Revised September 30, 2024

A. PURPOSE  

The use of uncrewed aerial vehicles (“UAVs”) and uncrewed submersible vehicles (“USVs”), commonly called “drones,” is a significant tool for University research, service, and extension/outreach in a variety of disciplines. Additionally, aerial photography with UAVs assists in University land and facilities management, athletics, law enforcement, communications, and other support functions.

UAV operational safety – entailing both UAV equipment and the pilots who operate them -- is regulated by the FAA. Both the Department of State (under ITAR) and the Department of Commerce (under EAR) assert export control over various forms of UAV and USV technology. Drones with payload capacity also pose terrorism and security concerns to law enforcement agencies.

As it does with other regulated technologies of scholarly or other operational importance, Michigan State University seeks to permit UAVs and USVs to be utilized productively in a manner that fully meets institutional legal, public safety, and ethical responsibilities. To facilitate that outcome, the University:

• issues this policy to guide the acquisition and operation UAV and USV technology,
• delegates administrative oversight of policy implementation to the Office of the Vice President for Research and Innovation, and
• charges the Office of the Provost and the Office of the Vice President for Research and Innovation to work jointly with the Department of Police and Public Safety, the Office of the General Counsel, Export Control and Trade Sanctions, and other offices to maintain up-to-date policies and procedures for UAV/UAS operations. The Provost will share these polices with academic governance for their information.

B. UAV and USV ACQUISITION

Before proceeding with flight operations, the following steps are required:

1. A determination that UAV/USV data are essential to the research, extension/outreach, or other program.
2. A determination whether there is a need to purchase equipment or if there are other options acquire the desired data. A user should consult first with Remote Sensing & Geographic Information Science Research and Outreach Services (RS&GIS) or other units which have UAV/USV equipment about the availability of using available UAV/USV equipment.
3. If purchase of UAV/USV is justified:
   1. Identify the needs, select the desired equipment, and identify an appropriate funding source.
   2. Contact University Procurement and Logistics (UPL) to request a quote from vendor and to determine if there are restrictions on the vendor/manufacturer proposed for purchase.  UPL will run Restricted Party Screening on vendor before moving forward.
   3. UPL will obtain quotes from approved vendors and ask the vendor for the export classification. UPL will send export classification to Export Control and Trade Sanctions (ECTS) to decide if any management plans are needed for the incoming parts/equipment and to confirm no international shipments of the equipment are made without prior ECTS review.
   4. Once ECTS approves, then UPL will process the purchase.
   5. If the chosen equipment is not approved, select approved equipment, or request a waiver through ECTS. (Strong justification is needed for a waiver.)
   6. All UAV/USV system and system component purchases shall be processed via requisitions through UPL. (PCard purchases are not approved. A waiver will be considered with strong justification.).
   7. Along with approval, other requirements include:
      1. Written documentation that any prerequisite licenses are in-hand or properly in process.
      2. Written documentation that the acquiring unit understands and has a plan for on-going compliance with applicable government and MSU regulatory guidelines.
4. Equipment must be registered with the FAA as soon as delivered and before any flights. The registration ID must be affixed to the drone in accordance with FAA regulations.
5. Once the equipment and necessary approvals are in place, proceed to submit an operating plan as outlined in the next section of this document. 

C. UAV and USV OPERATIONS

1. The operation of a UAV or USV on all lands and in all buildings governed by the Board of Trustees shall require the prior filing of an operating plan with the UAV and USV Operations Review Committee. This plan MUST be approved before any flight operations.
   1. All flights on the East Lansing campus (including lands south of Mt. Hope Road) require notification of MSU Police and the Office of the Vice President for Research and Innovation at least two days prior to flight operations. This requirement must be addressed in all operating plans.
   2. MSU Police use of UAV technology in execution of a search warrant or as part of a tactical response to an immediate threat is always authorized, subject to applicable law and government regulations.
   3. Infrastructure, Planning and Facilities is authorized to work directly with the Department of Police and Public Safety for the approval of routine flights to inspect roofs, building condition, storm damage, and related activities. DPPS may request that IPF submit an operations plan to the UAV and USV Operations Review Committee if it determines that the activities fall outside routine operations.
   4. Use of UAV technology for special events or promotional opportunities (Athletics, student events, television productions, drone light displays, etc.) will be under the purview of MSU Police.  MSU Police may provide a waiver for the specific UAV use without review by the Operations Review Committee. The Committee will review any operating plan for a special event if requested by MSU Police.
2. The operation of an MSU-controlled UAV or USV on lands not governed by the Board of Trustees (including outside the U.S.), shall require the prior filing of an operating plan with, and the formal approval of the plan by, the UAV and USV Operations Review Committee with concurrence of those with oversight of the site where the operation will take place.
3. Operating plans shall include: 
   1. Equipment to be used,
   2. Dates of flights including plan to notify MSU or landowner prior to flight operations,
   3. Locale(s), including the resident or temporary populations therein,
   4. Purpose(s) of the operation,
   5. The identity of pilot(s) or other remote operator(s),
   6. All forms of data (including imagery) to be collected,
   7. Current status of any required licenses or permissions, and
   8. Provisions for security of the equipment, both during and outside of operation, and of any sensitive data collected.
4. For approval of an operating plan by the UAV and USV Operations Review Committee: 
   1. The plan must be forthcoming and complete in its content,
   2. The envisioned operation must comply with applicable laws, government regulations, and other University policies,
   3. The envisioned operation must not pose an unacceptable threat to health, safety, privacy, or the environment, either in an absolute sense or compared to other methods of obtaining the desired information, and
   4. The Committee must judge the envisioned operation to be in the best interest of the public and the University.
5. The UAV and USV Operations Committee will consider proposals for blanket approval from MSU entities that conduct repeated, routine flights for core university functions such as Infrastructure, Planning and Facilities, RS&GIS, and Communications. Research programs that conduct repeated flights with experienced personnel to collect data/images from continuing experiments will also be eligible to request blanket approval.
6. Any property damage or lost UAV must be reported to the FAA following FAA regulations (https://faadronezone-operator.faa.gov/#/part107) along with MSU Police and the Office of the Vice President for Research and Innovation. 
7. The UAV and USV Operations Review Committee will work to accommodate expedited review of operating plans to address unexpected, short-term phenomenon (e.g., flooding, fire, or similar events). 
   1. If the proposer has a history of approved flights the committee will accept an addendum/extension to facilitate immediate action.
   2. If the proposer does not have a history of approved operating plans, the Committee will do its best to perform an expediated review but cannot guarantee an immediate response due to the need to maintain operating and safety standards.
8. Whenever the MSU Police or the UAV and USV Operations Review Committee approves an operating plan, the applicant will be issued written permission for execution of the plan via email. Regardless of the approver, both the MSU Police and the Office of the Vice President for Research and Innovation will receive and retain copies of each permission. 
9. Whenever a UAV or USV governed by this policy is in operation, the pilot or remote operator shall be in physical possession of an approved operations plan and a valid license, as required by law and shall display the permit or waiver upon request from law enforcement or other cognizant authorities. 

D. THE UAV AND USV OVERSIGHT AND REVIEW STRUCTURE

The UAV and USV structure shall include a standing Executive Committee to guideline broad policy for UAV and USV use at MSU and to serve as a resource to the Operations Review Committee. The Operations Review Committee will review operating plans and other matters that govern UAV and USV use by MSU employees, students, collaborators, and contractors consistent with policy set by the Executive Committee. 

The UAV and USV Executive Committee shall consist of:

• the Vice President for Research and Innovation or designee (chair),
• the MSU Police Chief or designee,
• Associate Vice President for Research Regulatory Support, or designee,
• the Director of Export Control and Trade Sanctions,
• the Risk Management and Insurance unit administrator,
• a college dean or other designee appointed by the Provost,
• a representative of the Office of the General Counsel. 

The UAV and USV Operations Review Committee shall consist of:

• an Associate Vice President for Research and Innovation or designee (chair),
• a representative of MSU Department of Police and Public Safety,
• a representative of MSU Remote Sensing and Geographic Information Science Research and Outreach Services,
• a representative of MSU AgBioResearch/south campus agricultural lands,
• a representative of MSU Extension or another off-campus user,
• a non-research user (i.e., IPF, Communications),
• a representative of the Office of Environmental Health and Safety.

Appointments to the Operations Review Committee shall be for three-year terms and are renewable. 

Deliberations of the UAV and USV Operations Review Committee may be informed by, but do not supplant or supersede, other related University policies and review procedures. 

When UAV and USV Operations Review Committee agenda items include issues falling under the purview of other specific MSU units, the Committee chair shall consult with or appropriate representatives to attend meetings in an ex officio capacity. 

E. APPEALS

Decisions of the UAV and USV Operations Review Committee may be appealed to the Committee. If the applicant and Committee cannot reach a resolution the decision may be appealed to the Vice President for Research and Innovation and the Provost, who in consultation with MSU Police, will decide. 

F. UPDATES OF THIS POLICY

This policy should be reviewed at intervals no greater than five years or whenever change is deemed necessary by the Executive or Operations Review Committee. The review will be led by the Office of the Vice President for Research and Innovation.