CLARIFICATION OF GROUP 1 AND 2 UNMANNED AIRCRAFT SYSTEMS (UAS) POLICY FOR THE OPERATION OF USMC SMALL UAS (SUAS)
Date Signed: 6/18/2024 | MARADMINS Number: 284/24
MARADMINS : 284/24

R 171830Z JUN 24
MARADMIN 284/24
MSGID/GENADMIN/CMC WASHINGTON DC PPO PO//
SUBJ/CLARIFICATION OF GROUP 1 AND 2 UNMANNED AIRCRAFT SYSTEMS (UAS) POLICY FOR THE OPERATION OF USMC SMALL UAS (SUAS)//
REF/A/DOC/CJCSI 3255.01 CH 1// 
REF/B/DOC/CNAF M-3710.7 CH 14//
REF/C/DOC/CNAF M-3710.9//
REF/D/DOC/CNAF 4790.2D//
REF/E/DOC/OPNAV 3750.6S//
REF/F/DOC/NAVMC 3500.107C// 
REF/G/DOC/NAVMC 1200.1J//
REF/H/MSG/CMC DC PPO/111151ZJAN23//
REF/I/DOC/DC AVIATION TRUAS WAIVER 6 FEB 2023//
REF/J/DOC/TRV-150 UAS CATEGORY 3 IFC FOR FLEET OPERATIONS//
REF/K/DOC/NAVMED P-117//
REF/L/DOC/AEROMEDICAL REFERENCE AND WAIVER GUIDE//
REF/M/DOC/DCA GROUP 3 WAIVER APPROVAL AUTHORITY//
NARR/REF A IS THE JOINT UNMANNED AIRCRAFT SYSTEMS MINIMUM TRAINING STANDARDS DIRECTIVE. REF B IS THE UAS CHAPTER OF NATOPS GENERAL FLIGHT AND OPERATING INSTRUCTIONS MANUAL. REF C IS THE GUIDANCE FOR THE OPERATION OF DEPARTMENT OF NAVY GROUP 1 AND 2 UNMANNED AIRCRAFT SYSTEMS. REF D IS THE NAVAL AVIATION MAINTENANCE PROGRAM. REF E IS THE NAVAL AVIATION SAFETY MANAGEMENT SYSTEM. REF F IS THE SMALL UAS TRAINING AND READINESS MANUAL. REF G IS THE MILITARY OCCUPATIONAL SPECIALTIES MANUAL DTD 9 JUN 23. REF H IS THE REVISED INTERIM MESSAGE GUIDANCE ON ESTABLISHING A DESIGNATED APPROVAL AUTHORITY AND AIRCRAFT REPORTING CUSTODIANS FOR SMALL UAS AND SUAS SAFETY PROGRAM MANAGEMENT. REF I IS THE DC AVIATION TACTICAL RESUPPLY UNMANNED AIRCRAFT SYSTEM (TRUAS) AUTHORIZATION TO OPERATE AS A GROUP 2 UNMANNED AIRCRAFT SYSTEM (UAS).  REF J IS THE CATEGORY 3 INTERIM FLIGHT CLEARANCE FOR THE TRUAS TRV-150 FLEET OPERATIONS. REF K IS THE MANUAL OF MEDICAL DEPARTMENT (MANMED). REF L IS US NAVY AEROMEDICAL REFERENCE AND WAIVER GUIDE publication serves as a guide that reflects MANMED, NATOPS, and NASA instructionsand requirements for flight duty. REF M IS THE LETTER FROM COMMANDER NAVAL AIR FORCE GRANTING DCA AUTHORITY TO WAIVE GROUP 3 TO OPERATE UNDER THE CNAF M-3710.9.//
POC/MSGT/B. W. POWELL/PPO POF/ EMAIL: BRYAN.W.POWELL@USMC.MIL/TEL: 703-614-4300// 
POC/MGYSGT/R. E. SEELEY/DCA AWS UAS/ EMAIL: RICHARD.E.SEELEY@USMC.MIL/TEL: 703-693-9884//
POC/COL/E. C. QUIST/PPO POF/ EMAIL: ERIK.QUIST@USMC.MIL/TEL: 703-692-4289//
POC/LTCOL/C. F. THOMPSON/DCA AWS UAS/ EMAIL: CHASE.THOMPSON@USMC.MIL/TEL: 571-256-1323//
POC/MAJ/S. R. BETSHER/TECOM PSD GSB/ EMAIL: SCOTT.BETSHER@USMC.MIL/TEL: 703-784-3012//
REMARKS/ 1.  Reference H is hereby rescinded and is replaced by this message.  This is a coordinated Deputy Commandant for Aviation (DCA); Deputy Commandant for Plans, Policies, and Operations (DC PP&O); and Training and Education Command (TECOM) message. Its purpose is to clarify, familiarize, and reinforce adherence to Group 1 and 2 UAS policies that affect unit manning, training, equipping, operations, and safety and airspace integration with manned aviation operations. This message does not encompass all UAS policies but is intended to highlight critical policies and ensure commanders understand the requirements these policies dictate. These policies are applicable to all active duty and reserve units that possess Groups 1 and 2 UAS defined by Reference A.
1.a.  This MARADMIN does not change or affect the requirements to operate Group 3 and above UAS per references B, D, and E.
1.b.  For the purposes of this message and for addressing generally, Groups 1 and 2 UAS will be referred to as Small Unmanned Aircraft Systems (SUAS). 
2.  Intent.   Service growth in the types and capacities of SUAS has been significant in recent years, with new capabilities being fielded as part of Force Design 2030 modernization.  This message reiterates necessary guidance regarding authorization for operation of SUAS.
3.  Policy  
3.a.  Training.  TECOM is responsible for establishing and approving the Training and Readiness (T&R) program and standards for all USMC Fleet Naval Aviation, to include SUAS.  SUAS T&R standards are codified in reference F. The purpose of SUAS T&R standards is to attain and maintain the ability to effectively support units where SUAS assets are assigned. These standards describe and define unit capabilities and requirements necessary to maintain proficiency in SUAS operations.
3.b.  Basic UAS Qualification (BUQ). References A and C define the four levels of BUQ training. Group 1 SUAS operators (SUAS-O) are required to achieve BUQ-1 prior to designation. BUQ-1 was developed to give the SUAS-O the required aviation and SUAS knowledge-based skills to fly visual flight rules (VFR) in Class E and G, and restricted/combat airspace <1200’ Above Ground Level (AGL). BUQ-2 expands the operator’s airspace management knowledge base to include additional classes of airspace and altitude blocks up to 3500’ AGL and is required for Group 2 SUAS-O and evaluators (SUAS-E), in addition to BUQ-1.
3.c.  UAS Categorization and Training Standards
3.c.1.  Group 1 UAS.  Defined in accordance with reference A as an air vehicle weighing 20 pounds or less which typically operates under VFR in Class E, G, and restricted or uncontrolled airspace below 1200’ AGL at speeds less than 100 knots. 
3.c.1.1.  Group 1 may be operated by any Marine across the force awarded the Free Military Occupational Specialty (FMOS) 8623 IAW the current NAVAIR issued flight clearance after successfully completing requirements outlined in reference F, including, but not limited to, system-specific Initial Qualification Training (IQT) and BUQ-1 IAW references A and F and being designated as a SUAS-O by the Aircraft Reporting Custodian (ARC).
3.c.2.  Group 2 UAS. Defined in accordance with reference A as an air vehicle weighing between 21-55 pounds.  Group 2 typically operates under VFR in class D, E, G, and restricted airspace below 3500’ AGL at speeds less than 250 knots. Currently the TRUAS TRV-150 has been waived by DCA to be operated and maintained as a Group 2 system for as long as reference I remains in effect.
3.c.2.1.  Group 2 SUAS-Os shall successfully complete a TECOM-approved BUQ-2 syllabus.  The syllabus to include IQT will be approved by TECOM.
3.c.2.2.  Group 2 PMOS.  USMC Group 2 UAS shall only be operated IAW the current NAVAIR issued flight clearance by an approved MOS and completion of training IAW the SUAS T&R Manual.  The Primary Military Operational Specialty (PMOS) 7316 Small UAS Operator is currently the only approved MOS to operate Group 2 systems. 
3.c.3.  IQT.  SUAS IQT courses focus primarily on the system specific operation of SUAS. The Training and Logistics Support Activity (TALSA) offers standardized IQT courses that meet USMC and joint training requirements and ensure students are trained to operate SUAS during contingencies and combat operations. Graduates of these courses are certified as SUAS-operators (SUAS-O) for the system instructed in IQT. Only instructors (known as IQT-Is or Adjunct Faculty) are authorized to instruct IQT courses. 
3.c.4.  SUAS – Evaluators (SUAS-E)/Program Managers (SUAS-PM) are prohibited from conducting IQT for any SUAS for the purpose of certifying SUAS-Os for the first time, or recertifying SUAS-Os who have gone out of currency for greater than 730 days.  
3.c.5.  Authorized Program of Record UAS IQT Learning Centers.  The SUAS schoolhouse under the School of Infantry, TALSA, or a TALSA staffed mobile training team.
3.d.  Marine Special Operations Command (MARSOC) SUAS Operations. Marines assigned to MARSOC holding the PMOS of 0370 (Special Operations Officer), 0372 (Critical Skills Operator), or Billet MOS (BMOS) 8071 (Special Operations Capabilities Specialist) are eligible to be trained on and operate Group 2 systems IAW the requirements in reference F. MARSOC Marines who receive the FMOS 8623 may be authorized to fly Group 2 systems. These Marines are hand selected and undergo a comprehensive screening process and a Special Operations Forces - Peculiar (SOF-P) training pipeline that enables these Marines to operate the Group 2 aircraft.
3.e.  Designated Approval Authorities (DAAs) and Aircraft Reporting Custodians (ARCs). IAW Reference C there are two essential command authorities assuming responsibility for UAS operations: the Aircraft Controlling Custodian (ACC) or the DAA, and the ARC. 
3.e.1.  ACCs and DAAs.  Within the Naval Aviation Enterprise (NAE), the management and operation of aircraft, including Groups 1 and 2 UAS, is the responsibility of an ACC. An ACC is responsible for exercising administrative control of assignment, employment and logistic support of Groups 1 and 2 UAS under their cognizance. A DAA is the flag officer, or SES equivalent, who assumes ACC authorities and responsibilities when the operation of an ARC falls outside of the NAE and the cognizance of a designated ACC. The ACC or DAA is responsible for designating in writing Groups 1 and 2 UAS ARCs under their cognizance. DAA responsibilities can be found in reference B, D and E. The DAA must ensure the designated ARC maintains the requisite personnel, training, equipment, and infrastructure to support safe flight operations in compliance with DON policies and instructions. Compliance must be ensured through DAA-conducted periodic evaluations of approved UAS program, see Reference F.
3.e.2. The ARC is the lowest echelon of command accepting responsibility for Groups 1 and 2 UAS operations, as designated by the Chief of Naval Operations (CNO), ACC, or DAA. ARC responsibilities can be found in references B, D, and E. An ARC is typically an O-5 level commanding officer but may be a military officer or government civilian leading an organizational component as deemed appropriate by the ACC or DAA.  The ARC is responsible for the safe operation of assigned Groups 1 and 2 UAS. ARCs must issue a written designation letter to each qualified individual upon their designation.
3.f.  Aviation Safety. Reference E governs aviation safety for all Department of the Navy (DON) manned and unmanned aviation to include Groups 1 and 2 UAS. Reference E is pending an update to include policies that accommodate SUAS. As indicated by the Naval Aviation Safety Office an exception is to be granted for the Aviation Safety Officer (ASO) to administer a command’s aviation safety program requirement for units operating SUAS.
3.f.1.  ASO Requirement. In the interim, the requirement for an ASO for units operating SUAS is waived. a command’s SUAS safety program shall fall under the command’s ground safety program and be administered by the command’s designated Ground Safety Officer (GSO) / Ground Safety Manager (GSM), a graduate of the Ground Safety for Marines and Ground Safety Mishap Investigator courses. Any mishaps, near miss events, or hazard reports (HAZREPs) involving Groups 1 or 2 SUAS shall adhere to ground safety program reporting requirements and be reported in Risk Management Information – Streamlined Incident Reporting (RMI-SIR), the current DoN program of record. A member of the DAA’s air department, or the appropriate subordinate unit’s air department, shall be available to advise and assist the ARC’s SUAS safety program.
4.  Direction to USMC Commands.  The operation and maintenance of SUAS will be performed in accordance with this message, references stipulated, respective system manuals and applicable governing policies and directives. Designated DAAs will ensure all applicable SUAS policies and their associated programs are enacted and inspected annually. The DAA will establish a SUAS program in accordance with references B, C, F and G. SUAS ARCs will ensure their UAS programs are executed in accordance with these policies.
4.a.  Chain of Command. Commands in the administrative chain of command between the DAA and the ARC shall have working knowledge of SUAS policy and operations commensurate with its level of command. This shall include funding, manning, training, SUAS aviation safety, operations and maintenance. These commands are considered part of the safety and endorsement chain of command in the event of a mishap IAW Reference E. 
4.b.  Unit SUAS Programs. USMC commands that possess SUAS shall immediately comply with the above referenced policies and further guidance established by this message. These commands shall establish their unit SUAS program IAW Reference F no later than 6 months from the publication of this message. 
4.c. Annual Unit SUAS Inspection (USI). The unit SUAS-PM at each command echelon shall conduct an annual USI for each immediate subordinate command maintaining a SUAS program. The SUAS USI shall be conducted in accordance with the SUAS program inspection checklist (see appendix A of reference F for the SUAS program assessment checklist). The purpose of these inspections is to ensure proper program administration and standardization, and to provide assistance and guidance for programs that do not meet standards. 
4.d.  SUAS-PM. Commanders of units with SUAS operations being conducted under their cognizance shall assign a SUAS-PM upon the assignee’s completion of SUAS prerequisites and the SUAS-PM course. The unit SUAS-PM at each command echelon shall maintain the unit’s SUAS program and conduct an annual USI for each immediate subordinate command maintaining a SUAS program.
4.d.1.  SUAS-PM Requirements for Units with SUAS. Units that have SUAS on their Table of Equipment (T/E) shall designate a Staff Noncommissioned Officer (SNCO) or officer as the unit SUAS-PM. The individual should be a SUAS-O. The SUAS-PM shall attend a formal SUAS-PM course, offered through the TALSA, within 90 days of being designated in accordance Reference F.
4.d.2.  SUAS-PM Requirements for Units without SUAS. Units that do not have SUAS on their T/E but who are assigned subordinate units that do shall have a SNCO or officer designated as the unit SUAS-PM; the individual should be assigned for a minimum of 12 months. The SUAS-PM shall attend a formal SUAS-PM course, offered through the TALSA, within 90 days of being designated in accordance with reference F.
4.e.  SUAS-E are experienced SUAS operators who instruct and conduct evaluations of SUAS-Os and assists the unit SUAS-PM. 
4.f.  ARCs shall ensure all SUAS-Os abide by requirements set forth in this MARADMIN as well as reference D and applicable operator manuals.
4.g.  Government Civilian / Contractor Instructors and Operators. This order does not change or affect the ability of contractors or government civilians to operate UAS as required per their contract or training and mission requirements. 
4.h.  Prior to operations, ARCs will ensure their designated SUAS-O currency requirements are met, range and airspace requests are approved, frequency deconfliction is complete, proper pre-flight checks have been completed, and the range is declared hot (as applicable). This requirement can be designated to the OICs or senior SUAS-Os. SUAS-Os will receive permission to launch from the range Officer-in-Charge, Range Safety Officer, or Airspace Control Authority.
5.  Administration and Logistics. Requests to waive or provide changes to any portion of this policy will be submitted through the chain of command and require endorsement from the DAA to DC, PP&O, Future Operations Branch for endorsement and appropriate routing for approval. Electronic submissions of requests and endorsements may be sent to the PP&O POCs listed above. 
5.a.  DCA has been granted the waiver authority from Commander, Naval Air Force, U.S. Pacific Fleet (CNAF) to allow Group 3 UAS to deviate from reference B and operate under the less restrictive requirements for Group 2 UAS contained in reference C, in accordance with reference M.
5.b.  Periodic Review. This message will undergo periodic reviews to integrate lessons learned and accommodate the evolution and integration of future systems until such time a SUAS Marine Corps Order is promulgated and authorized. Adjunct efforts will be set forth to make recommended changes to North Atlantic Treaty Organization Standardization Agreements and Department of Defense, Joint, and Department of the Navy policies. 
6.  Command and Signal
6.a.  Command.  Applicable to the total force.
6.b.  Signal. This message is effective on the date signed.
7.  Release co-authorized by Lieutenant General B.J. Gering, Deputy Commandant for Aviation and Lieutenant General J. W. Bierman,Deputy Commandant, Plans Policies, and Operations.//