Uncrewed Aircraft Policy - Northern Michigan University

Last reviewed: 2/6/2017

Definitions:

Northern Michigan University Property:  Buildings, grounds and land owned or controlled by University.

Federal Aviation Administration (FAA): National aviation authority of the United States.

Uncrewed Aircraft Systems (UAS): An uncrewed aircraft and all of the associated support equipment, control station, data links, telemetry, communications and navigation equipment, etc., necessary to operate the unmanned aircraft.  UAS may have a variety of names including but not limited to drone, quadcopter, and quadrotor.  FAA regulation applies to UAS regardless of size or weight.  Model aircraft are not considered by the FAA as UAS and have different regulations.  See http://content.govdelivery.com/attachments/MIMSP/2016/01/04/file_attachments/469144/FAA%2BLE%2BDrone%2BResponse%2BCard.pdf for a description of FAA categories.

Certificate of Authorization or Waiver (COA):  An authorization issued by the FAA to a public operator for a specific UAS activity.  After a complete application is submitted, FAA conducts a comprehensive operational and technical review.  If necessary, provisions or limitations may be imposed as part of the approval to ensure the UAS can operate safely with other airspace users.  In most cases, FAA will provide a formal response within 60 days from the time a completed application is submitted.

333 Exemption:  FAA exemption based on Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) which grants the Secretary of Transportation the authority to determine whether an airworthiness certificate is required for a UAS to operate safely in the National Airspace System.

Higher education institutions may operate UAS upon receipt of a certificate of waiver or authorization issued by the FAA.  This procedure outlines the responsibilities for obtaining proper authorization, ensuring safe flight areas, privacy, and insurance coverage. 

Flights on University Property:

Permission to operate a UAS on university property will only be granted to university departments wishing to sponsor the operation of a UAS for the benefit of the university.  The department may be flying the UAS or hiring a contractor to perform work using a UAS.   Any department sponsoring UAS flight on university property will submit an application to the department of Public Safety and Police Services no later than 48 hours before the event; earlier submission is encouraged.  The application will include the following: 

1. The application will identify the exact dates and times of intended operation, the identity of the individual operating the UAS and the purpose of the UAS flight. 
2. The request must be accompanied by a current 333 exemption or Certificate of Waiver or Authorization (COA) issued by the FAA or present documentation showing that the individual operating the UAS is fully authorized by the FAA to do so prior to operating the approved UAS.
3. UAS may not be used inside any university building without prior permission given by Public Safety and Police Services and Risk Management. 
4. Public Safety and Police Services is the account holder for COA’s for the University and will process all applications on a case-by-case basis. 

The department of Public Safety and Police Services will review this data to ensure that the flight is operating at a safe time and place and any required authorizations or exemptions are in place before the flight.  Risk Management will review the application to ensure that the flight does not require additional insurance or risk mitigation practices.  UAS users/sponsors can expect to be required to provide general liability coverage of $2,000,000 per occurrence, either by the department sponsoring use or as proof of insurance in this amount from the contractor.  Further, any requirement for ensuring that the flight area is cleared to ensure safety will be at the discretion of Public Safety and Police Services.  Public Safety and Police Services will retain all applications, certificates and exemptions.  Risk Management will retain evidence of insurance. 

Model Aircraft:  For the purpose of this procedure all UAS must adhere to the FAA requirements and it is the responsibility of the user to ensure that they meet all the requirements.

The university has identified the “Intramural Fields” located on the west side of campus adjacent to Wright Street and Lincoln Avenue as a location where UAS classified as Model Aircraft can be flown when no one is utilizing this area.  The UAS and operator must meet all FAA requirements.

Flights off-campus: Those wishing to operate an University-owned or University-grant-procured UAS off-campus shall fill out the UAS Off-campus flight request.

The request will include but is not limited to:

• Proof of insurance 
• Prohibition of student use or details of student supervision. 
• Attestation that all flights will be logged. 
• Standards of privacy to be used (which must be at least as restrictive as University privacy standards)Copies of any notice to land-owners or adjacent land-owners.

Purchasing a UAS:

Any University employee, student or department purchasing a UAS (or parts to assemble a UAS) with university funds or funds being disbursed through a university account, or grant funds, must first obtain approval from a Vice President of the university.   The purchase request must indicate how the device will be used.  In addition, it must indicate how the device will be secured in storage to prevent unauthorized use.  Finally, the request must indicate how the device will be disposed of after the purpose is accomplished if necessary.   Copies of the approved request will be maintained in Risk Management for liability insurance and monitoring purposes.

Privacy:

The flying of UAS over University property by members of the public is prohibited.   In operating a UAS for purposes of recoding or transmitting visual images, operators must take all reasonable measures to avoid violations of areas normally considered private.   UAS may not be used to monitor or record sensitive institutional or personal information which may be found in an individual’s workspaces, on computers or on other electronic devices.

All complaints concerning the operation of UAS over University Property are referred to the Department of Public Safety and Police Services.   Violations by students are referred to the Dean of Students office.  Violations by employees are referred to their supervisor.