Carnegie Mellon University

Unmanned Aircraft Systems (UAS), including aircraft commonly known as drones, are used at Carnegie Mellon University in a variety of ways related to academics, research, business and recreation.  All members of the  Carnegie Mellon community and guests on university property are expected to comply with all applicable federal, state, and local laws regarding the  operation of UAS.  In particular, all outdoor UAS operations must comply with Federal Aviation Administration (FAA) regulations.  Indoor UAS operation is not regulated by the FAA.

The Office of the General Counsel (OGC) and the Office of Risk Management and Insurance (ORMI) are available to assist members of the Carnegie Mellon community in obtaining necessary FAA registration and satisfying other FAA operational requirements.  In order to confirm compliance with FAA regulations and coverage under the university's insurance, please contact drones@.cmu.edu in advance of any outdoor UAS operation.  

The FAA has different regulations for recreational UAS operation and civil UAS operation.  Recreational operation is strictly limited to the operation of UAS for personal interests and enjoyment. Use of a UAS for any other reason is considered civil operation.  Under FAA rules, any use of a UAS for university business, including faculty research and sponsored research, or any non-recreational purpose is considered civil operation (also known as non-recreational operation). 

As detailed below under Student Academic Operation, there are limited circumstances where student UAS operation for the student's own academic pursuits may be considered recreational operation.

Recreational operators must abide by the following FAA guidelines:

  • Register the UAS with the FAA;
  • Fly at or below 400 feet;
  • Keep the UAS within visual line of sight;
  • Never flight near other aircraft, especially near airports;
  • Never fly over groups of people;
  • Never fly over stadiums or sports events;
  • Never fly near emergency response efforts such as fires;
  • Never fly under the influence of drugs or alcohol;
  • Be aware of FAA airspace restrictions (see FAA B4UFLY Smartphone App.

Source: FAA Fly for Fun website.

Civil UAS operation includes any UAS operation that is not strictly for the operator's own personal interest and enjoyment.  Examples of civil operation include, but are not limited to:

  • UAS operation for faculty or staff research projects
  • UAS operation by faculty, staff, or students for any sponsored research;
  • Student UAS operation for use in faculty/staff research or sponsored research;
  • UAS operation for aerial photography for use in any university-related purpose;
  • UAS operation for any university business purpose.

The FAA recently issued new regulations, effective August 28, 2016, concerning the civil operation of UAS.  These new regulations simplify the process for obtaining FAA approval for civl operation.  Individuals conducting civil operation on behalf of Carnegie Mellon should contact drones@cmu.edu for assistance in complying with these regulations and to confirm coverage under university insurance policies.

The most signification requirements of the FAA regulations are summarized below.  A complete list of requirements is available from the FAA at http://www.faa.gov/uas/media/Part_107_Summary.pdf.

  • The operator of the UAS must have a Remote Pilot Airman Certificate with a small UAS Rating or be directly supervised by an individual with such a certificate;
  • UAS must be registered with the FAA (see below under FAA Registration);
  • UAS must weigh less than 55lbs (25 kg), including any payload;
  • Visual line-of-sight operation only;
  • Daylight operations only;
  • UAS may not operate over any persons not directly involved in the UAS operation;
  • UAS must yield to other aircraft;
  • Maximum ground speed of 100 mph;
  • Maximum altitude of 400 feet above ground level;
  • Preflight inspection required;
  • May operate in Class G airspace without coordinating with Air Traffic Control.  Operations in Class B, C, D and E airspace are permitted with permission from Air Traffic Control;
  • Must comply with all other operational requirements of the FAA - see http://www.faa.gov/uas/media/Part_107_Summary.pdf.

Operations outside the parameters of FAA regulations summarized above require a waiver or exemption from the FAA.  Please contact drones@cmu.edu if you wish to apply for an FAA waiver or exemption.  Please note that requests for waivers or exempts may take upwards of 120 days for the FAA to process, depending on the nature of the request.

On May 4, 2016, the FAA issued new Guidance on Student Educational Use of UAS.  This guidance clarifies the circumstances under which student operation of a UAS for educational purposes will be considered recreational operation.

In short, student operation of UAS in furtherance of their own academic pursuits is considered recreational operation under FAA regulations, so long as all of the following apply:

  • The student receives no financial compensation for the UAS operation, including reimbursement of costs, honorariums, scholarships, etc.;
  • The student does not operate the UAS in connection with the professional duties, research,  and/or publication objectives of a faculty or staff member;
  • The student does not operate the UAS in connection with any sponsored project.

FAA guidance also specifies that because faculty and staff are paid employees, faculty or staff operation of UAS in connection with their professional duties is considered civil operation (i.e. non-recreational operation).  Therefore, faculty and staff who operate UAS in connection with their employment must satisify the FAA's regulations for civil UAS operation.

However, the FAA does provide a limited exception whereby a faculty instructor may provide limited assistance to student UAS operation in connection with the teaching of a course that uses UAS.  For this exception to apply, the UAS operation must be secondary to the design and construction of the aircraft, such that the primary purpose of the course is not to provide instruction on UAS operation.  For example, this exception would apply to an engineering course with a component on the design/construction of a UAS.  But the exception would not apply where the primary purpose of the course is to provide instruction on UAS flight operations.

For recreational operations, all UAS with a maximum take-off weight greater than 250 grams (approximately 9 ounces) must register with the FAA prior to outdoor operation and may register via the FAA’s new online registration system.  Personally owned UAS operated solely for recreational purposes may be registered on the FAA's website at https://www.faa.gov/uas/registration/.

For civil operations, all UAS, regardless of weight, must register with the FAA prior to any outdoor operation.  The Office of Risk Management and Insurance (ORMI) is responsible for the registration of any UAS owned or controlled by Carnegie Mellon that is to be operated outdoors.  To initiate the registration process, please contact drones@andrew.cmu.edu.

In addition to FAA regulations, some state and local governments have passed regulations governing the use of UAS in their jurisdictions.  The Commonwealth of Pennsylvania is currently considering legislation on UAS operations.

The City of Pittsburgh currently prohibits the operation of "motorized model airplanes, drones or any other mechanized or motorized devices" within, above or in the vicinity of any public park in the city. See City of Pittsburgh Code, Title 4, Article XI, Chapter 473.04.

In limited circumstances, some governmental agencies may be authorized by the FAA to issue COAs for UAS operations (e.g. to operate a drone in restricted airspace on a military base).  Please contact drones@andrew.cmu.edu prior to any public / governmental operation.  Even where UAS operation is authorized by a government agency, Carnegie Mellon must still review the operation to confirm appropriate insurance coverage.