Checklist for Granting an Exception for Commercial

Unmanned Aircraft System (UAS/Drone) Use

Effective Date: August 29, 2016

This checklist is designed to provide a tool to facilitate the required risk/benefit analysis pursuant to Campus policy before a commercial drone operation can take place over the Downtown Denver or Anschutz Medical Campus, or the South Denver location. Ultimate approval for any drone flight over CU Denver | Anschutz property lies with the Senior Vice Chancellor for Administration and Finance. Any flight that takes place without administrative approval will be deemed a violation of federal regulation and Campus policy, and those conducting the flight will be subject to sanctions at the discretion of Campus officials and will be promptly reported to Campus or local law enforcement, and the Federal Aviation Administration (FAA) Regional Operation Center.

Preliminary Inquiry:

(1)   Is the use of the UAS necessary or crucial to further the mission of the Campus? 

(2)   Are there no viable alternatives to using the UAS to achieve the stated goal or purpose? 

(3)   Has the Campus, or in some cases, System Administration, requested an outside company or internal party to perform commercial flight services? 

(4)   What Campus School/College/Department is involved and/or sponsoring the drone operation?  

(5)   Who owns the drone and who will be operating and insuring the drone?  

Before the Senior Vice Chancellor for Administration and Finance can determine whether or not the flight warrants an exemption, the following documentation will be required to be uploaded in your EMS request before an official waiver can be considered:

An FAA-Issued permanent Remote Pilot Certificate

Proof of Registration of the UAS with the FAA

Documentation that the aircraft is under 55 lbs

A UAS Flight Plan, which meets all required FAA Criteria:

• Flown in Class G Airspace
• Must be flown in visual line-of-sight
• Must fly under 400 feet
• Must fly during the day
• Must fly at or below 100 mph
• Must yield right of way to manned aircraft
• Must NOT fly over people
• Must NOT fly from a moving vehicle

If the answer to either question 1 or 2 is “no”, an exception will not be granted. Pursuant to Campus policy, there must be a compelling circumstance to grant a waiver to the prohibition on drone flights over campus property. 

If an internal department is requesting the use of a drone for commercial purposes, there are two routes for providing documentation for campus approval:

(1)   The option outlined above for small UAS operations under 14 CFR Part 107; OR

(2)   Obtain a blanket public Certificate of Waiver or Authorization (COA) from the FAA. A COA for public aircraft permits nationwide flights in Class G airspace at or below 400 feet, self-certification of the UAS pilot, and the option to obtain emergency COAs (e-COAs) under special circumstances. Special COAs must be approved by the FAA, and the requestor must contact 9-AJV-115-USACOA@faa.gov for more information. A COA application takes approximately 60 days to process.

Additionally, the drone owner/operator will need to provide proof of liability insurance sufficient to meet the requirements of the Campus. Please contact University Risk Management for more information.

Once the campus authorities have received all of the required documentation outlined in this document, the campus must be made aware of the proposed date, time, and exact flight plan of the UAS. If any documentation is incomplete, missing, or inadequate, or the proposed flight plan is deemed to be a risk to the campus community, the campus reserves the right to deny the UAS operation. Drone flights must be coordinated with each hospital and many offices on campus.  As such, the review process may TAKE UP TO 4 WEEKS TO BE APPROVED AND AS SUCH SHOULD BE PLANNED OUT AND REQUESTED WELL IN ADVANCE.  A review does not guarantee approval.

If your flight is approved, the Campus will issue a physical permit for all approved flights, which the flight operator must carry with them at all times during flight operation.  The drone operator, university sponsor and someone from the each of the hospital flight decks should be in constant communications at all times during the approved flight - WITHOUT EXCEPTION.