Procedures Relating to Policy PS-05:
Unmanned Aircraft (Drones/Model Aircraft)

University Users

Go to Hobbyist & Commercial Users Procedures

In conjunction with IU Policy PS-05, this set of procedures outlines the steps required to obtain approval to purchase and/or operate unmanned aircraft systems (UAS), including both Drones and Model Aircraft, on or above IU property.

It is important to note that the Federal Aviation Association (FAA) is responsible for the regulation and oversight of civil aviation within the U.S. The FAA delineates model aircraft operations for hobby or recreational purposes (see Hobby/Recreational Flying) from civil and public uses.

The PS-05 policy and these procedures apply to all university operations (i.e., not campus specific).

  1. Safety Procedures
    The Small Unmanned Aircraft System Safety Program established by Indiana University must be followed.
  2. Procedures are applicable to "small" UAS
    This program applies to all UAS. All UAS greater than 55lbs will require an aircraft-specific safety review and written safety plan. This safety review may include consultation with industry experts and regulators to determine the adequacy of the safety plan. If a safety plan cannot be developed that addresses IUEHS/INLOCC safety concerns, flight of the UAS will not be permitted by Indiana University. Contact Larry Stephens for further information.
  3. Use by IU employees or students as part of any university related activity or research (Drones)
    1. Registration with IU - You may not operate a UAS in relation to university business or over university property unless it and its use are registered with IU.
      1. Any present use of UAS shall be suspended until university approval is received.
      2. To register, complete the IU online application form provided by INLOCC.
      3. A list of approved registrations will be maintained by INLOCC.
    2. IU Approval - Registration forms will be automatically submitted to the appropriate units for approval. Approval must be unanimous. The review team includes:
      1. INLOCC
      2. Office of University Environmental, Health, and Safety Management (UEHS)
      3. Campus IUPD Chief
      4. Emergency Management and Continuity (EMC)
      5. University Chief Security Officer (UCSO)
      6. University Chief Privacy Officer (UCPO)
      7. Office of the Vice President and General Counsel (OVPGC)
    3. If any variance occurs from the operations and information as described on the form, you must contact stephenl@iu.edu describing the changes. A determination will be made if further action is needed by the approval group. A number of the regulations under Part 107 can be waived. You must request waiver using the IU online application form and we (INLOCC) will request the waiver from the FAA (if approved by the IU committee).
    4. Liability insurance is required. INLOCC will arrange for the necessary insurance but the department with the UAV will be responsible for the cost.
    5. Restrictions
      In operating a UAS for purposes of recording or transmitting visual images, operators must take all reasonable measures to avoid violations of areas normally considered private. Indiana state law provides that a person who knowingly or intentionally places a camera or electronic surveillance equipment that records images or data of any kind while unattended on the private property of another person without the consent of the owner or tenant of the private property commits a Class A misdemeanor.

      Use of UAS for video or electronic surveillance must comply with PS-02 Video and Electronic Surveillance. All uses of UAS must comply with Appropriate and Prohibited Uses specified below.

      1. UAS shall not be used to monitor or record areas where there is a reasonable expectation of privacy in accordance with accepted social norms. These areas include but are not limited to restrooms, locker rooms, individual residential rooms, changing or dressing rooms, and health treatment rooms.
      2. UAS shall not be used to monitor or record residential hallways, residential lounges, or the insides of campus daycare facilities.
      3. UAS shall not be used to monitor or record sensitive institutional or personal information which may be found, for example, on an individual's workspaces, on computer or other electronic displays.
      4. If images will be viewed or captured during the use of the UAS, additional information is needed on the registration form (see the form).
      5. Photos and video will be limited to areas and subjects required to achieve the purposes identified in the INLOCC registration form.
      6. Unless explicitly excluded by a Grant's project, if images of individuals will be captured in a resolution that allows people to be identifiable, prepare a written notice indicating the purpose of the filming to be distributed to anyone at the site who might be captured in the video.
      7. If identifiable images are captured, it is expected that reasonable safeguards will be employed to protect the data.
      8. If operating the UAS in a foreign country, verify with your international sponsor whether or not this activity implicates national and local data privacy laws.
    6. IU-FAA Approval - The FAA is very clear that any non-hobby/non-recreational use must have FAA authorization.
      1. To obtain an FAA COA, 333 exemption or Part 107 remote pilot in command designation for university use, the IU registration form will be used by INLOCC to gather information needed for the FAA process.
      2. FAA Part 107 eliminates the need for a COA or 333 exemption in most cases.
        1. While unlikely, if your proposed flight has very unusual parameters a 333 exemption might be required. We will advise you if that is determined.
        2. Part 107 gives you more freedom about where you fly BUT you still have the limitations of IU approval. If you wish to fly outside the original parameters given in the IU approval process, you must amend your application.
        3. An important requirement under Part 107 is the remote pilot in command. (See below)
        4. Any part of the rule shown as waiveable requires an application for waiver as an amendment to your IU application. INLOCC will then apply for the waiver. Do NOT apply to the FAA for a waiver, bypassing the IU approval process.
      3. Qualifying as RPIC under Part 107.

        Some of the steps to become a RPIC under Part 107 can be completed before 8/29/2016 when Part 107 becomes effective. Other steps cannot be completed until 8/29 or later.

        1. See Becoming a Pilot
        2. Study materials: Advisory Circular
        3. Study materials: Remote Pilot Airman Certification Standards
        4. Sample knowledge test
        5. Holders of a Part 61 license who have had a review within 2 years may become an RPIC by taking the online course. Others may take the course as a study help for meeting the requirements above.

          Logon at the FAAS site.

          If you do not have a logon ID/profile, create one.

          Click the link for the Part 107 sUAS course

        6. Everyone — new RPICs and Part 61 pilots becoming RPICs — must undergo a security check by the TSA. This is done by submitting FAA Form 8710-13. This will not be available until 8/29/2016. A link will be posted here when available.
      4. A 333 exemption request will be made if circumstances so dictate and, if granted, a 333-COA application will be completed.
        1. Do NOT attempt to register with the FAA directly. INLOCC is the IU point of contact with the FAA.
        2. The FAA 333 / COA process can be slow. They indicate a 60-days window (now increased to 120 days) for approval. It may take longer.
        3. At this time we do not know how broad a 333 will be regarding operations (what you do and where you do it). As we learn more about the process the information will be posted here.
      5. A Certificate of Authority (COA) (outside the 333 process) is for "governmental operations". The most likely resaon we would apply for a COA is police operations. Contact INLOCC is you feel your department needs a COA.

      6. Classes of Airspace

        You must be cognizant of the airspace you are flying in. Of IU's Indiana campuses (excluding Fort Wayne), only Bloomington and Columbus are in Class E airspace. If flying off–campus, you must consult air charts (see below) to determine what airspace you will be in.

        An unofficial review can be found at https://en.wikipedia.org/wiki/Airspace_class_(United_States). This is a good page to read because the amount of information is extensive. You should also review https://www.faasafety.gov/gslac/ALC/course_content.aspx?cID=42&sID=505&preview=true. This is a training page but it‘s an FAA page. See also Airspace.pdf (undated).

        It is incumbent upon the PIC (pilot in command) to know what kind of airspace he or she is about to fly in and whether they need a waiver. IU does not provide indemnification or insurance if you are fined for violations of FAA regulations. See https://skyvector.com/ or http://vfrmap.com/ for online charts (see legend below). Waivers can be requested at https://www.faa.gov/uas/request_waiver/.

        We have been told by one office of the FAA that waivers are specific to the Part 107 pilot requesting them, i.e., "IU" can‘t request a waiver for all drone flights in Class E airspace over IUB. To that point:

        "The FAA issued a news release last week in an effort to help applicants submit complete and appropriate waiver and airspace authorizations for part 107 drone operations. As of Nov. 2, 2016, the FAA has issued 119 authorizations for flights in Class D and E airspace, and has issued 47 waivers of part 107 provisions to drone operators who applied after the rule's effective date. However, the agency has found that many applications have incorrect or incomplete information. Many applicants request too many waivers or request waivers for flights in types of airspace for which the FAA is not yet granting approvals.

        The FAA says it's important for applicants to understand the information needed to make a successful safety case for granting a waiver and that they should refer to the performance–based standards. Applicants are also encouraged to help speed the process by making sure they make a solid, detailed safety case for any flights not covered under the small drone rule. To see the complete press release, click here."

        See also:

        1. Unmanned Aircraft Systems (UAS) Frequently Asked Questions/Help

        2. Fact Sheet — Small Unmanned Aircraft Regulations (Part 107)

        3. IU pilot Eric Rudd's waiver

        4. Supplementary document

    7. International Approvals - INLOCC will work with IU employees and students planning to use UAS in foreign countries to determine what requirements exists and how those requirements may be met.
    8. No IU-owned UAV/UAS will be rented, leased or lent to a non-IU party.
    9. To fly a UAS for the university you must:
      1. Have approval from IU through the application and approval process.
      2. If a) flown in the United States and b) flown outside, it must be registered with the FAA. Contact stephenl@iu.edu for registration.
      3. Have obtained a Part 107 license as RPIC — and provide proof of licensure and TSA clearance to INLOCC, or
      4.    Use a Part 61 pilot and fly under a 333 exemption obtained through the IU process, or
      5.    Fly under a COA obtained through the IU process.
      6. Be insured through INLOCC.

    10. Purchase of a UAS (or the parts to assemble a UAS) with university funds or funds being disbursed through a university account, or grant funds
      1. Request Approval to Purchase - It is recommended that you complete IU's online registration form provided by INLOCC before a purchase is made
        1. Include Intended/expected use of UAS
        2. Form will be submitted to appropriate units for approval.
      2. Approval to Purchase - If IU approval is granted:
        1. Purchase the UAS
        2. Update your application with the make, model and serial number of the unit. Notify stephenl@iu.edu the information is available for registration.
        3. INLOCC (stephenl@iu.edu) will register it with the FAA showing the Trustees of Indiana University as the owner (not an individual or department).
        4. INLOCC will amend your IU application with the registration number and supplemental information.
    11. For further information, contact Larry Stephens, 812-855-0104.