The purpose of this policy is to establish the requirements that every use of a UAS on or over University Property is in connection with a University Related Activity and

• is allowed by law and University policy;
• meets all conditions and limitations imposed by applicable law and University policy;
• is conducted safely, without harm or unreasonable risk of harm to persons and property; and
• respects personal and organizational privacy interests and does not inappropriately or illegally invade or diminish those privacy interests.

This policy applies to:

• all uses of UASs by University employees, faculty, students, vendors and/or agents in connection with any University Related Activity;
• any flights of UASs on or over University Property; and
• any flights of UASs in connection with University Related Activities not on or over University Property.

The Federal Aviation Administration (FAA) regulates the use of all aircraft, including UASs, in the National Airspace System. Brown University faculty, staff, students, vendors or agents who wish to use UASs on or over University Property or in connection with University Related Activities must send an application to Environmental Health & Safety (EHS) to seek approval for the use of a UAS in support of University Related Activities.

EHS must approve all UAS uses on or over University Property or in connection with University Related Activities, whether outdoors or indoors, prior to such use.

For the purpose of this policy, the terms below have the following definitions:

Civil Aircraft: Any aircraft except a Public Aircraft.

National Airspace System (NAS): The airspace, navigation facilities and airports of the United States along with their associated information, services, rules, regulations, policies, procedures, personnel and equipment.

Public Aircraft: An aircraft owned and operated by the United States government, government of a State, the District of Columbia, or a territory or possession of the United States or a political subdivision of one of these governments in furtherance of a governmental function, and that is not used for commercial purposes.

Remote Pilot in Command (PIC): The person directly responsible for and is the final authority as to the operation of the UAS.

UAS: An Unmanned Aircraft System (UAS) without a human pilot onboard controlled from the Remote Pilot in Command on the ground. An aircraft operated without the possibility of direct human intervention from within or on the aircraft. Another term for UAS is Drone.

University Property: The land and all real property owned or controlled by the University, as well as the airspace above such land and property.

University Related Activity: An activity undertaken by University faculty, staff or students, by recognized student groups, or by vendors or authorized agents of the University that relates to any academic, research, public service, administrative, or other function or purpose of the University and that is approved by a University Sponsor.

University Sponsor: A University faculty or staff member with the authority to make departmental decisions and able to adhere to responsibilities set forth in this policy.

All individuals to whom this policy applies are responsible for becoming familiar with and following this policy. University supervisors and employees with student oversight duties are responsible for promoting the understanding of this policy and for taking appropriate steps to help ensure and enforce compliance with it.

Remote Pilot in Command: The Remote Pilot in Command is responsible for

• Requesting and obtaining EHS approval prior to operating a UAS on or over University Property;
• Following the requirements of this policy, the Drone / UAS Standard Operating Procedure and all applicable laws and regulations;
• Maintaining safe UAS operating conditions;
• Maintaining possession of the approval letter from EHS at all times during UAS operation;
• Maintaining appropriate insurance, if operating for a vendor and/or for commercial use, as outlined in the Drone / UAS Standard Operating Procedure; and
• Immediately reporting any UAS related accident that results in injury or property damage.

University Sponsor: The University Sponsor is responsible for

• Ensuring the Remote Pilot in Command understands this policy and that the Remote Pilot in Command submits an application for approval to the EHS prior to using the UAS;
• Confirming that, when applicable, vendor contracts are in place prior to UAS use; and
• Ensuring that UAS operations are for eligible uses only.

Environmental Health & Safety (EHS): EHS is responsible for

• Administering this policy, including the review and approval (in consultation as needed with members of the University UAS Advisory Committee) of all applications for approval of UAS use in connection with University Related Activities;
• Responding to requests from University constituents for information and education about UAS use on or over University Property;
• Reviewing this policy regularly and updating as necessary, in consultation with the University UAS Advisory Committee;
• Identifying instances of non-compliance with law or this policy, and bringing such instances to the attention of the appropriate University personnel; and
• Reporting accidents or injuries that the University is required to report to the FAA or NTSB.

University UAS Advisory Committee: The committee shall meet as needed and shall be responsible for

• Assisting EHS as needed with reviewing applications from individuals or entities seeking permission to operate a UAS on or over University Property or in connection with a University Related Activity; 
• Reviewing appeals from application denials;
• Assisting EHS with assessing problems (or making of recommendations for the resolution of problems) relating to University Related UAS Activities;
• Recommending revisions and updates to this policy; and

Staying current with regulatory changes and emerging issues relating to UAS.

Failure to comply with this and related policies is subject to disciplinary action, up to and including suspension without pay, or termination of employment or association with the University, in accordance with applicable (e.g., staff, faculty, student) disciplinary procedures, or for non-employees may result in the suspension or revocation of the third party’s relationship with Brown University.

Violations of this policy by students shall be considered a violation of the University’s Student Code of Conduct or Academic Code and will be subject to disciplinary proceedings through the Office of Student Life or Dean of the College. 

Brown University is a community in which employees are encouraged to share workplace concerns with University leadership. Additionally, Brown’s Anonymous Reporting Hotline allows anonymous and confidential reporting on matters of concern online or by phone (877-318-9184).

The following information complements and supplements this document. The information is intended to help explain this policy and is not an all-inclusive list of policies, procedures, laws and requirements.