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Policy No: 2092
Responsible Office: Police Department
Last Review Date: 08/03/2022
Next Required Review: 08/03/2027
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Drones (Unmanned Aerial Vehicles)
1. Purpose
The purpose of this policy is to establish standards for the safe operation and use of Unmanned Aircraft Systems (UAS), also known as Unmanned Aerial Vehicles (UAV) or drones, at the University, and to promote the safe operation of UAS in compliance with all Federal Aviation Administration (FAA) rules and all applicable federal, state and local laws.
2. Applicability
This policy applies to faculty and staff of the University General Division and USA Health; also to students, contractors, visitors, vendors, or essentially anyone who operates or wishes to operate drones on university property.
3. Definitions
N/A
4. Policy Guidelines
Use of UAS on University property or at University sponsored or affiliated events by individuals who are not students, faculty or staff of the University must be approved in writing in advance by the University. Such users must follow the guidelines of this policy and all other applicable University rules and regulations, and a certificate of insurance must be provided prior to operation to the University’s Risk Manager and the UAS Operations Administrator.
The University is permitted to use small unmanned aircraft systems (UAS) in the National Airspace System for purposes that include research and development and educational/academic uses, provided that the pilots / operators follow operation and certification requirements as described in this policy. Hobby or recreational use of a UAS on or above University property or at any University sponsored event is not permitted.
4.1 USA Proximity to Airports and Helipads
Special rules apply to the use of UAS on the main campus due to its proximity to the Mobile Regional Airport, and at the USA Health University Hospital and USA Health Children’s & Women’s Hospital due to the presence of helipads.
Damages or injuries occurring to University property or individuals will be the responsibility of the UAS operator.
4.2 Regulatory Requirements
The University requires all users of UAS to comply with the regulatory requirements of the Code of Federal Regulations (CFR 14) Part 107. http://federaldroneregistration.com prior to use of UAS, all users are required to familiarize themselves with this policy and the Part 107 regulations. A completed UAS Approval Form must be submitted and approved by the UAS Operations Administrator and or designee prior to UAS flights.
In addition to regulatory requirements, all users must follow rules set forth in this policy whenever the rules are more stringent than those required by federal regulation. The rules include, but are not limited to:
• Prior to flight, the UAS must be appropriately registered and have markings as required by the FAA;
• UAS may not exceed a weight of 55 pounds;
• All UAS operation must be conducted in a responsible manner by an experienced pilot;
• No person may manipulate the flight controls of a UAS unless that person has a remote pilot certificate with a small UAS rating, or is flying under the direct supervision of a person who holds a remote pilot certificate and who has the ability to immediately take direct control of the flight of the UAS;
• No flying over people;
• No flying above 400 feet;
• No flying outside daytime hours (defined as 30 minutes before official sunrise to 30 minutes after official sunset);
• No flying in an unsafe manner;
• No flying beyond the operator’s ability to see the UAS;
• No flying while under the influence of alcohol or drugs;
• No flying in a manner that interferes with air traffic;
• No photography or videography of spaces where an individual has a reasonable expectation of privacy. This includes but is not limited to restrooms, locker rooms, residence facilities, and health treatment and medical facilities;
• No photography or videography of identifiable members of the University community or general public without written authorization. Contact the USA Office of Marketing and Communications for guidance;
• Recommend the use of a secure communications protocol and/or application.
A waiver of some of the above Part 107 requirements is possible through the filing of a Certificate of Waiver (Waiver) or Certificate of Authorization (COA) with and approval by the FAA. USA faculty and staff must obtain written approval from the UAS Operations Administrator prior to filing a request for Waiver or COA.
5. Procedures
5.1 Use On University Property
Persons wishing to operate UAS on University property must contact the UAS Operations Administrator at least two business days in advance of the desired flight time and provide the following:
• Remote pilot certificate with a small UAS rating proof of registration of UAS;
• Detailed flight plan to include specific time and location, duration of flight, identity of remote pilot in command (RPIC) and any other intended operator, purpose of flight, and emergency procedures which will be followed in case of lost link, lost visual or low voltage for each flight plan;
• SkyVector screenshot indicating the location and its distance to the nearest airport;
• Certificate of Insurance must be provided to University Risk Manager for flight by individuals who are not University students, faculty or staff.
All approved requests for UAS flight will be for a specific time and a specific location to avoid conflict with other UAS flight or other University activities. The UAS Operations Administrator will provide authorization in writing for approved flights. This written authorization (signed USA Approval Form) must be in the possession of the UAS operator during the flight. If notification or consent of Air Traffic Control of the Mobile Airport Authority or operators of the USA Health University Hospital and USA Health Children’s & Women’s Hospital helipads is required, communication will be handled by the UAS Operations Administrator. Flights approved on University property are restricted to uses that (1) meet the University’s educational mission, or (2) serve the University’s business needs, as determined by University officials, including the UAS Operations Administrator.
Users of UAS may be asked to stop the UAS flight or leave University property if they do not comply with this policy or are otherwise engaging in conduct that is considered harmful or dangerous to the University or persons on University property. Such conduct includes but is not limited to violations of FAA regulations.
5.2 Use Off University Property
University departments or employees wishing to fly UAS for University-related purposes off University property must have appropriate permits and property owner permission for the location of the flight. They must also comply with any federal, state and local laws and regulations of the jurisdiction where the UAS flight is conducted, including requisite permission of nearby airports.
6. Enforcement
Improper use of UAS may result in the violation of federal, state or local laws, including criminal laws. Users of UAS who violate this policy may be issued a no-trespass order by USAPD. Improper UAS use may also be a violation of University policy, subject to discipline.
The Chief of the USA Police Department (USAPD) serves as the UAS Operations Administrator and is responsible for compliance and enforcement. The Chief of Police (or his designee) also serves as the University’s primary point of contact with the FAA and the Mobile Regional Airport.
The UAS Program Advisory Committee, which includes the Chief of Police, as well as designees from the Colleges of Engineering and Arts and Sciences with expertise in the design and/or use of UAS, Risk Management, University Attorneys’ Office, and the Department of Safety and Environmental Compliance, provides assistance in the formulation, implementation and enforcement of policies and procedures pertaining to UAS.
7. Related Documents
Final Rule on the Operation and Certification of Small Unmanned Aircraft Systems (FAA)