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The beginning of Fall 2016 brought new restrictions on the use of drones and other unmanned aircraft systems (UAS). Since the Federal Aviation Administration (FAA) released new guidelines regulating drone usage, it has become increasingly difficult to use drones on state-funded college campuses such as Cal Poly.

While it is possible to fly drones and UAS on campus, getting approval for these aircrafts requires many steps including submitting paperwork, discussing intent and passing federal safety guidelines.

The new changes began in May 2015. A memorandum was sent out by the CSU Chancellor’s office breaking down the steps needed to fly a UAS on a CSU campus. In September 2016, Cal Poly reiterated the CSU and FAA guidelines, requiring that any and all drones owned by departments be registered with Cal Poly Risk Management.

As of now, there are two major ways UAS can be approved for departmental use on campus:

#1 — FAA Certificate of Authorization

The first way, which is the most likely to be approved, is through a Certificate of Authorization (COA) award by the FAA.

The FAA is the federal oversight committee in charge of regulating U.S. airspace, which includes governing power over airplanes, UAS and other aerial vehicles. In order to even apply for a COA, UAS must be public aircrafts. This means the UAS use must be non-commercial.  According to FAA standards, UAS “for educational or training purposes” are considered commercial. So, any UAS use must have some sort of purpose beyond educational value to be considered for a COA.

Once that is established, departments can request a COA through Cal Poly’s own UAS Committee, which reviews why a UAS is being used, who will be flying it, when it will be used and so on. If approved, the request is then sent to the CSU Office of General Counsel (OGC) to provide a public declaration letter that certifies the UAS is a public aircraft not used for commercial gain. With this letter, the application can be sent to the FAA for review and be granted a COA. After being granted a COA, the application still has to pass a flight-readiness test and a second overview by the University’s UAS Committee before it is approved for flight.

#2 — Section 333 Exception

The second way to fly an approved UAS on campus is through a Section 333 Exception, which is granted only rarely to non-public UAS. Somebody wishing to use a UAS but who does not comply with the COA guidelines can apply for a Section 333 Exception if they can prove they can still operate a UAS safely.

In this instance, the UAS request still goes though Cal Poly’s UAS Committee, but does not need a public declaration letter to be approved. Instead, they submit a petition for exemption to the FAA. If approved, this exemption lasts for two years. After being approved by the FAA, these applicants still need to pass a safety test and must be overviewed by the UAS Committee. Despite the significantly less paperwork, Section 333 exemptions for universities are rare. As of April 2015, only one has been granted.

Since these new regulations were put into place, the usage of UAS on campus has decreased as departments have to go through many steps to be approved through Cal Poly and the FAA.

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