Environmental Health & Safety Policies

SY45 Use of Drones

Policy Status
Active
Subject Matter Expert
Debra Thurley, 814-865-1775, djd116@psu.edu
Policy Steward
Chief of University Police and Public Safety; Associate Vice President for Research, Director of the Office for Research Protections

Contents:


PURPOSE:

To define the requirements for the use of a Drone on property owned or controlled by The Pennsylvania State University (“Penn State” or “University”), or elsewhere for University-Affiliated Activities.

DEFINITIONS:

Operator: any person controlling the flight of a Drone, whether through the direct operation as a pilot or under the supervision of a remote pilot in command. 

Restricted Areas: University Property that the University has deemed too sensitive or unsafe to permit use of Drone.   

Drone: an aircraft operated without the possibility of direct human intervention from within or on the aircraft.   

University-Affiliated Activity: an event, function or activity sponsored by the University, or a University department, organization, or group.  This includes research activities conducted under the auspices of the University but does not include activities by recognized student organizations.  

University Property: all property owned, occupied, or leased by The Pennsylvania State University.  Except with respect to Milton S Hershey Medical Center, for which Drone operations are governed by this policy and A-133 HAM, this does not include property that is solely, owned, occupied, leased or controlled by Penn State Health and governed by Penn State Health policy.  

USE OF A DRONE

Use of a Drone on University Property or for University-Affiliated Activities not on University Property is prohibited unless the operator is a student, University employee (in the course of their employment), or other individual approved by the University to operate a Drone.  Approval for all Drone operations on University Property must be provided by the Drone Operations Analyst. Such approval is at the sole discretion of the University. All such uses of a Drone, for any purpose, regardless of the size of the Drone or whether the mission is being conducted indoors or outdoors, must abide by University Policy and procedures, as well as the applicable FAA authorization.   

 
Restricted & Altitude Restricted Areas.  Use of Drones in Restricted Areas, or in violation of the maximum altitude above the ground in Altitude Restricted Areas, is prohibited by all Drone operators, for any purpose.  If the mission needs to be conducted above the FAA posted altitude, the pilot should work with the Drone Operations Analyst to submit a request to the FAA asking for authorization to operate at a higher altitude.
 

A. On University Property

Each University campus, in collaboration with the Drone Operations Analyst, will be responsible for developing a map identifying Restricted Areas for its respective campus.  If applicable, space may be deemed a Restricted Area only for particular day and/or times. 

B. For University-Affiliated Activities Not on University Property

Use of Drones for University-Affiliated Activities must abide by University policy as well as the rules and regulations governing the area of flight.  The pilot is responsible for obtaining documented permission from the property owner of the property where the Drone operations will occur. Such permission shall be provided to the Drone Operations Analyst. 

REQUIREMENTS FOR ALL OPERATIONS OF DRONES:

All use of a Drone on University Property and all use of a Drone on non-University property by the University, its students and employees, or third party contractors or affiliates for University-Affiliated activities must abide by the following requirements:

  1. Drone Flight Request. Prior to conducting drone operations on University Property or as part of a University-Affiliated activity, a drone flight request must be submitted to the ORP and approval must be granted. 

  2. University Drone Flight Operations Manual.  All Drone operations on University Property or as part of a University-Affiliated activity must be conducted in accordance with the applicable federal, state, and local laws, as well as the University’s Drone Flight Operations Manual, which addresses issues such as training, pre- and post-flight procedures, flight logs, safety concerns and flight restrictions. 

  3. Registration. All Drones being flown outdoors must be registered with the FAA. Penn State owned Drones must be registered under “The Pennsylvania State University." 

  4. Insurance. Drones that are purchased and owned by Penn State must be reported to the Drone Operations Analyst who will coordinate with the Risk Management Office to be added to the fleet of insured vehicles. Penn State staff are not permitted to use personally owned Drones on University property or for University-affiliated activities. Third parties who are operating on University property or for a University-affiliated activity must meet the third party insurance requirements. Proof of insurance does not consistute flight approval. A drone flight request must still be submitted to and approved by the Drone Operations Analyst for approval before a drone flight is conducted (see #1 above). 

  5. License. Operators must possess and supply their piloting credentials to the University prior to flight. Students operating under the Exception for Limited Recreational Operations of Unmanned Aircraft (USC 44809) are not required to possess a remote pilot license. However, any pilot who is operating for recreation is required to complete the FAA Trust exam. Additionally, the University’s Drone tutorials must be completed and all drone operations must be approved by the Drone Operations Analyst.

  6. Waivers and Authorizations. Penn State personnel wishing to operate outside of the FAA Part 107 provisions must work with the Drone Operations Analyst to submit a waiver request to the FAA. If a third party will be operating under their own FAA Part 107 waiver or authorization, the third party will provide copy to the Drone Operations Analyst for prior approval.  

  7. Airport. Pilots operating within a 5-mile radius of an airport must request authorization through the FAA. Most airport facilities fall under a Low Altitude Authorization Notification Capability (LAANC) and requests can be submitted using a LAANC approved application. Additional information may be found at https://www.research.psu.edu/DroneOperations.

  8. Safety. Storage and use of a Drone shall not create an undue hazard to life or property, and they may not be operated in a way which invades privacy, unduly affects the environment of those working within a building, or those entering, exiting or walking around a facility or University Property. The Drone must be under the control of the operator at all times.

  9. Permissions. All use of Drone operations on University Property or for University-Affiliated Activities require prior authorization by the Drone Operations Analyst. Some University Property locations will require additional authorizations, which will be coordinated by the Drone Operations Analyst. Drone Operations that are part of a University-Affiliated Activity but not on University Property must receive documented permission from the property owner of the property where the Drone operations will occur. Such permission shall be provided to the Drone Operations Analyst. Operations that occur in a country that is not governed by the FAA must follow the respective country’s authoritative rules. 

  10. Accident Reporting. All accidents that result in injury or that cause property damage (other than to the Drone itself) must follow the Accidents Incidents and Events of Interest Standard Operating Procedure (SOP). In addition, all injuries must be reported as outlined in Policy SY04, Employee Accidents – Reporting and Investigation, and SY05, Injuries to Any Person, And Reporting Incidents Involving Other Than Employees.

  11. Training. All Drone operators must successfully complete the Drone tutorials. Penn State pilots are also required to go through a standardization flight check. Third parties are required to go through a flight observation. 

  12. Film Agreement or Indemnification Agreement. Third parties may require further coordination with the Offices of Strategic Communications for a film agreement and Procurement Services for an indemnification agreement. Approval from Strategic Communications does not constitute flight approval.  A drone flight request must still be submitted to and approved by the Drone Operations Analyst for approval before a drone flight is conducted (see #1 above). 

EXCEPTIONS:

Any exceptions or waivers to the FAA regulations related to a flight request or this Policy must be pursued through the University’s Drone Operations Analyst. Public Safety entities requesting flights to support emergency response must follow FAA policies and procedures to obtain flight authorization. Entities making such requests will coordinate with Police and Public Safety who will make notification of such flights to the University’s Drone Operations Analyst.  

RESPONSIBILITIES:

Drone Operator: the operator of the Drone is directly responsible for, and is the final authority as to, the operation of that Drone. The Operator is responsible for ensuring Drone operations complies with federal, state, and local laws as well as this Policy.  

Office for Research Protections (ORP): The University shall establish and maintain policy and procedures for safe and compliant use of Drone operations on University Property or as part of a University-Affiliated Activity. The ORP will provide oversight of established policies and procedures related to Drone operations.  The ORP will identify the Drone training criteria required by this Policy and keep records of all training/certification completed as required by federal, state, and local laws as well as this Policy. 

Drone Operations Anlayst: The University shall designate an individual to serve as the Drone Operations Analyst. The Drone Operations Analyst shall be responsible for and have authority for approval of all Drone Operations conducted at or by the University. The Drone Operations Analyst shall report directly to the Director of Reserach Safety and Compliance, who reports to the Associate Vice President for Research, Director, ORP, on matters related to Drone operations, and will regularly consult with the Offices of Risk Management, Police and Public Safety and Strategic Communications.

  1. Develop and maintain the University’s Drone Flight Operations Manual.  
  2. Promote Drone operations in support of the University mission that are safe, effective, and efficient.
  3. Ensure that University faculty, staff, and students participating in University Drone operations comply with federal, state and local laws, applicable waivers, authorizations or letters of agreement, and this Policy.
  4. Serve as the University’s primary point of contact with the FAA for issues relating to the use of Drones on University Property or as part of a University-Affiliated Activity.
  5. Ensure compliance with FAA/NTSB reporting requirements.
  6. Maintain all required records.

NONCOMPLIANCE:

The University has the right to immediately terminate the operation of a Drone if it interferes with campus operations, poses hazards to any person or university facilities, equipment, or other property, or has not received the proper approvals as required by federal, state, and local laws as well as this Policy.  Failure to comply with this Policy, the standards set forth in the University’s Drone Operations Manual, a Drone approved flight plan, or regional, state, or federal law may result in a decision of non-compliance. Non-compliance can lead to the prescription of remediation and/or sanctions, up to and including revocation of the privilege to fly a Drone under the auspices of the University or on University Property.  Suspected non-compliance shall be handled by the Drone Operations Analyst and the ORP as described in the applicable standard operating procedures. Additionally, policy AD104 may apply.

FURTHER INFORMATION:

For questions, additional detail, or to request changes to this policy, please contact Assistant Vice President for Police and Public Safety or the Associate Vice President for Research and Director of the Office for Research Protections.

CROSS REFERENCES:

AD53 - Privacy Statement

SY04 - Employee Accidents - Reporting and Investigation

SY05 - Persons, Other Than Students or Employees, Who Are Injured or Become Ill on University Property

AD104 - Trespass Warning Policy


 

Most Recent Changes:

  • May 28, 2024 - Changed reference of Part 101 to USC 44809, added AD104 as a cross-reference, other small changes.  

Revision History (and effective dates):

  • September 1, 2023 - Updated Subject Matter Expert to Debra Thurley, Associate Vice President for Research.  
  • June 8, 2023 - Updated policy steward from AVP of UPPS to Chief of UPPS.
  • January 20, 2022 - Terminilogy change from "Unmanned Aircraft" to "Drone."
  • November 11, 2020 - Policy rewritten; Requirements section fully updated. 
  • May 23, 2018 - Policy rewritten; sections added: Requirements for all Operations of UA, Exceptions, Responsibilities, and Noncompliance. Co-steward added: Associate Vice President for Research, Director of the Office for Research Protections.
  • September 1, 2015 - The Policy and Use of an Unmanned Aircraft sections have been revised to clarify the point that all uses of UA for all University purposes must be done in accordance with the FAA guidelines.
  • October 23, 2014 - New policy.
Date Approved
Date Published