Unmanned Aircraft Systems (UAS) or Drones

FAA Flowchart  UAS Self-Assessment Tool

Overview

Unmanned Aircraft systems (UASs) or drones, as they are often called, come in a variety of shapes and sizes, and are used for various purposes. Regardless of the size, shape or purpose, they need to be flown safely and in compliance with all Federal Aviation Administration (FAA) rules and the University of Florida (UF) Policy.

Only UAS flown outdoors are subject to FAA rules. However, the UF Policy addresses additional privacy requirements for flying UASs indoors.

UASs include the unmanned aircraft and associated elements, including communication links and components that control the unmanned aircraft, required for the pilot-in-command to operate the UAS safely and efficiently. Examples of UASs include Unmanned Aerial Vehicles (UAV), Remotely Piloted Vehicles (RPV), Drones, Unmanned Aircraft (UA), Remotely Piloted Aircraft (RPA), Remote helicopters (including quadcopters, hexacopters, octocopters, etc.)

The FAA regulates UAS operation that falls into the following three categories: (1) operation by a public entity for a public purpose; (2) operation by a civil/commercial entity for a civil/commercial purpose; and (3) operation of model aircraft by any user for a hobby or recreational purpose. FAA rules differ depending on the entity (public/civil) flying the UAS as well as the operation (public/commercial) of the UAS. Note that UF’s operation of UASs may fall into the first or second category, depending upon the purpose for which the UAS is flown. Further, in certain limited circumstances, a UF student’s operation may qualify for the third category as a hobby or recreational purpose (see “Model Aircraft (Hobby or Recreational Only)” below).

For more information or for frequently asked questions about UASs see Unmanned Aircraft Systems (UAS) FAQs.


Public Entity/Public Operation (Governmental)


Public entities include federal, state and local governmental agencies, as well as law enforcement and public universities and colleges. Since UF is a public body corporation of the state of Florida, UF faculty, staff and students who plan to fly a UAS, as part of their official UF work, fall in this category if the UAS is flown for one of the following governmental functions:

  • Intelligence missions, or
  • Firefighting, or
  • Search & rescue, or
  • Law enforcement, or
  • Aeronautical research, or
  • Biological or geological resource mapping.

Note: UASs used for research that does not fall under “aeronautical research” are not used for a governmental function and do not fall under this category. Similarly, education (teaching how to fly UASs) is not a governmental function and does not fall under this category.

UASs used by Public Entities for Public Operations (i.e., governmental functions) must apply for and receive a FAA Certificate of Authorization (COA) prior to flying.


Civil or Commercial Entity/Civil or Commercial Operation (Non-Governmental)


In general, commercial entities, private higher educational institutions and fly-for-hire groups that use UASs for commercial operations fall in this category. However, UF’s operation of UASs for research that will not qualify for the Public Operation (governmental function) category, including general educational uses of UASs (e.g., teaching how to fly UASs), also falls in this category. Examples of commercial operations include industrial equipment or factory inspections, professional photography, mapping, land or agricultural surveys, flight demonstrations, and other research or teaching functions.

UASs in this category must apply for a Special Airworthiness Certificate (SAC) or petition for a 333 Exemption prior to flying.


Model Aircraft (Hobby or Recreation only)


Model aircraft are small UASs flown solely for hobby or recreational purposes. Information collected during the flight from a model aircraft should be personal and cannot be funded by someone else or sold. In general, UASs flown by UF faculty, staff, or students in their official UF capacity will not qualify as being flown solely for hobby or recreational purposes. In some cases, however, UASs flown by students may qualify as model aircraft being flown for hobby or recreational purposes, but such operation must be approved in advance by UF Environmental Health & Safety. In particular, a student’s operation of UASs will qualify as a hobby or recreational use in the following circumstances:

  • Student UAS operation is a component of the student’s science, technology, or aviation-related educational curricula; or
  • Student UAS operation is a component of the student’s other coursework, such as television and film production or the arts.

Note that student operation of UASs will not qualify as hobby or recreational use if the UAS was used in support of a faculty member’s research or other sponsored activities, or the student received any form of compensation directly or incidentally related to the student’s operation of the UAS. Additionally, faculty participation in the student’s operation of the UAS will also qualify as hobby or recreational only where the faculty member provides limited assistance to students operating the UAS. In all other circumstances, faculty operation of UAS qualifies as either a public operation or commercial operation. For further explanation and examples of student uses of UAS for hobby or recreational purposes, see the FAA’s Interpretive Memorandum.

If you are operating a model aircraft for hobby or recreation only, and you have received pre-approval from EHS to do so, the following guidance will apply to your operation. Model aircraft can be operated under specific safety guidelines established by Congress that include but are not limited to, the following:

  • The model aircraft is operated in accordance with a community-based set of safety guidelines and within the programming of a nationwide community-based organization (such as the Academy of Model Aeronautics).
  • The model aircraft is not greater than 55 pounds unless additional, specific conditions are met.
  • The model aircraft is within line of eyesight at all times.
  • The model aircraft is operated in a manner that does not interfere with and gives way to any manned aircraft.
  • The model aircraft is flown below 400 feet above ground level, beyond 5 nautical miles of any airport, and beyond 2 nautical miles of any active heliport.

Effective December 14, 2015, owners of model aircraft weighing more than 0.55 pounds (250 grams) and less than 55 pounds (approx. 25 kilograms) including payloads such as on-board cameras need to register model aircraft with the FAA. For more information, see the FAA press release.


Certificate of Authorization (COA)


COAs are provided by FAA to allow Public Entities to fly the UASs for Public Operations. Generally, COAs are issued for a specific period of time and include special provisions unique to each operation.

However, UF has obtained a blanket COA for certain UF UAS operations on the main campus and at all extension facilities. To determine whether you are eligible to operate UASs under UF’s COA, contact UF Environmental Health & Safety.

In instances where UF’s blanket COA will not apply to your UAS operation, there are two main steps to apply for an individual COA:

  1. Contact EHS for access to the public FAA COA website and submit a letter on official letterhead indicating why secure access to the FAA COA website is needed. FAA checks the credentials of the person requesting access and does a background check. It typically takes FAA 7 – 10 business days to vet the applicant and create a login and password to allow the applicant to access the secure portion of the FAA COA web-site.
  2. Complete and submit the COA Application
    1. The applicant will either need a certified manned pilot or somebody with extensive aviation knowledge, to complete the application as certain sections of the application would not make any sense to a ‘non-aviation oriented’ individual. Note – an incomplete application or one that is clearly lacking aviation knowledge will immediately be returned to the applicant by the FAA for further information and resubmission, or rejected altogether.
    2. The applicant will also need to submit an airworthiness statement specific to the UAS. As a public entity, UF can self-certify airframes designed and built at UF. However, it is unlikely that UF can self-certify commercially available airframes that are purchased from manufacturers/vendors as the airworthiness certification requires information from someone familiar with UAS development as well as specifics on the UAS performance parameters.
    3. The applicant will also need to provide specifics about the proposed UAS operation (i.e., sponsored research project for which the UAS is being utilized) as well as operating procedures, personnel qualifications, time of day, altitude, geographical area, fail-safes, etc.

Note – If there are any changes made to the UAS or the information contained within the COA application after a COA has been issued, the applicant must contact the FAA UAS COA office to ascertain if a ‘COA amendment’ is needed or whether a completely new COA application must be submitted.

For more information or for frequently asked questions about COAs see FAA COA website.


Special Airworthiness Certificate (SEC)


SECs in the experimental category are provided by FAA to allow Civil Entities to fly the UASs for Commercial Operations. An applicant needs to first register the aircraft and then submit an application to the local FAA office.

Contact the FAA office directly for further guidance on SECs or see the following sites for additional information.


333 Exemption


Since June 2014, FAA has accepted petitions for exemptions to the SEC from civil entities for low risk commercial operation. Examples include aerial filming and photography, critical infrastructure inspection, precision agriculture, research and development, and educational/academic uses.

Petition for 333 Exemption can be submitted electronically or in writing. Contact EHS before submitting a petition for 333 Exemption. Submission instructions are available here (PDF). The Petition for exemption should include:

  • Name, mailing address and contact information
  • Specific section(s) of the regulation from which you seek an exemption
  • The extent of relief and reason for the exemption
  • How the request would benefit the public as a whole
  • Reasons why the exemption would not adversely affect safety
  • A summary for publication in the Federal Register
  • Additional information, views, or arguments to support the request

As of March 23, 2015, the FAA will automatically grant a “blanket” COA for flights at or below 200 feet to any UAS operator with a Section 333 exemption, provided the aircraft weighs less than 55 pounds, operations are conducted during daytime, the operation is within visual-line-of-sight of the pilot, and certain distance away from airports or heliports. Details are available here.

Note: If you have an approved COA and wish to change any of the approved parameters of the existing COA, you need to apply for a separate COA specific to the new parameters.

For frequently asked questions about 333 Exemptions see the Permissions, Authorizations, Waivers, and Exemptions section of the UAS Frequently Asked Questions website.