Non-IU Drones Procedures

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

Hobbyist & Commercial Users

Go to University Users Procedures

In conjunction with IU Policy PS-05, these procedures outline the steps required to obtain approval to operate unmanned aircraft systems (UAS), including both Drones and Model Aircraft, from 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 defines 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 operations from  University properties (i.e., not campus specific).

1. 1. 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 INLOCC safety concerns, flight of the UAS will not be permitted by Indiana University. Contact Mitch Druckemiller for further information.

   2. University departments contracting for UAS services

      This may be a two–step process.

      1. The department buying the services must complete the IU online application form to receive clearance for the operation. The registrant will have the opportunity to select a vendor when doing this.
      2. If the department doesn’t find the vendor on the vendor list, then the vendor must register (at the same location) as a commercial operator. They should notify the department when that has been done so they can update their application.
      3. If a department is using a commercial operator, they must be able to select that business name before the application will be approved.

1. Use of a UAS/UAV by any non–IU entity for Hobby/Recreational Purposes (Model Aircraft), Commercial or other purposes
   1. IU controls hobby flights from  IU property and must grant approval for all flights.
   2. The Small Unmanned Aircraft System Safety Program established by Indiana University sets the minimum standards for safety that must be followed.
   3. Registration — You may not operate a UAS in relation to University business or from 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. If you are a commercial operator being hired by an IU department, that department should make the application using the “University users” button.
      3. A list of approved registrations will be maintained by INLOCC.
   4. 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 Privacy Officer (UCPO)
      6. Office of the Vice President and General Counsel (OVPGC)
   5. If any variance occurs from the operations and information as described on the form, you must contact Mitch Druckemiller describing the changes. A determination will be made if further action is needed by the approval group or the FAA.
   6. Liability insurance is required. (see below)
   7. 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. Commercial users: 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. Hobbyists:
         1. Hobby use, if approved, will require the hobbyist to sign an indemnification agreement with IU.
         2. The agreement covers the named pilot. No one else may operate the craft over university property.
         3. 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.
         4. Units must have GPS capabilities.
         5. Units must have the ability to limit their flying range. i.e., a “fence.” The maximum fence shall be 50 yards/meters.
         6. If mulitple UAS are flying in the same area, their fences may not overlap and must be separate by at least 20 yards/meters.
         7. Units must have “return–to–home” capability if the signal is lost from the controller.
         8. Units must have the ability to set minimum altitude on return–to–home. That altitude shall be 50 feet/15 meters.
         9. In keeping with FAA rules, all flights must be
            1. Line–of–sight, and
            2. The altitude must be no more 400 feet/122 meters A.G.L. 
            3. UAS can fly no closer than 100 yards/meters to buildings.
         10. No more than 5 observers are allowed at each control point.
             1. Observers may not be present unless they have signed waivers of liability that are on file with INLOCC. [online form to be available soon]
             2. Observers must not interfere with or distract the controller.
             3. Observers must stay within 10 feet/3 meters of the controller when inside the fence.
         11. Hobbyists may only launch within designated areas. Their “fence” must be within the designated area.
             1. IUB
                1. Field between Campus View and Tulip Tree
             2. IUPUI: none
             3. IUN: none
             4. IUSB: none
             5. IUK: none
             6. IUE: none
             7. IUS: none
             8. Bradford Woods: TBD
             9. Judson Mead: TBD
         12. If identifiable images are captured, it is expected that reasonable safeguards will be employed to protect the data.
         13. Each campus may adopt more restrictive rules.
      8. Commercial users: If operating the UAS in a foreign country (on behalf of the university), verify with the international sponsor whether or not this activity implicates national and local data privacy laws.
   8. FAA Approval
      1. FAA certification is not required for hobbyists. (see Hobby/Recreational Flying )
      2. Commercial entities must apply directly with the FAA, IU does not get involved in a third party’s quest for a COA or 333 exemption.
   9. IU Approval — to finalize the IU Approval process, the commercial entity must provide the UAS’s registration number and proof of compliance with Part 107 or proof of an aproved 333 exemption.
   10. IU Contract
       1. Commercial entities must also engage in a contract with IU prior to conducting business involving the UAS.
   11. Classes of Airspace

       FAA regulations have changed and a waiver to fly over the IUB campus is no longer required.

       The FAA says, “It’s still a good idea to let them (BMG) know you’re out there.” Based on that, we recommend you contact BMG when flying over the athletic facilities north of 17^th Street as this is a flight path for BMG.

   12. Insurance Requirements
       1. Commercial Operators
          1. Aircraft Liability
             1. Owned aircraft liability: $2 million
             2. Non–Owned aircraft liability: $2 million
          2. Other required coverages, provisions and certificate holder: see Vendors insurance policy
          3. The University reserves the right to change these requirements based on its determination of risk.
       2. Hobbyists
          1. Aircraft Liability
             1. Unless you can provide a certificate of insurance from your general liability insurance company (usually your homeowners insurance carrier) stating their policy applies to liabilities, in the amounts stated below, arising from the use of model/hobby aircraft, you must provide the following:
                1. Owned aircraft liability: $500,000
                2. Non-Owned aircraft liability: $500,000
                3. You must obtain a certificate of insurance from your agent showing these coverages. The certificate holder must be

                   The Trustees of Indiana University
                   c/o Office of Insurance, Loss Control & Claims
                   400 E. 7th Street Room 705
                   Bloomington, In. 47405-2206

                   and Indiana University must be named an Additional Insured.
                   
                   - or -
                4. Proof of coverage for at least $500,000 through the Academy of Model Aeronautics .
          2. The University reserves the right to change these requirements based on its determination of risk.
2. Identification & Infractions
   1. An identification card will be issued to each approved operator.
   2. The identification card will be shown upon request by any person.
   3. If suspect operations are observed, contact IUPD.
   4. Penalties for infractions may include
      1. Action by Academic Affairs
      2. Action by Student Affairs
      3. Action by Human Resources
      4. Referral to a local criminal justice agency (jail, prosecutor ...)
      5. A ban on further flying and revocation of any existing permits.

See also:

• • Unmanned Aircraft Systems (UAS) Frequently Asked Questions/Help 

• Supplementary document

For further information, contact Mitch Druckemiller, 812-855-6140.