Drones at Williams

Williams UAS (Unmanned Aircraft Systems) Policy is designed to help the Williams community balance the needs of research, teaching, administration, and recreation with requirements of the Federal Aviation Administration, as well as other commonsense privacy and safety considerations.

  • The operation of Unmanned Aerial Systems (UAS) and Model Aircraft, more commonly known as Drones, is regulated by the Federal Aviation Administration (FAA) and relevant state laws and local ordinances. Williams College has established this policy to remind the College community of the need to comply with these legal obligations and to reduce the possibility of risk to the safety and privacy of the Williams community and its neighbors. 

    • Permission to operate Unmanned Aerial Systems (UAS) for all uses is conditional. Williams College employees, students and third party guests must comply with relevant federal, state, and local laws and regulations pertaining to the operation of UAS. UAS and UAS operators must comply with the additional requirements of this policy and other relevant Williams College policies. 

      It is recognized that the risks associated with UAS operations generally increase with aircraft weight, speed and sensitivity of surrounding conditions. Some UAS operations may therefore require additional safety measures, insurance coverage, may only be conducted by third parties with suitable qualifications, equipment, and insurance, or may be prohibited altogether.

    • This policy applies to: 

      • Williams College employees and students operating unmanned aerial systems (UAS) in any location as part of College-related activities; 
      • Any person operating a UAS on or above Williams College property; 
      • Any person hiring or arranging for any UAS services on behalf of the College or one of its offices, departments, or programs. 

      Unmanned Aerial Systems (UAS) include all remote-controlled, autonomous, and directly controlled airborne or flight-capable objects. FAA Small Unmanned Aircraft Rule (Part 107)

      The following are considered UAS:

      • Drones (aerial)
      • Unmanned Aerial Vehicles (UAV)
      • Unmanned Aircraft Systems
      • Small Airborne Objects (SAO)
      • Remote controlled model aircraft (e.g. airplanes, helicopters, etc.). 

      The following are not considered UAS:

      • Manned aircraft explicitly governed by FAA FAR and Part 103
      • Lighter-than-air craft and rocket vehicles that have distinct licensing, weight and altitude restrictions governed by FAA Part 101
      • Propelled athletic objects (javelins, shot-puts, golf balls, etc.).  
      • Other common unmanned and un-motorized aerial objects (frisbees, kites, gliders, etc.).
    • Per FAA Small Unmanned Aircraft Rule (Part 107), there are only two allowable uses of UAS at Williams College:

      Commercial Use (a.k.a. College-related activities)

      Commercial use is any FAA qualifying use, including any use that benefits, is performed in the service of, or is compensated by Williams College. 

      • Commercial use includes but is not limited to teaching, research, and administrative uses. Williams College faculty or staff, or students working for College faculty or staff, using UAS in pursuit of professional or academic responsibilities is considered Commercial use. 
      • Williams College employees operating UAS as part of College-related activities and following this policy are covered by Williams general liability insurance.
      • Any UAS flown by a third party on behalf of the College (i.e. licensed pilot contracted or sponsored by a College employee) is also considered Commercial use, as are any UAS flights performed in the commercial interest of other businesses or individuals on College property. 
      • Any UAS use that does not fall under Commercial use must adhere to the FAA requirements for Recreational use.  

      Recreational Use (a.k.a. Hobbyist)

      Recreational use is any FAA qualifying use, including any UAS use that does not benefit or perform a service of, and is not compensated by Williams College. 

      • In addition to the requirements of this policy, Recreational use should be governed by membership with a community-based organization (e.g. Academy of Model Aeronautics).
      • Any UAS use that does not fall under Recreational use must adhere to the FAA requirements for Commercial use.
    • Williams College UAS policy is written to remind the College community of the need to comply with FAA regulations, and also to ensure the safety and privacy of the Williams community and neighboring areas. 

      Safety

      All aircraft operate in opposition to gravity and environmental conditions. In addition, conditions in the air or on the ground may change moment to moment. In the event of mechanical failure, adverse weather, or operator error, even the smallest UAS could be dangerous to persons or property on the ground if that UAS is free falling from a given altitude (E = mgh, or effectively F = ma). UAS operators are to take all precautions to prevent or mitigate risks to safety during UAS operation. 

      All airspace is regulated by the FAA and designated by Airspace Class. Generally, airspace is shared by a variety of aircraft and great effort is taken by both pilots and air traffic controllers to avoid the possibility of collision. UAS operators must do the same, and further must yield to all other aircraft without hesitation or exception - under no circumstances does a Commercial or Recreational UAS have right-of-way with regard to other aircraft. Similarly, UAS must not interfere with or distract the operation of ground-based vehicles, machinery, or facilities.

      Privacy

      UAS are capable of hosting technology that does not directly support flight operation. This includes technology capable of surveilling a range of area surrounding the UAS (e.g. imaging cameras, detection and ranging systems, etc.). UAS operators should assume a right to privacy for any person or property from whom permission has not been expressly granted.

    • Guests of Williams College (visiting speakers, students from other schools, etc.) or other third parties (contractors, consultants, etc.) wishing to operate UAS on College property must be sponsored by an employee of the College and must follow this policy. Williams College employees include faculty and staff, but exclude student employees.

      1. Williams College employees and students operating unmanned aerial systems (UAS) in any location as part of College-related activities must comply with this policy.  
      2. Any member of the College community seeking to operate a UAS on College property is personally responsible for complying with FAA regulations, state and federal laws, and with all requirements and procedures encompassed by this policy. This includes but is not limited to the FAA Small Unmanned Aircraft Rule (Part 107)
      3. UAS operators must comply with all other relevant College policies. 
      4. All UAS uses compensated by Williams College (e.g. teaching, research, or administration) or that otherwise benefit Williams College are considered Commercial use.
      5. All flights for Commercial use must be piloted by someone with FAA Remote Pilot Certification.
      6. Only Williams faculty, staff, students, or those with a College sponsor may operate UAS on College property.
      7. All purchases of UAS using College funds must be reviewed by the UAS Operations Group prior to purchase. 
      8. College-owned UAS must only be used for teaching, research, and administration (Commercial Use), and cannot be used for Recreational flying.
      1. Williams College employees operating UAS as part of College-related activities and in compliance with this policy are covered by Williams general liability insurance. Failure to comply with this policy may void an operator’s insurance coverage. 
      2. Recreational use (hobbyist) requires proof of individual liability insurance of no less than $1M for UAS operations (individuals may purchase coverage through the Academy of Model Aeronautics or another entity).
      3. Third parties sponsored by Williams College employees must carry their own Commercial liability insurance (CLI) or personal liability insurance (PLI).
    • Registration is required for all UAS operated on College property, and for UAS pilots flying commercially (see the Procedures section for more information).

      1. Every UAS operated on College property must be registered with the College. 
        1. All UAS weighing more than 0.55 lbs must first be registered with the FAA
        2. All UAS operated for Recreational Use must weigh less than 5.0 lbs. 
        3. UAS operated for Commercial Use must weigh less than 55.0 lbs. 
        4. UAS must not be modified from the original manufacturer’s condition (custom UAS or UAS peripherals must receive written approval from the UAS Operations Group). 
        5. Third party UAS must be registered by a Williams College employee. 
        6. UAS registrations expire upon the earliest of:
          1. Two years after registration; 
          2. When FAA UAS registration expires, if applicable; 
          3. When an operator’s relationship to the College changes. 
      2. Commercial UAS operators must be registered with the College with proof of FAA Remote Pilot Certification in good standing (see the Allowable Uses section for more information). Recreational UAS operators are not required to register (but must still register their UAS with the College and provide proof of sufficient liability insurance).
        1. The FAA requires operators to carry their FAA Remote Pilot Certification on their person during Commercial operations.
        2. Third party Commercial UAS operators must be registered by a Williams College sponsor (see the Sponsorship section for more information).
        3. Commercial operator registrations expire: 
          1. After two years; 
          2. When FAA Remote Pilot Certification expires; 
          3. When an operator’s relationship to the College changes. 
      3. UAS Customization
        1. Drones, controllers, and drone accessories manufactured by a company have passed regulatory requirements for performance and safety. Any modification of a company's drone or controller, fabrication of parts/components (machined, 3D printed, etc.), or assembly of operational parts/components sold separately is considered a customization.
        2. Any customization, in whole or in part, must receive written approval from the UAS Operations Group prior to UAS registration with the College. A copy of this written approval must be provided to Campus Safety & Security for verification as part of the UAS registration process.
        3. Customized UAS weighing greater than 0.55 lbs must be registered with the FAA prior to and as a prerequisite for Williams registration.
      1. UAS may only be operated in Williams designated fly zones under appropriate conditions. 
      2. Operators who are registered with the College may operate UAS in the designated fly zones appropriate to Commercial or Recreational use. 
        1. Williams employees registered with the College as Commercial UAS operators holding FAA certification may directly supervise students operating UAS in designated fly zones only. 
        2. Flights within designated fly zones are further restricted to areas that are unoccupied or nearly unoccupied at the time of the UAS operation. 
        3. Without an exception waiver to this policy, UAS operation should not occur: 
          1. Above people (e.g. passers-by, sporting events, tours, concerts, graduation, etc.). 
          2. Near other persons operating equipment (i.e. cause a distraction near roads, parking lots, construction sites, etc). 
          3. In areas conventionally considered private. 
          4. Within 25 feet of residence halls (dorms). 
          5. Within 25 feet of private properties abutting Williams properties. 
        4. A UAS should never enter onto, overfly, survey, or create a nuisance on any private property abutting College property, unless advanced written permission from the private property owner is received by the College. 
      3. Designated fly zones are depicted on the Williams Designated Fly Zones Map. The designated fly zones are: 
        1. Zone 1
          1. Commercial and Recreational uses allowed.
          2. Area defined near Cole Field House / Poker Flats, 25ft from structures, roads and abutting properties. 
          3. Refer to the Drones at Williams course for more information about the conditions for operating a UAS in this location.
        2. Zone 2
          1. Commercial use only allowed.
          2. Area defined near Hopkins Memorial Forest, 25ft from structures, roads and abutting properties. 
          3. Refer to the Drones at Williams course for more information about the conditions for operating a UAS in this location.
      1. Williams College property exists within US air space and, in addition to this policy, is governed by the Federal Aviation Administration (FAA). This policy also applies to certain UAS operations outside of Williams College property where other governing laws, regulations, or policies may also apply. All UAS operators are required to be familiar with and maintain compliance with all laws, regulations, and policies relevant to the jurisdiction within which the operation occurs.
      2. All aspects of FAA Small Unmanned Aircraft Rule (Part 107) apply and are incorporated into this policy.
        1. This includes but is not limited to the rules governing:
          1. § 107.25 – Operation from a Moving Vehicle or Aircraft
          2. § 107.29 – Daylight Operations
          3. § 107.31 – Visual Line of Sight Aircraft Operation
          4. § 107.33 – Visual Observer
          5. § 107.35 – Operation of Multiple Small UAS
          6. § 107.37(a) – Yielding Right of Way
          7. § 107.39 – Operation Over People
          8. § 107.51 – Operating limitations for Small Unmanned Aircraft
        2. Any intention to violate Part 107 rules may require that an FAA waiver first be obtained for each rule violation specified (see the Exception Waivers section for more information).
      3. Campus Safety & Security (CSS) must be notified prior to all UAS operations on Williams property.
        1. Notification must include information about the pilot, observer, flight location/area, flight start/end times, and drone registration ID.
        2. Receipt of notification by CSS does not constitute approval for a flight under any circumstances. Flight approval is implicit with pilot compliance with this policy or explicit with pilot compliance with the conditions set in a written approval for a policy exception.
      4. UAS operators must maintain visual line of sight (VLOS) of the UAS during operation.
        1. This means operation without obstruction or distraction, and during daylight hours and good weather.
        2. UAS orientation, altitude, and speed must be monitored throughout operation.
        3. An operator may only have one UAS in flight at a time.
      5. UAS operation by virtual means is prohibited on Williams property (e.g. pilot operating via UAS mounted video, VR headset, etc.). 
      6. All UAS operations on Williams property (Commercial and Recreational) require the presence of at least one person in addition to a pilot to act as an observer for the pilot.
        1. An observer is responsible for monitoring and keeping UAS operators informed of environmental changes in the airspace and on the ground, including but not limited to:
          1. Approaching aircraft, vehicles, persons, or wildlife.
          2. Imminent changes to weather conditions. 
          3. Proximity to persons, structures, or hazards.
          4. Other objects or conditions the UAS should avoid. 
        2. A UAS operator (pilot) cannot also simultaneously be an observer (the operator must maintain line of sight on the UAS, and the observer must monitor the surrounding area). 
        3. UAS pilots and observers must maintain constant communication with each other (pilots notify observers of changes to or intentions to change operation, and observers notify pilots of changes to surrounding conditions). 
      7. Under the direct supervision of a Williams registered UAS operator (pilot), other non-licensed persons may operate a UAS if:
        1. The non-licensed person has demonstrated comprehension of FAA regulations, Williams UAS Policy, and the specific operational requirements of the UAS. 
        2. While operating the UAS, the non-licensed person immediately complies with all directives of the UAS pilot and/or observer. 
        3. The UAS pilot is always ready and able to immediately assume control of the UAS. 
      8. No UAS may be operated at speeds in excess of 25 mph. 
      9. To mitigate the possibility of collision, all UAS operations must yield to other larger aircraft without hesitation or exception. 
        1. Upon detection of other aircraft, a UAS should be moved to a location and altitude that will not distract or interfere with the other aircraft. 
        2. If necessary, the UAS should be grounded until the other aircraft has left the airspace.
      1. Only Williams College employees may sponsor a third party (guest) of the College. Students, spouses/partners, alumni, and emeriti must seek the sponsorship of Williams College employees on behalf of a third party. 
      2. As a representative of the College, the sponsor assumes responsibility for ensuring third party adherence to this policy for UAS operations on College property, and that the third party is properly licensed and insured.
      3. Sponsors must act on behalf of a third party or guest to ensure that a third party’s UAS is registered with the College or to register the third party itself as a UAS pilot with the College.
      4. Prior to any College employee providing a College-owned UAS to a third party for any purpose, regardless if a fee is charged, approval must be received from the UAS Operations Group
      5. Contracts with third parties must:
        1. Stipulate compliance with all FAA regulations, Williams College policies, and other applicable laws.
        2. Provide proof of FAA Remote Pilot Certification and FAA UAS registration, as applicable. 
        3. Provide proof of Commercial liability insurance.
      1. Williams College employees and students may petition the UAS Oversight Group for exception waivers to Williams UAS policy. 
      2. Williams exception waivers do not affect or change Williams UAS policy itself, and are only applicable to the specific parties, uses, and conditions granted by the exception waiver. 
      3. Williams exception waivers do not supersede or substitute for FAA or airport administrator waivers. 
      4. As applicable, proof of FAA or airport administrator waivers may be required prior to the College's consideration of an exception to Williams UAS policy.
      5. Receipt of an FAA or an airport administrator waiver may be a prerequisite for, but does not supersede or guarantee the receipt of, a Williams exception waiver
      6. To ensure safety and privacy, exception waivers may have additional conditions set by the UAS Oversight Group (e.g. period limitations, mitigation procedures, notification requirements, etc.).
      1. The UAS Registration Group has the right to deny registration to any operator or UAS for use on Williams College property or in affiliation with Williams College. 
      2. Williams employees and students who feel they have been unfairly denied registration have the right to appeal the decision to the UAS Operations Group. 
      3. The UAS Oversight Group has the right to deny approval for a Williams UAS Policy exception. 
      4. Williams employees and students who feel they have been unfairly denied approval for a policy exception have the right to appeal the decision to the Chair of the Risk Management and Compliance Committee.
      1. Any violations of College policies by an individual will be dealt with in accordance with applicable College policies and procedures, which may include revocation of privileges, confiscation, or disciplinary actions up to and including termination from the College or expulsion, as applicable.
      2. The College may prohibit access to College properties or resources and may pursue legal action against third parties that operate UAS in violation of this policy.
      3. Fines or liabilities incurred by persons who fail to comply with this policy will be the responsibility of those persons and will not be paid by Williams College.
      1. Submit the Drone or Drone Pilot Registration form (you must login using your Williams user name and password).
        • Registrants must sign an acknowledgement that they have read, understood, and will comply with Williams UAS Policy.
      2. Once the form is submitted, UAS owners (or Williams employees sponsoring a UAS owner) must bring the following to the UAS Registration Group (Campus Safety & Security, in the basement of Hopkins Hall): 
        • Registrant’s Williams ID card.
        • The UAS. 
        • For UAS weighing more than 0.55 lbs, proof of UAS registration with the FAA is required
        • A copy of the manual or printout of the specifications from the manufacturer's website. 
        • A copy of written approval from the UAS Operations Group for drone customization, if applicable.
        • For Hobbyists, proof of third-party liability insurance with coverage of no less than $1,000,000 US.
        • Sponsors must also:
          • perform the procedures outlined in the Sponsor a Third Party or Guest section.
          • provide current and accurate contact information of the third party UAS owner.
      3. If the requirements above are met and in compliance with this policy, then the UAS Registration Group will issue a unique UAS ID tag. The tag must be applied to and remain on the UAS.
      1. Submit the Drone or Drone Pilot Registration form (you must login using your Williams user name and password).
        • Registrants must sign an acknowledgement that they have read, understood, and will comply with Williams UAS Policy.
      2. Once the form is submitted, Commercial UAS operators (or Williams employees sponsoring a Commercial UAS operator) must bring the following to the UAS Registration Group (Campus Safety & Security, in the basement of Hopkins Hall):
        • Registrant’s Williams ID card.
        • Proof of FAA Remote Pilot Certification
        • Sponsors must also :
          • perform the procedures outlined in the Sponsor a Third Party or Guest section.
          • provide current and accurate contact information of the third party UAS operator.
          • provide proof of third party Commercial liability insurance.
      3. If the requirements above are met and in compliance with this policy, then the UAS Registration Group will record the pilot's information and authorize them to fly on Williams property.
    • Any UAS customization, in whole or in part, must receive written approval from the UAS Operations Group prior to UAS registration with the College. A copy of this written approval must be provided to Campus Safety & Security for verification as part of the UAS registration process.

      To begin the customization review process please refer to the Consultation section and submit a Consultation Request form.

    • Prior to any UAS operation on Williams property, Campus Safety & Security (CSS) must be notified.

      1. Notify CSS by phone (on-campus x4444 / off-campus 413-597-4444)
      2. Provide CSS with the following information:
        • Williams registered UAS ID number
        • Pilot, full name
        • Observer, full name
        • Location or area of flight
        • Flight start/end times

      Detailed UAS operations procedures may be found in the Drones at Williams course.

    • UAS procured using Williams College funds shall be owned by the College, and therefore are for Commercial Use only (i.e. as part of College-related activities). Procurement must undergo review by the UAS Operations Group to ensure that the UAS will:

      • meet the needs of the requester.
      • meet the requirements of Williams UAS Policy.
      • have reasonable warranty or technical support from the maker.
      • be supportable by Williams faculty, students, or staff.

      To begin the review process please refer to the Consultation section and submit a Consultation Request form.

    • To petition for a Williams UAS Policy exception waiver, the petition may be submitted to the UAS Operations Group.

      1. Submit a UAS Policy Exception form (you must login using your Williams user name and password)
      2. The UAS Operations Group will:
        1. Consult and support the petitioner.
        2. Refine the petition to address any conflicts or concerns.
        3. Submit the petition to the UAS Oversight Group for consideration.
      3. The UAS Oversight Group will:
        1. Consider the petition.
        2. Coordinate with various committees, subject matter experts and stakeholders as needed.
        3. Issue a decision:
          1. Grant the policy exception waiver, and apply additional conditions and/or set a waiver expiration period as appropriate.
          2. Deny the policy exception waiver until noted concerns can be addressed by the requester, the UAS Operations Group, or changes that alleviate other prohibitive factors.
  • The administration of UAS at Williams College falls to three groups each with distinct roles and responsibilities.

    • Role

      Provision of UAS and UAS operator registration for Williams College. 

      Responsibilities

      • Registration of UAS.
        • Inspection and verification that the UAS meets the requirements of Williams UAS Policy. 
        • Issuance of UAS Registration IDs.
      • Registration of UAS operators.
        • Inspection and verification that the UAS operator qualifications meet the requirements of Williams UAS Policy.
        • Recording of UAS pilot credentials and certifications. 
      • Record and track the registration of UAS and UAS pilots at Williams. 
      • Respond to and document violations of Williams UAS Policy.
      • Submit recommendations to the UAS Oversight Group as needed.

      Members

      • Director of Campus Safety and Security
      • Campus Safety & Security Officers (as assigned)
    • Role

      Provision of reliable support of UAS operations at Williams College. 

      Responsibilities

      • Educate Williams’ community through information resources, training workshops, and curricular or administrative partnerships.
      • Consult on FAA and Williams policy regarding UAS usage and procurement.
      • Consult on FAA and Williams UAS policy exception requests. 
      • Monitor registration of UAS and UAS pilots/owners at Williams College.
      • Liaise with all registered UAS pilots/owners of Williams College.
      • Liaise with airports, municipalities, and other entities surrounding Williams College. 
      • Manage UAS product inventory for Commercial purposes (i.e. as part of College-related activities).
      • Regulate custom UAS or UAS peripherals.
      • Provide UAS piloting services for Commercial purposes (i.e. as part of College-related activities). 
      • Submit recommendations to UAS Oversight Group as needed.

      Members

      • OIT Director of Instructional Technology
      • Science Center Instrumentation Engineer
      • OIT Instructional Technology Specialist
      • Campus Safety & Security Officer
    • Role

      Oversight of UAS policy and needs at Williams College. Oversight of the UAS Operations Group and UAS Registration Group. 

      Responsibilities

      • Review of requests for policy exceptions, funding, or other needs not handled by the UAS Operations Group.
      • Coordinate with various committees, subject matter experts and stakeholders as needed.
      • Issue policy exception waivers or policy changes as needed.
      • Issue directives to UAS Registration Group as needed.
      • Issue directives to UAS Operations Group as needed.

      Members

      • Associate Vice President for Finance
      • CIO of the College
      • Director of Campus Safety and Security
      • OIT Director of Instructional Technology (ex officio)
      • Science Center Instrumentation Engineer (ex officio)
      • OIT Instructional Technology Specialist (ex officio)