as applicable (e.g., natural disasters, search and rescue, emergency situations to safeguard human life).
(e) Developing protocol for conducting criminal investigations involving a UAS, including documentation of time spent monitoring a subject.
(f) Implementing a system for public notification of UAS deployment. (g) Developing an operational protocol governing the deployment and operation of a UAS including but not limited to safety oversight, use of visual observers, establishment of lost link procedures, and secure communication with air traffic control facilities. (h) Developing a protocol for fully documenting all missions. (i) Developing a UAS inspection, maintenance, and record-keeping protocol to ensure continuing airworthiness of a UAS, up to and including its overhaul or life limits. (j) Developing protocols to ensure that all data intended to be used as evidence are accessed, maintained, stored, and retrieved in a manner that ensures its integrity as evidence, including strict adherence to chain of custody requirements. Electronic trails, including encryption, authenticity certificates, and date and time stamping, shall be used as appropriate to preserve individual rights and to ensure the authenticity and maintenance of a secure evidentiary chain of custody.
(k) Developing protocols that ensure retention and destruction periods are maintained in accordance with established records retention schedules. (l) Facilitating law enforcement access to images and data captured by the UAS. (m) Recommending program enhancements, particularly regarding safety and information security.
(n) Ensuring that established protocols are followed by monitoring and providing annual reports about the program to the Chief of Police.
(o) Maintaining familiarity with FAA regulatory standards, state laws and regulations, and local ordinances regarding the operations of a UAS.
606.4.2 UAS UNIT SERGEANT
The UAS Unit Commander shall select a Police Sergeant, subject to the Chief's approval, to serve as the supervisor of the UAS unit. The sergeant is responsible for the following:
(a) Ensuring that all flight operations personnel understand and adhere to applicable regulatory requirements, standards, and organizational safety policies and procedures concerning UAS operations.
(b) Observing and controlling safety systems by monitoring and supervision of UAS pilots and observers.
(c) Monitoring pilot/observer performance compliance with organizational goals, objectives, and regulatory requirements.
(d) Maintaining standards and the practices of UAS Unit personnel.
Santa Ana Police Department
Santa Ana PD Policy Manual
Unmanned Aerial System
Copyright Lexipol, LLC 2026/01/05, All Rights Reserved.
Published with permission by Santa Ana Police Department ***DRAFT*** Unmanned Aerial System - 4 (e) Ensuring that the UAS safety officer receives the proper training to fulfill the duties of this role.
606.4.3 UAS PILOTS
(a) To be considered for selection as a UAS pilot, applicants must be in good standing with the Santa Ana Police Department and meet any other standards required by the UAS Commander.
(b) A UAS pilot's primary duty is the safe and effective operation of the Santa Ana Police Department's UAS in accordance with the manufacturer's approved flight manual, FAA regulations, and agency procedures. Pilots must remain knowledgeable of applicable FAA regulations, the UAS manufacturer's flight manual, and Department policy. (c) Pilots must maintain a valid FAA Part 107 certificate. (d) To fly a flight (other than flights required for initial training or currency), pilots must have completed department-required UAS training, as may be modified from time to time, including three (3) UAS currency events, within the previous 90 days. Currency events include landings, takeoffs, and simulator flights. (e) Night flight requirements are the same as those in subsection (d), but the currency events must be completed at night. A simulator may not be used to complete night currency.
(f) UAS pilots may be removed from the UAS Unit and/or flight status at any time by the UAS Unit Commander for reasons determined by the UAS Unit Commander. These reasons may include, but are not limited to, performance, proficiency, and the like. 606.4.4 UAS FLIGHT SAFETY OFFICER
Safety is the responsibility of all UAS Unit members. A UAS unit member may be designated as the UAS flight safety officer. The position will be in addition to other duties. The flight safety officer's duties may include:
(a) To copy and circulate pertinent safety information. (b) Assist the sergeant in debriefing training sessions with an emphasis on safety concerns.
(c) Periodically preparing a bulletin that contains reported safety-related problems and corrective actions taken. If there were any in-flight problems, the proper procedures for handling that problem will be discussed.
606.5 DRONE AS A FIRST RESPONDER (DFR) UNIT PERSONNEL This policy authorizes the use of UAS as a DFR to assist first responders in the course of their duties to increase safety, reduce the risk of injury to officers, suspects, and bystanders, and increase the likelihood of bringing incidents to successful resolutions. General examples of such use include: responding to calls for service, providing overwatch, assisting with directed (specific purpose) patrol efforts, and assisting field personnel in the performance of their duties. The DFR Pilots can authorize the use of the UAS in this capacity on established DFR shifts.
Santa Ana Police Department
Santa Ana PD Policy Manual
Unmanned Aerial System
Copyright Lexipol, LLC 2026/01/05, All Rights Reserved.
Published with permission by Santa Ana Police Department ***DRAFT*** Unmanned Aerial System - 5 The DFR Unit shall consist of sworn members of the Police Department. Management of the DFR Unit is the responsibility of the UAS Commander, and coordination of the DFR Unit is the responsibility of the assigned UAS sergeants. All DFR Unit personnel shall abide by this policy. 606.5.1 DFR PILOT
(a) To be considered for selection as a DFR pilot, applicants must be in good standing with the Department and meet any other standards required by the UAS Commander. (b) A DFR pilot's primary duty is the safe and effective operation of the Department's UAS in accordance with manufacturers' approved flight manual, FAA regulations, and agency procedures. Pilots must remain knowledgeable of applicable FAA regulations; the UAS manufacturer's flight manual, and this policy.
(c) Pilots must maintain a valid FAA Part 107 certificate. (d) To fly a flight (other than flights required for initial training or currency), pilots must have completed department-required UAS training, as may be modified from time to time, including three (3) UAS currency events, within the previous 90 days. Currency events include landings, takeoffs, and simulator flights. (e) Night flight requirements are the same as those in subsection (d), but the currency events must be completed at night. A simulator may not be used to complete night currency.
(f) DFR pilots may be removed from the UAS Unit and/or flight status at any time by the UAS Unit Commander, for reasons determined by the UAS Unit Commander. These reasons may include, but are not limited to, performance, proficiency, and the like. 606.6 USE OF UAS
Only authorized operators who have completed the required training shall be permitted to operate the UAS.
Use of vision enhancement technology (e.g., thermal and other imaging equipment not generally available to the public) is permissible in viewing areas only where there is no protectable privacy interest or when in compliance with a search warrant or court order. In all other instances, legal counsel should be consulted.
UAS operations should be conducted in accordance with FAA regulations. 606.6.1 AUTHORIZED UAS FLIGHT TYPES
UAS are intended to serve as a benefit to public safety and/or public service, improve operational safety, or help manage incidents or events. Authorized UAS use is permissible only in areas where there is no protected privacy interest at issue, when in compliance with a search warrant or court order, or in emergency or exigent circumstances. This policy authorizes the use of a UAS to assist in the following types of incidents:
(a) Incident documentation/diagramming
(b) Field operations support
Santa Ana Police Department
Santa Ana PD Policy Manual
Unmanned Aerial System
Copyright Lexipol, LLC 2026/01/05, All Rights Reserved.
Published with permission by Santa Ana Police Department ***DRAFT*** Unmanned Aerial System - 6 (c) Investigative support
(d) Searches for missing persons
(e) Search and rescue
(f) Explosive device investigation support
(g) Illegal fireworks deterrence and enforcement
(h) Firefighting/Investigation support
(i) Tactical operation support
(j) Disaster/mass casualty response support
(k) Event planning and management
(l) Training
(m) Drone as a First Responder
(n) Any incident where the UAS will provide enhanced safety to the Community or responding members without compromising the Community's privacy rights and with the authorization of an Incident Commander, Watch Commander, or the UAS Commander
(o) Community event support
When the UAS is being flown pursuant to any of the authorized uses above, onboard cameras will be directed away from occupied structures as feasible, or the recording function will be disabled to minimize the inadvertent capture of video or still images of uninvolved persons. However, it is recognized that under certain exigent circumstances, such as an event/incident involving a threat to members of the public or officer safety, these efforts may not always be feasible or appropriate. 606.6.2 ASSISTING OTHER AGENCIES/CITY DEPARTMENTS
A UAS may be deployed to assist another City Department or other law enforcement or government agency as long as the deployment is authorized by the UAS Unit Commander or higher, and the UAS is operated in accordance with this policy.
In the event operators from other agencies assist the Santa Ana Police Department with the operation of a UAS at a crime scene, any and all data/evidence obtained from the UAS will be provided to the Santa Ana Police Department for chain of custody. This data will be retained according to the Department's Evidence Policy.
606.7 PROHIBITED USE
The UAS video surveillance equipment shall not be used:
(a) To conduct random surveillance activities.
(b) To target a person based solely on actual or perceived characteristics, such as race, ethnicity, national origin, religion, sex, sexual orientation, gender identity or expression, economic status, age, cultural group, or disability. (c) To harass, intimidate, or discriminate against any individual or group.
Santa Ana Police Department
Santa Ana PD Policy Manual
Unmanned Aerial System
Copyright Lexipol, LLC 2026/01/05, All Rights Reserved.
Published with permission by Santa Ana Police Department ***DRAFT*** Unmanned Aerial System - 7 (d) To conduct personal business of any type.
The UAS shall not be equipped with any device or platform capable of employing lethal force.
Notwithstanding the authorized or prohibited uses above, the Bureau Commander or their designee must approve any other use of the UAS not expressly provided for in this Policy. 606.8 UAS OBTAINED DATA
Except for training and demonstration purposes, when the UAS is used to capture video or still images, the recordings shall be reviewed for evidentiary value. Any items of evidentiary value shall be downloaded and booked as evidence under the related case number. Audio and/or images captured by a UAS and booked as evidence shall be retained in accordance with the Department's Evidence Policy.
(a) The collection of data includes, but is not limited to, digital photographs, videos, and IR images, and is limited to the extent necessary to accomplish the mission. (b) As a general rule, the UAS Pilot will not record during operations. (c) If the UAS Pilot determines circumstances exist such that a recording has or may have evidentiary value, the UAS Pilot may record as necessary. (d) Only data that qualifies as having a legitimate training objective or evidentiary value will be retained after a mission is concluded. Any retained data will be uploaded to Evidence.com. All other data will be purged via electronic deletion. Digital flight logs are exempt from this requirement. This data will be stored in accordance with the Department's Records Maintenance and Release Policy.
Department members shall not retain recordings of activities or information obtained during an on-duty UAS deployment. Members shall not duplicate or distribute such recordings, except for authorized legitimate Department business purposes. Unless for official business, recordings of any type shall not be posted to or distributed via the internet, email, file transfer, remote computer access, news services, social networking, social media, instant messaging, text messaging, blogs, forums, video, or other file sharing sites without prior approval from the Chief of Police or their designee.
606.9 TRAINING WITH UAS VIDEO FILES
Video files and images from a UAS deployment may serve as a training tool for individuals, specific units, and the Department. Department members recommending the utilization of a UAS video file for training purposes will submit the recommendation for approval through the chain of command to their Division Commander, who will present the request to the UAS Unit Commander. 606.10 FLIGHT LOGS AND INFORMATION
Following the completion of any flight, UAS pilots will log the date, flight time, and locations of all UAS deployments. All UAS Flight logs shall, at a minimum, note: case number, incident type, purpose of flight, duration of flight, maximum altitude, and specify whether automated flight or manual flight.
Santa Ana Police Department
Santa Ana PD Policy Manual
Unmanned Aerial System
Copyright Lexipol, LLC 2026/01/05, All Rights Reserved.
Published with permission by Santa Ana Police Department ***DRAFT*** Unmanned Aerial System - 8 (a) For DFR flights, the UAS pilot controlling a flight shall complete the automated information fields regarding the purpose of the flight and after-action/ disposition elements.
(b) All UAS flight information shall be included in the established public-facing web portal.
Any flights that are not included in the public-facing web portal must be for a valid reason (such as part of an ongoing investigation, have statutory privacy protections, etc.) and must be approved by the UAS Unit Commander.
606.11 UAS COLLISIONS
(a) If a collision occurs during the operation of the UAS and results in serious injury to any person, any loss of consciousness, or if it causes damage to any property (other than to the UAS itself) in excess of $500 to repair or replace the property, notification shall be made to the Flight Standards District Office located in Long Beach within 10 days, per FAA guidelines.
1. Flight Standards District Office for Orange County https://www.faa.gov/about/ office_org/field_offices/fsdo/lgb/Long Beach Flight Standards District Office (562) 420-1755 - Office Address: 5001 Airport Plaza Drive, Long Beach, CA 90815
(b) While at the scene, the RPIC shall notify the UAS Sergeant or the Incident Commander, who shall respond to ensure photographs of the collision scene and any resulting injuries or property damage are taken. The RPIC shall be responsible for completing an incident report describing the incident and damage. If the collision results in less than $500 in damage, or if the only damage is to the UAS itself, the Pilot shall complete an incident report and notify the UAS Sergeant. In either case, the UAS Sergeant shall conduct or direct a review of the collision to determine if it could have been prevented through maintenance, training, or other measures, and ensure that all necessary paperwork has been submitted. As warranted, the UAS Sergeant or designee should contact the City's Risk Management Division. 606.12 REVIEW OF RECORDINGS
(a) When preparing written reports, written/oral statements, or testimony, members may review UAS recordings as a resource. However, members should not use the fact a recording was made as a reason to write a less detailed report. The UAS Unit Commander or Sergeant may routinely inspect recordings, provided the inspections are reasonable, conducted in good faith, and not for the sole purpose of searching for violations of Department policy or law not related to a specific complaint or incident.
Recorded files may also be reviewed:
1. By an employee, his or her attorney or representative, who is participating in, as a subject or witness, an official investigation, such as a personnel complaint, administrative investigation, or criminal investigation, if the subject officer's image or voice is captured on the recorded file or the officer was present during the incident.
Santa Ana Police Department
Santa Ana PD Policy Manual
Unmanned Aerial System
Copyright Lexipol, LLC 2026/01/05, All Rights Reserved.
Published with permission by Santa Ana Police Department ***DRAFT*** Unmanned Aerial System - 9
2. Pursuant to lawful process or by court personnel who are otherwise authorized to review evidence in a related case.
3. By media personnel with permission of the Chief of Police or the authorized designee.
4. In compliance with a public records request, if authorized by law, and in accordance with the Records Maintenance and Release policy. 606.13 MAINTENANCE
A properly maintained UAS is essential to its safe operation. Compliance with the preflight checklist, post-flight inspection, and the immediate repair of mechanical problems will ensure the availability and safety of the Department's UAS.
The UAS Commander will designate a UAS Maintenance Officer who will coordinate maintenance for the UAS. This assignment can be in addition to other duties of a team member or someone outside the UAS Team. Maintenance will be scheduled when it has the least impact on operations, if feasible. The Maintenance Officer shall notify the UAS Sergeant of the UAS's operational status.
The Maintenance Officer shall be responsible for keeping the UAS maintenance record updated.
Maintenance records shall be retained as provided in the established records retention schedule. 606.14 STORAGE
UAS and associated equipment shall be stored in a secure location at the Department or an approved off-site location, and UAS shall not be operated for personal use.