Use and Safety Protocol for Unmanned Aerial Systems Governed by FAA Part 107

Preamble

The educational use of unmanned aerial systems (commonly called unmanned aerial vehicles, unmanned aerial devices, drones, multicopters, or quadcopters), hereafter called "UAS" in this Protocol, can make significant contributions to academic research and service in a variety of academic disciplines. Additionally, aerial photography with UAS can assist in support functions in furtherance of the University's educational mission.

The purpose of this Protocol is to promote the safe and orderly use of institutional property and safe and orderly conduct of academic research, coursework and other educational activities, or other support functions in furtherance of the University's educational mission, on institutional property or elsewhere with landowner permission. Washington and Lee University seeks to permit UAS to be used productively in a manner that meets institutional legal and safety responsibilities and that complies with requirements of the Federal Aviation Administration's (FAA) final rule on Small Unmanned Aircraft Systems, 14 C.F.R. Part 107 (hereafter "Part 107") and Advisory Circular AC 107-2 (hereafter "AC 107-2") . This Protocol applies to UAS governed by Part 107.

Any UAS operator previously authorized under the University's Revised Interim Use and Safety Guidelines who has not, by the date of adoption of this Protocol, obtained a Remote Pilot Certificate and registered each UAS that they previously have been operating for University purposes, will no longer be authorized to operate any UAS covered by Part 107 for University purposes until s/he has done so.

I. Specific Use Authorization Required

No person shall operate a UAS on W&L property, or for university purposes elsewhere, without prior authorization from either the Provost or designee (faculty uses for academic research, course-related operations, or other academic purposes, which authorization would allow non-compensated student use in furtherance of an educational course or project when under the direct supervision of that faculty member or another RPIC) or the Treasurer/Vice President for Finance and Administration or designee (all other employee uses). Authorization shall be specific to a particular course, research project, or other academic purpose, or particular University support function in furtherance of the University's educational mission. Approvals may be granted for a recurring course, ongoing research project, or ongoing University support function without the need to seek approval for each event related to such ongoing course, project, or function. Any individual seeking use authorization must apply in writing for such authorization and provide the information specified in the request form. As s/he deems it necessary or helpful, the University official reviewing an authorization request may consult with other appropriate University officials, including but not limited to the Director of Public Safety, the Director of University Facilities, the Director of Environmental Health and Safety, and/or others. If approved, the operator(s) must be in physical possession of the use authorization during UAS operations, or be able to present it promptly if requested by University Public Safety or law enforcement. UAS must be operated in accordance with this Protocol and any restrictions accompanying the use authorization.

Note: individuals who previously had a Use Authorization under the now obsolete UAS Guidelines and/or Interim Guidelines and who intend to engage in UAS operations after the adoption of this Protocol should submit a new Use Authorization Request under this Protocol.

Note: Student use of UAS for coursework is considered "recreational," as is de minimis faculty use of UAS, incidental and secondary to student operation of UAS in a course where UAS operation is one part of the curriculum, but not the principal point of the course. However, more than de minimis use by faculty in such a course, and any and all faculty research use or other non-course use (and use of a student or staff employee for such other use) would NOT be considered recreational and would fall under Part 107 and require adherence to this Protocol. Recreational users must comply with the model aircraft safety standards and not Part 107 - - see https://www.faa.gov/uas/faqs and https://www.faa.gov/uas/getting_started/fly_for_fun. Student use of UAS on W&L's campus is not permitted with the exception of academic use referenced in this paragraph or other educational uses under the supervision of a faculty member authorized to do so pursuant to this Protocol.

II. Definitions

Control Station: An interface used by the Remote Pilot in Command or the person manipulating the controls to control the flight path of the UAS.

Person Manipulating the Controls: A person other than the Remote Pilot in Command who is manipulating the flight of a UAS under the supervision of the Remote Pilot in Command.

Remote Pilot in Command (RPIC): The UAS operator authorized by the Provost or Treasurer/Vice President for Finance and Administration under these guidelines. The RPIC has the final authority and responsibility for the operation and safety of the UAS operation. The RPIC is required to be a certificated Remoted Pilot under Part 107.

Visual Observer (VO): A person acting as a flightcrew member who assists the RPIC and any person manipulating the controls to see and avoid other air traffic or other objects aloft or on the ground.

III. UAS Use Parameters and Restrictions

  • UAS shall not weigh more than ten (10) pounds, with payload.
  • UAS operations shall not endanger the safety of the National airspace system.
  • UAS operations shall not pose an undue hazard or threat to health, safety, or property.
  • UAS RPIC must maintain the UAS in safe operating condition and inspect the UAS prior to flight in accordance with AC 107-2 best practices (Chapter 7 and Table C-1) (see pre-flight inspection checklist template in Appendix A to this Protocol) to determine that the system is in condition for safe operation; further, the RPIC shall discontinue any flight when the condition of the UAS or circumstances would pose a hazard to other aircraft, people, or property.
  • UAS RPIC must conduct a pre-flight assessment of the planned operation, in accordance with FAA Part 107 (see required elements in Appendix B to this Protocol).
  • Only one UAS may be operated at a time.
  • Only daylight operations are allowed.
  • Visual Line of Sight (VLOS) only - - the RPIC and person manipulating the flight controls must have the capability to see the UAS at all times during flight with unaided vision (except eyeglasses or contact lenses). If the location of the flight renders this impossible, the UAS must remain within VLOS of designated visual observer(s). On board first-person view cannot satisfy the VLOS requirement, but can be used as long as VLOS is satisfied in other ways. If, during a flight, VLOS is lost and cannot be regained, the RPIC or person manipulating the controls should follow pre-determined procedures, depending on the capacity of the UAS, which may include immediate landing, entering hover mode, or auto fly home.
  • The VO(s) must be able to effectively communicate the UAS location (altitude, attitude, and direction) and the position of other aircraft or hazards, to avoid endangering life or property. The VO(s) and RPIC must establish effective and non-distracting means of communication (whether handheld radios, Bluetooth, or other means).
  • UAS shall not be used autonomously without the possibility of human intervention.
  • UAS shall not exceed 350 feet above ground level on the W&L Campus and Peniel Farm, or any other W&L-owned property.
  • Minimum visibility, as observed from the location of the control station, must not be less than three (3) miles.
  • UAS shall not fly over any non-W&L owned property without permission from the landowner, shall not exceed 400 feet above ground level when flying over such property, and shall be used only within the scope of the permission granted.
  • No UAS may be operated at a speed in excess of 50 (fifty) miles per hour.
  • RPIC must download the B4UFLY app and always check it before flight operations to determine if there are any temporary flight restrictions in effect for the area of operations or if the planned flight is to be conducted within controlled airspace (Classes B, C, D, or E). If so, RPIC needs to obtain Air Traffic Control permission to use the airspace via the FAA online portal (not by contacting the particular tower or airport). No notification or authorization is necessary if the UAS operation is in uncontrolled airspace (Class G). Note: for flights of UAS at the altitude allowed under these Revised Interim Guidelines, the W&L campus and Peniel Farm are in uncontrolled airspace (Class G).
  • UAS shall not be used in proximity to any manned aircraft, and shall be operated in a manner than does not interfere with and gives way to any such aircraft.
  • When flown within the vicinity of an airport or heliport, the RCIP must be aware of all traffic patterns and approach corridors and avoid operations that may interfere with airport operations. Note: As of the date of adoption of this Protocol, W&L and Carilion Stonewall Jackson Hospital are collaborating on a letter of agreement regarding campus UAS operations and hospital helipad operations. Once that letter is finalized, it will become an addendum to this Protocol.
  • UAS shall not carry any weapon or any hazardous substance (small batteries or other power sources with appropriate protections are not considered hazardous for the purposes of these guidelines).
  • No RCIP, person manipulating the controls, or VO shall operate a UAS while under the influence of alcohol or drugs; nor shall such person participate in the operation if s/he knows or has reason to know of a physical or mental health condition that could interfere with the safe operation of the UAS.
  • UAS shall display the RPIC's contact information and aircraft registration information.
  • The RCIP shall be in possession of the use authorization as approved by the appropriate University official, his/her Remote Pilot Certificate, and proof of registration obtained for the UAS.
  • No operator should fly a UAS directly over or near persons not participating in the operation of the UAS unless they are located under a covered structure or covered stationery vehicle capable of providing reasonable protection from a falling UAS.
  • No UAS may be operated from a moving land or water vehicle unless in a sparsely populated area; no UAS may be operated from a moving aircraft.
  • For the entire flight, the RCIP and any personal manipulating the controls, or VO, must know the location of the UAS, observe the airspace for other aircraft or hazards, and determine the UAS does not pose an undue hazard to persons or property.
  • All UAS operations and all RPICs shall comply with Part 107, as well as other applicable laws and regulations, and applicable University policies.
  • The RPIC may deviate from the requirements of these guidelines and Part 107 in response to an in-flight emergency.
  • UAS RPICs represent that they have knowledge of this Protocol, proficiency with the UAS, system reliability, safe lost-link behavior, and georeference functionality prior to any use of the UAS.
  • Any injury or property damage caused by a UAS should be reported to University Public Safety right away.
  • Any operation of a UAS that results in serious injury (requiring hospitalization), loss of consciousness, or property damage of at least $500 (to property of that or greater value) must be reported to the FAA by the RPIC within ten (10) days of operation with notice to the Office of the Treasurer of the University. Report to: https://www.faa.gov/uas/report_accident/.
  • Any authorized UAS operation on University property not conforming to this Protocol or any unauthorized UAS operation on University property should be reported immediately to University Public Safety.Adopted: July 12, 2017
    By the Provost and the Treasurer/Vice-President for Finance and Administration

Adopted: July 12, 2017
By the Provost and the Treasurer/Vice-President for Finance and Administration

Replacing Revised Interim Guidelines Adopted: October 25, 2016
Replacing Interim Guidelines Adopted: July 8, 2015
By the Provost and the Treasurer/Vice-President for Finance and Administration

This Protocol was derived, in part, from the following institutional policies and draft policies: Michigan State University, Interim Policy on University Use of Uncrewed Aerial and Submersible Vehicles (May 20, 2014); Colgate University Draft Small Airborne Object Safety Guidelines (January 19, 2015); Smith College, Safety Code for Small Airborne Objects on Institutional Property (February 28, 2014) and updated following the final FAA's adoption of Part 107.

APPENDIX A

Preflight Inspection Checklist Template - - FAA Part 107

Even if the small unmanned aircraft system (sUAS) manufacturer has a written preflight inspection procedure, it is recommended that the Remote PIC ensure that the following inspection items are incorporated into the preflight inspection procedure required by part 107 to help the Remote PIC determine that the sUAS is in a condition for safe operation.

Conduct a preflight visual or functional check of the aircraft, including (but not limited to) the steps below.

  • Visually inspect the condition of the unmanned aircraft system components
  • Inspect the airframe structure, including undercarriage, all flight control surfaces and linkages
  • Inspect registration markings for proper display and legibility
  • Inspect moveable control surface(s), including airframe attachment point(s)
  • Inspect servo motor(s), including attachment point(s)
  • Inspect the propulsion system, including powerplant(s), propeller(s), rotor(s), ducted fan(s), etc
  • Verify all systems (e.g. aircraft, control unit) have an adequate energy supply for the intended operation and are functioning properly
  • Inspect the avionics, including control link transceiver, communication/navigation equipment and antenna(s)
  • Calibrate UAS compass prior to any flight
  • Inspect the control link transceiver, communication/navigation data link transceiver, and antenna(s)
  • Check that the display panel, if used, is functioning properly
  • Check ground support equipment, including takeoff and landing systems, for proper operation
  • Check that control link correct functionality is established between the aircraft and the control station
  • Check for correct movement of control surfaces using the control station
  • Check on board navigation and communication data links
  • Check flight termination system, if installed
  • Check fuel for correct type and quantity
  • Check battery levels for the aircraft and control station
  • Check that any equipment, such as a camera, is securely attached
  • Verify communication with UAS and that the UAS has acquired GPS location from at least 4 satellites
  • Start the UAS propellers to inspect for any imbalance or irregular operation
  • Verify all controller operation for heading and altitude
  • If required by flight path walk through, verify any noted obstructions that may interfere with the UAS
  • At a controlled low altitude, fly within range of any interference and recheck all controls and stability

Adapted from Advisory Circular (AC) 107, Small Unmanned Aircraft Systems


APPENDIX B

Pre-Flight Assessment of Planned UAS Operation
(separate assessment from pre-flight inspection of UAS)


1. Conduct an assessment of the operating environment. The assessment should include at least the following:

  • Local weather conditions,
  • Local airspace and any flight restrictions,
  • Location of persons and property in the planned operations area, and
  • Other ground hazards.

2. Make sure that all persons directly participating in the UAS operation are informed of the following:

  • Operating conditions,
  • Emergency procedures,
  • Contingency procedures (including but not limited to loss of VLOS that cannot be regained),
  • Roles and responsibilities of each person involved in the operation, and
  • Potential ground or air hazards.

3. Confirm that all control links between the control station and the UAS are working properly. If the RPIC observes that one or more of the UAS flight control surfaces are not responding correctly to control station inputs, the RPIC should not conduct flight operations until correct movement of all flight control surfaces is established.

4. Confirm that there is sufficient power to continue controlled flight operations to a normal landing.

5. Make sure that any object attached or carried by the UAS is secure and does not adversely affect the flight characteristics or controllability of the aircraft.

6. Confirm that all necessary documentation is available for inspection, including the University use authorization, the RPIC's Remote Pilot Certificate, and Aircraft Registration.

June 2017