HomeMy WebLinkAboutItem 6.1 - 2124 Drone Ordinance Amendments
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STAFF REPORT
CITY COUNCIL
DATE: August 21, 2018
TO: Honorable Mayor and City Councilmembers
FROM:
Christopher L. Foss, City Manager
SUBJECT:
Amending Chapter 5.100 (Parks and Recreation Areas and Facilities) and
adding Chapter 5.116 (Unmanned Aircraft Systems) to Title 5 (Public
Welfare) of the Dublin Municipal Code to restrict the operation of
unmanned aircraft systems (PLPA-2018-00019)
Prepared by: Robert Paley, Assistant Planner
EXECUTIVE SUMMARY:
The City Council will consider amending the Dublin Municipal Code related to the
regulation of unmanned aircraft systems. This includes an amendment to Chapter
5.100 (Parks and Recreation Areas and Facilities) and adding of Chapter 5.116
(Unmanned Aircraft Systems) to Title 5 (Public Welf are) of the Dublin Municipal Code to
restrict the operation of unmanned aircraft systems within portions of the City limits
around Government Facilities and City-sponsored events The proposed amendment
will promote public safety, protect people engaging in public events, and to control the
activity below the navigable airspace over and within one -half mile of Government
Facilities.
STAFF RECOMMENDATION:
Conduct the public hearing, deliberate, waive the reading and INTRODUCE an
Ordinance Amending Chapter 5.100 (Parks and Recreation Areas and Facilities) and
adding Chapter 5.116 (Unmanned Aircraft Systems) to Title 5 (Public Welfare) of the
Dublin Municipal Code to restrict the flying of unmanned aircraft systems within City
limits.
FINANCIAL IMPACT:
None.
PROJECT DESCRIPTION:
An unmanned aircraft system (UAS), also known as a drone, is an aircraft without a
human pilot onboard – rather, the UAS is controlled remotely from an operator on the
ground. UAS are to some extent subject to regulation by the Federal Aviation
Administration (FAA) to ensure safety of flight, and safety of people and property on the
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ground. However, because UAS can fly at altitudes below the navigable airspace
(generally set at 400 feet), the FAA’s regulations are somewhat limit ed.
While some activities that are regulated by the FAA are also prohibited by federal law,
cities face a challenge in enforcing these laws or relying on existing law to address
unsafe or reckless operation of this technology. As a result, states and lo cal
jurisdictions are increasingly exploring regulation of UAS or proceeding to enact
legislation relating to UAS operations.
In January 2017, the League of California Cities circulated a policy statement that
provides guidelines for local agencies that are interested in establishing local UAS
regulations. The guidelines recommend the following objectives for local UAS
regulations:
1) Narrow the UAS regulations so as to enhance public safety without being unduly
restrictive.
2) Do not attempt to change federal rules about navigable airspace.
3) Ensure reasonable use of municipal police power under Article XI, Section 7 of
the California Constitution.
4) Do not invite charges of federal pre-emption, based on the guidance provided by
the Federal Aviation Administration.
5) Ensure consistency, wherever possible, with existing FAA regulations.
As UAS operations continue to increase dramatically due to changes in technology and
increased popularity, and because of the lack of oversight at the Federal level, the
authority to preserve uniquely local concerns can be addressed by the City. Therefore,
this Draft Ordinance is being proposed in order to restrict the operation of unmanned
aircraft systems within City limits in order to ensure safety of flight, and safety of people
and property on the ground as a reasonable use of municipal police power.
ANALYSIS:
The draft Ordinance amends Chapter 5.100 (Parks and Recreation Areas and Facilities)
and adds Chapter 5.116 (Unmanned Aircraft Systems) to Title 5 (Public Welfare) of the
Dublin Municipal Code. The amendment to Chapter 5.100, and more specifically,
Section 5.100.110 (D), is to clarify that the City’s existing prohibition of the operation of
“powered or line-attached model crafts of any kind or description” in City parks includes
UAS.
The proposed new Chapter 5.116 prohibits the operation of UAS around Government
Facilities and City-sponsored events. The Draft Ordinance prohibits unmanned aircraft
systems from being deployed, launched, operated or flown in any airspace within a one-
half mile radius of Government Facilities and City-sponsored events. The prohibition on
operation and flight would not apply in the navigable airspace, as defined by federal law,
which is the airspace above 1000 feet in elevation. The proposed ordinance would also
require all unmanned aircraft systems flown within City-limits to be registered with the
FAA and flown in accordance with all FAA regulations. For the ease of implementation,
the ordinance adds a few relevant definitions.
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The ordinance would restrict the flying of unmanned aircraft systems within City limits in
order to promote public safety. The purpose of the restrictions are to protect persons
gathered in groups where risk of injury is high due to a greater number of people
gathered in a close proximity. The regulations implemented by this Ordinance are not
intended to restrict legitimate hobbyists operating unmanned aircraft systems in
compliance with FAA rules and any applicable laws, and outside of the prohibited areas.
The Ordinance is not intended to preempt FAA rules, but to operate in conjunction with
those rules to promote public safety while recognizing the limitations in the FAA’s
enforcement capabilities.
Enforcement
Enforcement of the new regulations would continue to fall within the authority of Dublin
Police Services as do several other activities outlined in Title 5 (Public Welfare). Similar
to other activities within the City such as, graffiti or fireworks, the City has the authority
to site an infraction as provided in Section 1.04.030 (Violations as misdemeanors or
infractions—Penalties) of the Dublin Municipal Code.
ENVIRONMENTAL REVIEW:
This Ordinance is exempt from the California Environmental Quality Act (CEQA) per
CEQA Guidelines Section 15061(b)(3). Section 15061(b)(3) states that CEQA applies
only to those projects that have the potential to cause a significant effect on the
environment. The adoption of the proposed Ordinance is exempt from CEQA because
the adoption of the proposed amendments to the Munici pal Code does not, in itself,
allow the construction of any building or structure or authorize any activity, but rather
restricts the flying of unmanned aircraft systems within the City. This Ordinance,
therefore, has no potential for resulting in significant physical change in the
environment, directly or ultimately.
NOTICING REQUIREMENTS/PUBLIC OUTREACH:
In accordance with State law, a Public Notice regarding this Public Hearing was
published in the East Bay Times and posted at several locations throughout the City in
accordance with Section 36933 of the Government Code of the State of California.
ATTACHMENTS:
1. Ordinance Amending Chapter 5.100 and Adding Chapter 5.116 to the Dublin
Municipal Code
ORDINANCE NO. XX - 18
AN ORDINANCE OF THE CITY COUNCIL
OF THE CITY OF DUBLIN
* * * * * * ** * * * * * * * * * * * * * *
AMENDING CHAPTER 5.100 (PARKS AND RECREATION AREAS AND FACILITIES) AND
ADDING CHAPTER 5.116 (UNMANNED AIRCRAFT SYSTEMS) TO TITLE 5 (PUBLIC
WELFARE) OF THE DUBLIN MUNICIPAL CODE TO RESTRICT THE OPERATION OF
UNMANNED AIRCRAFT SYSTEMS
PLPA-2018-00019
THE CITY COUNCIL OF THE CITY OF DUBLIN DOES HEREBY ORDAIN AS FOLLOWS:
SECTION 1. RECITALS
A. Unmanned aircraft systems are so-called drones or other unmanned aircraft that can fly
under the control of a remote pilot, first person view, or via a global positioning system guided
autopilot mode; and
B. Federal laws and regulations allow unmanned aircraft systems to fly at altitudes below
the navigable airspace (generally set at 500 feet above incorporated cities). Commercial
operation of unmanned aerial system is regulated by the Federal Aviation Administration, which,
among other things, has prohibited operations beyond the line of sight of the operator, above
400 feet, at night, and above people and structures . Federal law prohibits the FAA from
regulating “hobbyist” operations to the extent operated within the line of sight of the operator ;
and
C. The City of Dublin currently prohibits the operation of “powered or line-attached model
crafts of any kind or description” in all City parks, with some exception; but does not specifically
identify “unmanned aircraft systems” (Dublin Municipal Code Section 5.100.110D); and
D. Changes in technology require clarification that the prohibition of “powered or line-
attached model crafts of any kind or description” also includes unmanned aircraft systems; and
E. Unmanned aircraft systems have become increasingly popular and available to private
citizens and hobbyists, as well as commercial enterprises; and
F. Unmanned aircraft systems can be equipped with cameras, as well as mechanized to
carry and drop packages; and
G. Unmanned aircraft systems have become a threat to the public health, safety and
welfare of the community for their ability to be flown with little restriction over public events and
government facilities such as Alameda County Santa Rita Jail, Federal Correctional Institution
(FCI) Dublin, Camp Parks and similar government lands within City limits; and
H. The City Council desires to clarify the regulations pertaining to the use of unmanned
aircraft systems within City parks, over public events, government facilities and other areas of
the City to ensure the public’s health, safety and welfare in the City of Dublin; and
I. The City Council held a duly noticed public hearing on the proposed amendments on
August 21, 2018 at which time all interested parties had the opportunity to be heard.
SECTION 2.
Section 5.100.110 (D) (Parks and Recreation Areas and Facilities) of the Dublin Municipal Code
is hereby amended to read as follows:
D. Operate powered or line-attached model crafts of any kind or description and unmanned
aircrafts systems, as defined in Section 5.116.020, except in areas provided for such specific
activities;
SECTION 3.
Chapter 5.116 (Unmanned Aircraft Systems) is added to Title 5 (Public Welfare) of the Dublin
Municipal Code to read as follows:
"Sections:
5.116.010 Purpose and intent.
5.116.020 Definitions.
5.116.030 Restrictions.
5.116.040 Exemptions.
5.116.050 Enforcement.
5.116.010 Purpose and intent.
This chapter is intended to promote public safety , protect people engaging in public events, and
to control the activity below the navigable airspace over and within one-half mile of Government
Facilities. All restrictions are intended to protect persons gathered in groups where risk of injury
is high due to a greater number of people gathered in a close proximity. This chapter is not
intended to preempt FAA rules, but to operate in conjunction with those rules to promote public
safety while recognizing the limitations in the FAA’s regulations and enforcement capabilities.
5.116.020 Definitions.
“City-sponsored event” means an event as defined in Section 5.56.040.
“Unmanned Aircraft Systems” means drones and other unmanned aircraft that fly under the
control of a remote pilot, first person view, or via a global positioning system guided autopilot
mode.
“Government Facilities” means property owned and occupied by the United States of America
(or any of its agencies), the State of California (or any of its agencies), the County of Alameda,
the City of Dublin, the Dublin San Ramon Services District, and the Dublin Unified School
District. Government Facilities specifically includes parks, as defined in Section 5.100.020, the
Santa Rita Jail, the Federal Correctional Institution (FCI) Dublin, and Parks Reserve Forces
Training Area.
5.116.030 Restrictions.
A. Unless otherwise exempt under this chapter, it is unlawful for a person to:
1. deploy or launch an unmanned aircraft system within one-half mile of Government Facilities
and City-sponsored events.
2. fly or operate an unmanned aircraft system in the airspace outside of the navigable airspace,
as defined by federal law, that is within a one-half mile radius of Government Facilities and City-
sponsored events.
3. operate an unmanned aircraft system without registering with the Federal Aviation
Administration (FAA), where required by federal law or regulation.
4. operate an unmanned aircraft in a manner that is prohibited by federal law or regulations.
5.116.040 Exemptions.
This chapter shall not prohibit the use of unmanned aircraft systems by the City, Dublin San
Ramon Services District, Dublin Unified Schoo l District, or designee, and any law enforcement
agency for an otherwise lawful purpose and in a lawful manner.
5.116.050 Violation—Penalty.
Any person violating any provision of this chapter shall be guilty of an infraction, and upon
conviction thereof shall be punishable as provided in the City has the authority to site an
infraction as provided in Section 1.04.030 Violations as misdemeanors or infractions —Penalties
of the Dublin Municipal Code.
SECTION 4. CALIFORNIA ENVIRONMENTAL QUALITY ACT
This Ordinance is exempt from the California Environmental Quality Act (CEQA) per CEQA
Guidelines Section 15061(b)(3). Section 15061(b)(3) states that CEQA applies only to those
projects that have the potential to cause a significant effect on the environment. Th e adoption
of the proposed Ordinance is exempt from CEQA because the adoption of the proposed
amendments to the Municipal Code does not, in itself, allow the construction of any building or
structure or authorize any activity, but rather restricts the flyi ng of unmanned aircraft systems
within the City. This Ordinance, therefore, has no potential for resulting in significant physical
change in the environment, directly or ultimately.
SECTION 5. SEVERABILITY
The provisions of this Ordinance are severable and if any provision, clause, sentence, word or
part thereof is held illegal, invalid, unconstitutional, or inapplicable to any person or
circumstances, such illegality, invalidity, unconstitutionality, or inapplicability shall not affect or
impair any of the remaining provisions, clauses, sentences, sections, words or parts thereof of
the ordinance or their applicability to other persons or circumstances.
SECTION 6. EFFECTIVE DATE AND POSTING OF ORDINANCE
This Ordinance shall take effect and be in force thirty (30) days from and after the date of its
passage. The City Clerk of the City of Dublin shall cause this ordinance to be posted in at least
three (3) public places in the City of Dublin in accordance with Section 36933 of the
Government Code of the State of California.
PASSED, APPROVED, AND ADOPTED BY THE CITY COUNCIL OF THE CITY OF DUBLIN
on this ___ day of __________, ____, by the following votes:
AYES:
NOES:
ABSENT:
ABSTAIN:
___________________________
Mayor
ATTEST:
_____________________
City Clerk