Use of Small Unmanned Aircraft Systems (sUAS) on University Property Policy
Responsible Executive(s): Dean for Research and Executive Vice President
Responsible Office(s): sUAS Management Team
Contact(s): Please direct questions concerning this policy to firstname.lastname@example.org, or Karla Ewalt, Associate Dean for Research at email@example.com or 258-9410. More information about sUAS is available at the website drones.princeton.edu.
Effective Date: 1/16/17
I. Policy Statement
This policy establishes an approval process and procedures to ensure safe and responsible operation of sUAS in, on or above University Property. Adherence to this policy ensures compliance with all applicable laws, enhances safety, and preserves the security and privacy of the members of the University community.
II. Who Is Affected by This Policy
This policy applies to any person operating or seeking to operate sUAS in, on or above University Property, including University Appointees, Invitees and members of the public.
Federal Aviation Administration (FAA). U.S. government agency under the Department of Transportation, which regulates civil aviation including unmanned aircraft systems.
Invitee. An individual or entity who visits University Property, by invitation of a faculty member, staff member, or registered student organization for some purpose that benefits Princeton University, including, but not limited to, contractors/third-party operators, consultants and vendors.
No Drone Zone. An area over which unmanned aircraft are not allowed to fly.
Small Unmanned Aircraft Systems (sUAS). An unmanned controlled aircraft of a weight up to 55 pounds, any size or design, and all associated support and control equipment, such as communications, telemetry and navigational equipment intended to fly in the National Airspace System. sUAS may also be referred to as a drone or model aircraft.
(Note: Aircraft that weigh 55 lbs or more will need to receive authorization through the FAA Section 333 exemption process. Contact the sUAS Management Team for more information.)
sUAS Advisory Committee. A sub-committee of the University Environmental Safety and Risk Management (ESRM) Committee, comprised of representatives from University offices including, but not limited to, Audit and Compliance, Dean for Research, Environmental Health and Safety, Facilities, General Counsel, Public Safety, Risk Management, School of Engineering and Applied Sciences, and Procurement Services, who serve as advisors to the sUAS Management Team on issues pertaining to the oversight of sUAS.
sUAS Operator(s). Person(s) seeking to operate the sUAS, each of whom is responsible for maintaining control of the sUAS throughout the flight.
sUAS Management Team. A group with sUAS operational management responsibility, composed of a senior representative from the Offices of the Dean for Research, Environmental Health and Safety and the Department of Public Safety.
University Appointee. Any faculty member, postdoctoral appointee, student, staff member, or any other individual with an appointment at the University, paid or unpaid.
University Property. Any land or facilities owned or leased by the University.
The University recognizes that sUAS may offer significant contributions to the teaching and research endeavors of University faculty, researchers and students, and may also offer opportunities for University administrative offices in carrying out their functions. The use of sUAS, however, is regulated by law and can pose significant safety, security and privacy risks to the University community. To minimize those risks, it is the policy of the University to:
- Ensure that the operation of sUAS in, on or above University Property complies with all applicable laws, regulations, and rules as updated or amended, including but not limited to Sections 333 and 336 of the FAA Modernization and Reform Act of 2012, the FAA Summary of Small Unmanned Aircraft Rule (Part 107), and Princeton University’s sUAS Safety and Operational Standards.
- Require that any person seeking to operate sUAS in, on or above University Property for any purpose must comply with the procedures below.
- Establish the sUAS Advisory Committee, which shall provide advice to the sUAS Management Team on issues pertaining to the oversight of sUAS.
Prohibited Uses of sUAS
In addition to any prohibited uses of sUAS established by law, the University prohibits:
- The operation of sUAS on University Property by persons of the general public;
- Hobby or recreational operation of sUAS inside of University buildings;
- The operations of sUAS in, on or above University Property without prior approval by the sUAS Management Team as required in this policy;
- The operation of sUAS in areas of public assembly, sporting events or areas of construction without prior approval by the sUAS Management Team;
- The use of sUAS to monitor or record areas where there is a reasonable expectation of privacy in accordance with accepted social norms and legal requirements;
- The use of sUAS to monitor or record inside of University facilities from the outside without prior approval by the sUAS Management Team; or
- The use of sUAS in a No Drone Zone or in any location in which there is a significant safety, security or privacy risk to the University community as determined by the Department of Public Safety, the Office of Environmental Health and Safety, or the sUAS Management Team.
To operate an sUAS in, on or above University Property, a University Appointee must:
1. Submit an sUAS Flight Request form for all locations that require approval to firstname.lastname@example.org along with documentation of all required training, certifications and registrations;
- Locations that require prior sUAS management team approval include all outdoor locations and all indoor public spaces, common areas, and rooms that may be reserved (e.g., atrium, hallways, classrooms, athletic facilities).
- Locations that do not require prior sUAS Management Team approval are indoor spaces, where use is otherwise permitted, that are assigned to specific faculty, staff, or students (e.g., research laboratory, office)
2. Receive approval in advance from the sUAS Management Team. Approvals will specify the date(s) and time(s) of operation. Additional operation times and/or locations require new form submission and approval.
3. Operate in a manner that preserves the safety, security and privacy of people and structural integrity of University Property at all times and in accordance with Princeton University’s policies, including the sUAS Safety and Operational Standards.
To operate an sUAS in, on or above University Property, an Invitee must:
- Have a request submitted on the Invitee’s behalf to email@example.com by the University department responsible for the Invitee while on campus, along with documentation of all required training, certifications and registrations.
- Have a signed contract with Princeton University covering the operation of an sUAS in, on, or above University Property that: (a) holds the University harmless from any resulting claims or harm to individuals and damage to University Property, (b) provides liability (general liability or aircraft hull liability) coverage with a $1 million per occurrence limit, and (c) adds “Trustees of Princeton University, its officers, employees, students and agents” as an additional insured. Any modification or deviation from these insurance requirements will require review and approval by Risk Management.
- Receive approval in advance from the sUAS Management Team. Approvals will specify the date(s) and time(s) of operation. Additional operation times and/or locations require new form submission and approval.
- Operate in a manner that preserves the safety, security and privacy of people and structural integrity of University Property at all times and in accordance with Princeton’s policies, including the sUAS Safety and Operational Standards.
- Obtain approval from the Office of Communications for photography and/or filming. Invitees must fill out and submit an Authorization Form to the Office of Communications.
- Be accompanied at all times, when the sUAS is operating, by a representative of the University department responsible for the Invitee while on campus.
Persons violating this policy will be held accountable for their actions, including:
- Persons operating an sUAS on University Property in violation of any applicable federal, state, or local law or regulation or in violation of University policies may be directed to cease operation of the sUAS immediately.
- Unauthorized sUAS Operators who are not University Appointees or Invitees may be removed from University Property, reported to local law enforcement and the FAA, and subject to other legal action by the University.
- University Appointees will be subject to applicable University policies and procedures, which may include disciplinary actions.
- Failure to comply with FAA regulations pertaining to sUAS may result in civil or criminal penalties under federal law.
VII. Related Documents and Forms
Princeton University sUAS Website - drones.princeton.edu
sUAS Flight Request Form - https://drones.princeton.edu/suas-flight-request-form
sUAS Flight Management Checklists - https://drones.princeton.edu/sites/drones/files/suas_pre-flight_checklist.pdf
sUAS Safety and Operational Standards - https://drones.princeton.edu/sites/drones/files/suas_safety_and_operational_standards.pdf
Photography Authorization Form - https://www.princeton.edu/communications/services/docs/Authorization-form.pdf
FAA Website on UAS - https://www.faa.gov/uas/
VIII. Roles and Responsibilities
|sUAS Management Team||The sUAS Management Team enforces the policy, assists with processing requests for sUAS activities consistent with applicable regulations, laws, and policies, provides policy interpretation, responds to general inquiries regarding sUAS activities, reviews and approves requests to fly sUAS, and issues No Drone Zones and temporary flight restrictions of sUAS flights on University Property.|
|sUAS Advisory Committee||Provides advice and consultation to the sUAS Management Team on issues related to the oversight of sUAS, including policy and process development.|
|sUAS Operator||The operator is personally responsible for complying with FAA regulations, state and federal laws, and University policies. The operator must obtain approval in advance to fly an sUAS on campus for any outdoor location or indoor public space, common area or room that may be reserved.|
IX. Related Policies
U.S. Department of Energy Order: Aviation Management and Safety (DOE O 440.2C) (applies to Princeton Plasma Physics Laboratory)
X. Update Log
August 11, 2017 – Added contractors/third-party operators to definition of Invitee; added requirement that contractors/third-party operators must be accompanied by sponsoring University department representative when operating sUAS on/above Princeton University property.