Memorandum #165—Use of Small Unmanned Aircraft Systems (sUAS) Policy

Original Date of Issue: November 22, 2023
Approved by: President
Policyholder: Associate Vice President, Budgets and Business Services, and Risk Manager; and Director, Public Safety and Security

PURPOSE

This policy establishes the minimum requirements for the use of small unmanned aircraft systems (sUAS) on Community College of Philadelphia (“College”) property in accordance with the regulations set forth by the Federal Aviation Administration (FAA) and the Commonwealth of Pennsylvania. The use of sUAS is not permitted in any location on College property unless authorized via the process outlined in this policy. These guidelines are established to support the use of sUAS in ways that ensure the safety and protect the privacy of all members of the College community, and promote compliance with all applicable federal, state and local laws.

No Unmanned Aircraft Systems over 55 pounds are permitted on or over College property under any circumstances

SCOPE

This policy applies to the entire College community while operating a sUAS on or over College property, including students, faculty, staff, contractors and visitors. All sUAS use on College property must adhere to the requirements stated in this policy and all federal, state and city regulation

DEFINITIONS

1. Federal Aviation Administration (FAA). U.S. government agency under the Department of Transportation, which regulates civil aviation including unmanned aircraft systems.
2. No Drone Zone. An area over which unmanned aircraft are not allowed to fly.
3. Small Unmanned Aircraft Systems (sUAS). An unmanned controlled aircraft of a weight up to 55 pounds, any size or design, and all associated support and control equipment, such as communications, telemetry and navigational equipment intended to fly in the national airspace system. sUAS may also be referred to as a drone or model aircraft.
4. sUAS Operator(s). Person(s) seeking to operate the sUAS, each of whom is responsible for maintaining control of the sUAS throughout the flight.
5. ­­­­­­­­College Property. Any land or facilities owned or leased by the College.

PROHIBITED USES of sUAS

1. Invasion of Privacy: Using sUAS to capture images, video or audio in a manner that invades an individual's reasonable expectation of privacy is strictly prohibited. This includes recording or photographing individuals in spaces where an individual has a reasonable expectation of privacy, i.e., restrooms, locker rooms, or individual work spaces.
2. Harassment and Surveillance:  sUAS should not be used for the purpose of harassing, stalking or surveilling individuals without their consent.
3. Interference with College Operations:  Operating sUAS in a manner that disrupts College activities, events, or operations is not allowed. This includes flying sUAS in areas where they could potentially distract or interfere with classes, meetings or emergency response efforts.
4. Endangering Safety:  Using sUAS in a manner that endangers the safety of individuals or property is prohibited. This includes flying too close to people, buildings or vehicles, or conducting reckless maneuvers that could result in accidents.
5. Flying in Prohibited Zones:  sUAS should not be operated in areas designated as no-fly zones, which may include restricted airspace, military installations, near airports, and other areas outlined by relevant aviation authorities.
6. Hazardous Materials:  Carrying or delivering hazardous materials, weapons, or dangerous items via sUAS is not allowed.
7. Use for Illegal Activities:  Using sUAS for any illegal activities, including but not limited to drug trafficking, harassment, or vandalism, is strictly prohibited.
8. Commercial Use:  Flying sUAS for commercial purposes, such as aerial photography or delivery services is not allowed on College property.
9. Personal Use:  Flying sUAS for personal use is not permitted on College property.
10. Non-Compliance with Federal and Local Regulations: All use of sUAS on College property must comply with federal, state, and local regulations. Violating these regulations is strictly prohibited.
11. Unauthorized Modification of sUAS:  Modifying sUAS in a way that makes them unsafe or non-compliant with regulations is strictly prohibited.

sUAS REGISTRATION

All sUAS, weighing between 0.55 lbs and 55 lbs, must be registered with the Federal Aviation Administration (FAA) and must be registered under “Community College of Philadelphia.” Visit the FAA drone registration webpage for more information.

Use of sUAS On, Over or Near College Property

All members of the College community operating a sUAS on or over College owned or leased property are responsible for complying with Federal Aviation Administration regulations, state, and local laws and as well as all other College policies. Operators of sUAS are expected to follow the FAA's basic guidelines for flight safety and the Small Unmanned Aircraft Systems Rule (Part 107). Part 107 (14 CFR Part 107) is the primary regulation for flying drones weighing less than 55 pounds. Part 107 permits drones to be flown for many reasons, including work or business, recreation, education, or for public safety missions.

sUAS may only be used on or over College property for educational purposes in connection with educational courses or programs. Commercial and personal use of sUAS are strictly prohibited.

Operators are required to follow these rules:

1. Operate your sUAS in a safe manner. 
2. Instructors must possess and supply piloting credentials to the College’s Associate Vice President of Business and Budgets. 
3. Students in College credit programs operating under 14 C.F.R. Part 101 are not required to possess a remote pilot license, however, they must complete the Recreational UAS Safety Test, carry proof of test passage, and only operate the sUAS under the supervision of a credentialed pilot and College instructor.
4. K-12 participants in the College’s Jr. STEM Academy who fly sUAS under .55 lbs must pass the Recreational UAS Safety Test, earn a TRUST Certificate and only operate the sUAS under the supervision of a credentialed pilot.
5. Follow the safety guidelines of existing aeromodelling organizations or use the FAA-provided safety guidelines per Advisory Circular 91-57B.
6. No flying UAS/drones heavier than 55 pounds.
7. Keep the sUAS within eyesight at all times.
8. Only operate one sUAS at a time.
9. Give way to and do not interfere with manned aircraft.
10. Obtain authorization before flying in controlled airspace.
11. Do not fly higher than 400 feet.
12. Do not fly near people, moving vehicles, or personal residences.
13. Do not interfere with emergency response activities.
14. Comply with No Drone Zone locations. 
15. Have a current registration mark on your sUAS showing the registration number, and carry proof of registration with you (unless the sUAS is under .55 lbs). Educational programs must coordinate their flight plan with the FAA.

Accident Reporting

All accidents resulting in injury or property damage must be reported to the Department of Public Safety and to the Associate Vice President of Budgets and Business Services.

Sanctions

Violations of this policy may result in disciplinary actions in accordance with student conduct policies, collective bargaining agreement, the Employee Handbook, and/or other College policies. Legal prohibitions regarding physical presence on College property apply to sUAS. Legal action may be pursued against parties that operate sUAS in violation of this policy.

This policy applies to operations of sUAS on or over College property. All Community College of Philadelphia faculty, staff and students must fully comply with the policies and procedures of any other facility before flying sUAS over any other facilities’ property.