Use of Unmanned Aerial Systems

Recommended By
Office of Research and Sponsored Programs
Approved
Judy K. Sakaki, President
Issue Date
Wednesday, February 12, 2020
Current Issue Date
Wednesday, February 12, 2020
Effective Date
Wednesday, February 12, 2020
Contact Office
Office of Research and Sponsored Programs
Policy number
2020-1
  1. Purpose
    To provide guidance concerning the appropriate use of Unmanned Aircraft Systems (UAS) related to research, instructional and administrative endeavors at Sonoma State University. Small Unmanned Aerial Vehicles (sUAV) applicable to this policy are those 55 lbs. or under operated in outdoor airspace. UAV’s over 55 lbs. (25 kg.) are not permitted under this policy.
     
  2. Introduction
    The use of UAS’s provide faculty and student researchers access to data that may enhance research projects within existing courses, enable undergraduate capstone and master’s thesis projects, and permit research that answers significant questions benefiting the state of California, the nation, and beyond.

    The use of UAS’s offer faculty, students, staff and volunteers at SSU valuable opportunities to acquire data inexpensively in a wide range of disciplines. In addition to experience associated with programming/flying sUAV’s, student researchers benefit from the design, selection, and operation of data sensors and from the post-processing and analyses of sensor data.

    While the use of UAS’s has enormous research potential, their use requires strict observance of Federal Aviation Administration (FAA) regulations, as this agency controls all navigable airspace within the United States. The FAA established specific regulations for Small UAV’s (sUAV) under 14 CFR Part 107 effective August 29, 2016.

    All University employees, students, and visitors must comply with FAA regulations and SSU policy in order to operate an UAS on University property or at University sanctioned events or under any project being done under the University name.
     
  3. Authorization
    The Provost/Vice President for Academic Affairs is responsible for the implementation and enforcement of this policy and may delegate to the AVP for Research.
     
  4. Applicability
    This policy applies to powered aircraft operated without a human pilot onboard, by SSU faculty, students, staff, university volunteers and the general public in the course of scholarly endeavors, recreation and commercial operations. Powered aircraft consist of fixed wing, helicopter, drone and rocket. Commercial use of these aircraft on and off campus by those who represent SSU is governed by specific contractual agreement prepared by the Procurement Office.
     
  5. Revisions
    Jointly the AVP of the Office of Research and Sponsored Programs and the Director of Risk Management are responsible for reviewing this policy by April 30, 2021 and bi-annually thereafter, to ensure the policy is current and up to date, and revise as appropriate.
     
  6. Acronyms and Definitions
    Unmanned Aircraft Systems (UAS)
    An all-encompassing description that encapsulates the aircraft (i.e. drone or UAV), the ground-based controller, and the system of communications connecting the two.


    Unmanned Aerial Vehicle(UAV)
    Commonly known as a drone, is an aircraft without a human pilot aboard.

    Small Unmanned Aerial Vehicle (sUAV)
    UAV weighting 0.55 lbs.(250 gm) and 55 lbs.(25 kg)

    Federal Aviation Administration (FAA)

    Flight Operations Proposal/Plan (FOP)

  7. Procedures for Research or Instruction

    1. Prior to deployment of any UAS/sUAV by SSU faculty, staff, students, or volunteers, operators must have an SSU approved Flight Operations Plan approved by the UAV Review Board. Operators must submit a Flight Operations Proposal to the UAV Review Board no later than 30 days prior to flight date. The approved Flight Operations Proposal serves as the Flight Operations Plan.
       
    2. Unmanned Aircraft Systems
      Unmanned Aircraft Systems (UAS) and Unmanned Aerial Vehicles (sUAV) used under the provisions of this policy will be tagged and follow SSU inventory control procedures. All sUAV’s will have the FAA registration number displayed on the craft in as large a format as practicable.
      Operating a sUAV without a Flight Operations Plan, UAV Review Board approval or a properly registered vehicle violates this policy and may result in administrative action, including those in accordance with the SSU Policy on Research Misconduct.
       
    3. UAV Review Board
      The UAV Review Board is a presidentially-appointed committee under CSU guidelines composed of the Director of Risk Management (or designee), the Director of Environmental Health & Occupational Safety (or designee), the University Chief of Police (or designee), the Senior Director of Faculty Research & Sponsored Programs (FRSP), one Academic Dean, two faculty members familiar with UAV operations and one alternate.
      The UAV Review Board is responsible for the review, approval and oversight of sUAV/UAS operations at SSU. An approval from the UAV Review Board provides a minimum level of assurance that the operators are aware of the additional FAA requirements, and are prepared and capable of operating the sUAV safely and responsibly. Only operations approved by the UAV Review Board are permitted under this policy.
       
    4. Application/Operations Procedure
      1. The following steps outline the process to gain approval to use UAS’s for research:
        1. The Principal Investigator (PI) develops the Flight Operations Proposal (FOP) and submits the Application for Purchase and Use of Unmanned Aerial Systems to the UAV Review Board for campus approval. 
        2. Upon approval of the Flight Operations Proposal by the UAV Review Board, an approval letter (or denial) will be delivered to the applicant.
        3. The applicant may then purchase the sUAV/UAS through the Electronic Requisition process.
        4. Flight operations may commence provided all FAA Part 107 regulations are followed throughout every component of operations and provided that a sUAV Certified Pilot is present.
      2. Flight Operations Proposals (FOP) should minimally address the following elements:
        1. Purpose, nature (research, instruction, other) and goals of the work to be undertaken
        2. Need for a UAS/sUAV.
        3. Type of vehicle(s) and equipment to be utilized and the manner in which they will be operated.
        4. The identity of the FAA certified sUAV pilot(s) who serves as sUAV pilot or observer.
        5. Date(s)/Schedule of activities to be undertaken.
        6. Locale(s) and flight plan for operations.
        7. All forms of data (including imagery) to be collected.
        8. Provisions for security of the equipment, both during and outside of operation, and of any sensitive data collected.
        9. Sources and nature of financial support.
        10. Communications plan for notifying campus police, local landowners, and police agencies, as appropriate, in the overflight radius of planned operations each time an sUAV is flown.

          Careful consideration should also be given to other issues such as airworthiness, training, and access to requisite personnel, such as qualified visual observers.

          All accidents that result in injury, property damage or vehicle repair must be reported to the UAV Review Board and Campus Police within 24 hours of the incident.
           
    5. Data Storage and Use
      Only approved research projects may collect data under the auspices of SSU. The sUAV must have a university property tag for tracking purposes, FAA registration and designated campus storage locations identified in the Flight Operations Plan. Data collected using UAS’s that do not adhere to these guidelines, are in violation of federal, state, local law, or that are not approved by the UAV Review Board cannot be published with an SSU affiliation. Collection of such data without prior approval may be construed as research misconduct. Any data sharing or distribution is the responsibility of the PI or faculty member and should generally be publically available within one year of termination of the data collection project.

      This policy prohibits the unlawful photography and surveillance on public or private property. As such, the PI or faculty member for a project will perform due diligence to ensure proper use of data as specified by this policy and local, state, and federal regulations. This includes data review by an individual designated by the PI, faculty or staff member to eliminate sensitive, compromising, or otherwise inappropriate material (e.g. attributes that identify individuals such as, but not limited to, recognizable faces, license plate numbers on vehicles, etc.) before data are distributed for analysis beyond the research team, stored on a server with broader access, or made public in any way. When a UAS is operated in conjunction with a partner agency (e.g., County, State, Federal or NGO), and the agency has first access to the data, the agency will perform the prescribed due diligence.

    6. Maintenance and Storage of Equipment and Instrumentation
      The physical maintenance, storage and preparation of UAS’s operated and owned by SSU will be conducted by an academic program or administrative area. This responsibility rests with the PI, faculty member or administrative staff member named in the Flight Operations Plan.

      Aside from any fixed, onboard systems (i.e., temperature loggers, GPS, barometers, navigation, cameras), the maintenance (including calibration) of any sensor instrumentation is the responsibility of the PI, faculty or staff member who filed the Flight Operations Plan.

      The Provost or designee may review and modify assignment of responsibilities for the maintenance and storage of UAS’s and equipment as needed. Any university-owned UAS and related support equipment will be stored in appropriate facilities designated in the approved Flight Operations Plan.

    7. Document Retention
      Copies of the UAV Review Board approval will be maintained in the Office of Research and Sponsored Programs for a period of three years.

    8. Compliance with Applicable Regulations and Law
      The UAS/sUAV operator is responsible for compliance with all relevant FAA Part 107 regulations and any changes in regulations issued by the FAA (see FAA link below). Both the applicant and the campus should ensure that the proposed UAS operations:
      1. Comply with applicable laws, governmental regulations and University policies
      2. Do not pose a threat to health, safety, privacy, or the environment
      3. Do not operate over large groups of people or near buildings
      4. Include appropriate steps to manage and mitigate associated risks
      5. Serve the mission of the University and interests of the public at large
         
    9. Flight Operation Requirements
      Prior to commencing flight operations, the UAS/sUAV operator must have in possession the appropriate procedures and any documentation to ensure safe, legal and appropriate operation. During flight operations of the aircraft, pilots must have in their position documentation that includes but may not be limited to the following:
      1. UAV Review Board approval letter
      2. Proof of access to public or private property associated with flight operations
      3. Valid FAA sUAV Pilot’s Certificate held by the sUAV pilot or observer
      4. FAA UAV registration number (displayed prominently on the aircraft)

      Following approval and prior to beginning operations, appropriate insurance coverage should be obtained for registered UAV’s. Information on obtaining insurance can be obtained from the Office of Risk Management.

    10. On-Campus and Recreational Use
       
      1. Recreational use of sUAV’s is prohibited in the airspace over campus property without approval by the UAV Review Board.
      2. Instructional use of sUAV’s within the curriculum is permitted when piloted only by students and in accordance with the FAA May 12, 2016 clarification letter on educational use (or superseding FAA communications). UAV Review Board approval is required and may be granted in perpetuity by course number.
      3. Contractual agreements for 3rd party commercial UAV use must be routed through the Electronic Requisition (EREQ) process and is subject to UAV Review Board approval.
      4. sUAV purchases must be routed through the Electronic Requisition process to ensure compliance and inventory control. sUAV/UAS’s are prohibited items for Procurement Card transactions.
      5. In all cases, any sUAV/UAS use on campus must have written authorization from the UAV Review Board prior to operations. Additionally, the UAV operator must have this authorization on his/her person during flight operations
         
      References
      Federal Aviation Administration Regulations on UAV’s (Part 107) 
      Federal Aviation Administration UAV Registration Site