Unmanned Aircraft Systems (UAS)/Drones Policy
Unmanned) aircraft systems (hereafter
drones, can be important and useful tools in supporting University priorities. Example uses
include: scientific mapping missions, archeological and geological field studies,
precision agriculture, aerial photography and cinematography, journalism, and more.
West Chester University recognizes that the regulated use of UAS may be beneficial
to academic and administrative units on campus and endeavors to allow this use while
ensuring the safety and security of the campus and surrounding communities. This policy
formalizes the processes to manage University-related UAS operations, to protect people
and property near UAS operations, and to ensure full compliance with all State and
Federal laws and regulations.
The Federal Aviation Administration (FAA) has jurisdiction over the national airspace system and UAS are subject to regulation by the FAA. Federal law is clear that the FAA may take enforcement action against operators who operate aircraft in a manner that endangers public safety or the safety of the national airspace system.
The policy ensures that the University has clear lines of authority and well-defined internal processes to identify, manage, and mitigate risk and to ensure safe and legal operation of UAS in furtherance of its institutional goals and objectives.
This policy applies to University employees, students, and visitors to campus, and it covers the use of UAS on the WCU campus.
Definitions and Background
- Unpersonned (or
Unmanned) Aircraft (UA): an aircraft without a human pilot onboard; instead, the UA is controlled by an operator on the ground. A UA is sometimes called a
- Small Unmanned Aircraft (small UA): an unmanned aircraft weighing less than 55 pounds (25 kg) on takeoff, including everything that is onboard or otherwise attached to the aircraft.
- Model Aircraft: a small UA flown strictly for hobby or recreational purposes.
- Unpersonned (or
Unmanned) Aircraft System (UAS): an aircraft without a human pilot onboard but with associated elements, including communication links and components used to control the UA safely and efficiently.
- Remote Pilot in Command (PIC): A person who holds a remote pilot certificate with a small UA rating and who has the final authority and responsibility for a small UAS operation conducted for work (14 CFR Part 107).
The FAA classifies all aircraft into one of two categories: public or civil. A public
aircraft is one that is used only for the United States Government; or owned and operated
by the government of a State, the District of Columbia, a territory or possession
of the U.S., or a political subdivision of one of those governments. Any aircraft
that does not meet the definition of a public aircraft is considered
civil aircraft. Regardless of category, however, all UA weighing more than 0.55 lbs. (250 grams)
must be registered with the FAA and labeled clearly before flight ().
The FAA effectively classifies civil aircraft operations into one of two categories: 1) flying for fun (as a hobby or for recreation) or 2) flying for work (for commercial or work-related purposes).
1 Flying for fun – Prohibited on WCU Property
Operating a UAS for hobby or recreational purposes on or over property owned, managed, or leased by West Chester University is prohibited. Any employee, student, or visitor wanting to fly UA for hobby or recreational purposes is encouraged to consult the local chapter of the Academy of Model Aeronautics (AMA) to find an AMA-sanctioned location where such use is approved.
2 Flying for work
Remote pilots in command (PIC) who are West Chester University employees (including student workers) or hired by University employees will comply with all FAA rules and regulations, and take great care to avoid violating the rights of others to privacy and from harassment. If working abroad, the PIC will comply with the rules and regulations of the country in which they are working.
Remote PICs will notify the UAS Advisory Committee (see below) about the location, date, time, and duration of any UAS operation on or over property owned, managed, or leased by West Chester University no later than 24 hours prior to the start of the operation. Flights over property owned, managed, or leased by West Chester University must maintain an isolation distance of 200 feet distance from private residencies and occupied student residence halls, and 50 feet from academic and administrative buildings. Any University employee interested in operating a UAS or hiring a third party to operate a UAS to support the University’s institutional goals or objectives should contact the office of the UAS Advisory Committee to discuss rules, responsibilities, and procedures.
In 2016, the FAA created new opportunities for businesses and government to use small UA. Remote pilots working for either a private business or a public entity may now operate a UAS in accordance with the rules in 14 CFR Part 107 (Summary of Small Unmanned Aircraft Rule (Part 107)):
Part 107 rules for remote pilots in command (PIC):
- Must hold a remote pilot airman certificate with a small UAS rating, which requires:
- being at least 16 years old;
- passing an initial aeronautical knowledge test at an FAA-approved knowledge testing center;
- vetting by the Transportation Safety Administration (TSA); and
- passing a recurrent aeronautical knowledge test every 24 months.
- Must conduct a preflight check of the small UAS (aircraft, control station, and crew) to ensure that it is in a condition for safe operation.
- Must not operate a small UA if he or she knows or has reason to know of any physical or mental condition that would interfere with the safe operation of a small UAS.
- Make available to the FAA, upon request, the small UAS for inspection or testing, and any associated documents/records required to be kept under the rule.
- Must report to the FAA within 10 days of any operation that results in serious injury, loss of consciousness, or property damage of at least $500.
- Must NOT act as a remote pilot in command or VO for more than one unmanned aircraft
operation at one time.
Part 107 rules for small UA operations:
- Operations in Class B, C, or D airspaces are allowed with ATC permission.
- Operations in G and some E airspaces are allowed without ATC permission.
- Operations must yield right of way to all other aircraft.
- The aircraft must NOT be flown recklessly or carry hazardous materials.
- Flight must occur during daylight (or during civil twilight with anti-collision lighting).
- Flight must occur within visual line-of-sight.
- Flight must occur while atmospheric conditions allow at least 3 miles of weather visibility from the control station.
- Flight must occur no higher than 400 feet AGL, or no higher than 400 feet above a structure if the aircraft is within 400 feet of the structure.
- Flight must NOT occur at speeds faster than 100 mph (87 knots).
- Flight must NOT occur over people not under a covered structure.
- Flight must NOT be controlled from a moving vehicle.
Part 107 rules for small UA:
- The aircraft must weigh less than 55 lbs. (25 kg). *
- The aircraft must be registered with the FAA if it weighs more than 0.55 lbs. (250 grams).
- The aircraft must be in a condition for safe operation before each flight.
Responsibilities and Procedures
1 UAS Advisory Committee
WCU will maintain a UAS Advisory Committee, initially to include 1 member from the President’s Office, 1 member from Information Services & Technology (IS&T), 1 member from Public Safety, and 2 members from Academic Affairs (1 faculty member and 1 administrative). The UAS Advisory Committee will be responsible for policy development, establishing fly/no-fly zones, flight plan approval, and public notice, as detailed below:
- Policy development - Creating, reviewing, modifying, or rescinding policies, procedures, and standards for University-related UAS operations.
- Reviewing applications for a public Certificate of Waiver or Authorization (COA) and making recommendations to approve or not approve them.
- Establishing fly/no-fly zones - Certain areas of campus are sensitive to privacy and safety of individuals. With additional regard to FAA regulations, zones of campus will be classified as areas that can or cannot be approved for UAV flights.
- Flight plan approval - Reviewing data acquisition plans for unmanned aircraft systems (UAS) and making recommendations (to approve or not approve them).
- Public notice - UAS flights made on or over property owned, managed, or leased by WCU will be made known to local authorities as determined by the UAS Advisory Committee. Notice of flight details will be made available through online documents managed by the UAS Advisory Committee.
2 Future changes to FAA rules
As the aviation industry, UAS technology, and applications of UAS evolve, the FAA may change the special rules for model aircraft, the rules in Part 107, or other rules. Any change will supersede this policy and, if needed, prompt a meeting of the UAS Advisory Committee to recommend to the President and Cabinet to amend or rescind this policy.
3 Public Certificate of Waiver or Authorization (COA)
Government entities or organizations (e.g. public universities) not wanting to operate a UAS under Part 107 rules may choose to apply for a blanket public Certificate of Waiver or Authorization (Public COA). Public COAs can be granted only for purposes that meet the strict definition of public aircraft operations. Public COAs cannot be granted to public universities for education, training, or other uses because those applications are considered commercial in nature. Note - any such COA would be granted to the University and not to an individual.
4 UAS Acquisitions
The UAS Advisory Committee, or its designee, will review and recommend approval, if appropriate, all university UAS and UAS sensor purchases to avoid duplication of effort within the university and to acquire systems that have broad applicability to the university’s research and education functions. The UA must weigh less than 55 pounds (25 kg) and be restricted to traveling less than 100 mph (87 knots). The aircraft must be registered with the FAA if it weighs more than 0.55 lbs. (250 grams).