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Uncrewed Aerial System Policy

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Section 1 - Purpose and Context

(1) The purpose of this policy is to set out the University's requirements for the use and operation of Uncrewed Aerial Systems (UAS) or drones, to ensure regulatory compliance, including ensuring the health, welfare, privacy and safety of the University staff, students, volunteers, and members of the public.

(2) This policy applies to all activities involving the operation and use of UAS conducted on a University campus, regardless of whether they are operated by University staff, students, volunteers or others, including University controlled entities, contractors and members of the public.

(3) This policy also applies to the operation and use of UAS for the purposes of carrying out University activities (such as research, teaching or marketing) conducted outside a University campus, including internationally.

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Section 2 - Definitions and Interpretation

(4) For the purpose of this policy, definitions that apply can be found in the Policy DDS Glossary, in addition to the following:

  1. CASA means the Australian Civil Aviation Safety Authority, which is an independent statutory body established to regulate civil aircraft operations in Australia and the operation of Australian aircraft outside Australia.
  2. Chief Remote Pilot (CRP) means the approving authority for all UAS flights conducted on University campuses or for the University.
  3. Operator Accreditation means the minimum CASA requirement for operating a UAS for work, issued after completing an online course through the CASA portal.
  4. Pilot means to a person who is approved to pilot a UAS in accordance with the ‘Authorised UAS Pilot’ clauses in Section 4 – Procedures, and who is listed on the University's register of approved UAS Pilots.
  5. Remotely Piloted Aircraft Operators Certificate (ReOC) means an operator’s certificate that must be held by an organisation.
  6. Remote Pilot License (RePL) means the license required to operate a UAS, issued by CASA on completion of UAS training course provided by a CASA approved training school.
  7. Uncrewed Aerial System (UAS) means a remotely piloted aircraft or other air-borne device, also commonly referred to as drones or remotely piloted aircraft (RPA).
  8. University Campus means any premises owned or under the management and control of the University.
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Section 3 - Policy Statement

(5) University UAS operations are conducted under the University's ReOC. Unless they meet the requirements for Education and Research purposes in accordance with part 101.023 of the Civil Aviation Safety Regulations 1998 (CASR).

(6) All operations conducted under part 101.023 of the Civil Aviation Safety Regulations 1998, must have a RePL holder in attendance supervising the operation.

(7) It is the responsibility of the School or Institute to ensure flights conducted under part 101.023 of the Civil Aviation Safety Regulations (CASR) 1998 are not conducted for marketing, promotion or commercial purposes.

(8) The University will maintain a central register of approved flights, pilots and UAS, as required by the ReOC.

(9) The University permits the operation of UAS on University campuses for University activities, subject to compliance with this policy.

(10) The University will grant permission for the operation of UAS outside University campuses for legitimate University activities, including research and fieldwork, subject to compliance with this policy.

(11) UAS operated on-campus and off-campus, including internationally, must be operated in accordance with relevant local laws, regulations, and rules.

(12) The University will meet its statutory requirements under the Privacy and Personal Information Protection Act 1998 (NSW) and the Workplace Surveillance Act 2005 in relation to the capturing of images using UAS, as outlined in the Privacy Policy, Privacy Management Plan and Workplace Surveillance Policy.

(13) The University may, in its absolute discretion, approve recreational use of UAS, or the operation of UAS by third parties on University campuses, in accordance with relevant local laws, regulations and rules.

(14) Any use or operation of UAS except in accordance with this policy is strictly prohibited. Non-compliance with this policy may result in legal or other action by the University.

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Section 4 - Procedures

Responsibilities

(15) Business units and individuals are responsible for complying with this policy.

  1. Staff, students, visitors, and contractors are responsible for:
    1. adhering to this policy for all UAS operations
    2. ensuring they have Operational Accreditation, RePL, or a ReOC for contractors, for the specific type and class of UAS to be flown
    3. ensuring all flights are carried out in accordance with the approved flight authority and CASA regulations, and
    4. seeking clarification from the CRP or Director, Teaching and Research Technical Services if they are unsure about any of the requirements of this policy. 
  2. The University CRP is responsible for:
    1. ensuring all flights are carried out in accordance with: the University ReOC's Operations Manual (Staff login required), Civil Aviation Safety Regulations 1998, Part 101 (Unmanned Aircraft and Rockets) Manual of Standards 2019, and the University's Uncrewed Aerial Systems Policy
    2. maintaining a register of approved University UAS Pilots
    3. maintaining a register of approved University UAS
    4. approving all flights on behalf of the University, and
    5. reporting all relevant incidents to the University’s Work Health, Safety and Wellbeing unit
  3. Campus Safety and Security is responsible for:
    1. reporting all incidents of unauthorised flights to the Work Health, Safety and Wellbeing unit and the CRP for review.

Procurement

(16) All University-owned UAS must be placed on the University's asset register.

(17) All UAS flown for, or on behalf of, the University must be registered and labelled in accordance with CASA regulations. 

Authorised UAS Pilots 

(18) UAS flights are only permitted to be conducted by University-approved UAS pilots.

(19) A person may apply to become a University-approved UAS pilot by submitting the UAS Pilot Registration form via WesternNow.

Operation Approval

(20) Before operations begin, external UAS contractors must meet the compliance requirements of CASA and the University.

(21) University-approved pilots must have received an approved UAS Flight Authority from the CRP through the UAS Management System.

(22) The pilot must have the required documents and safety equipment on hand.

(23) Indoor use of UAS for University activities must be:

  1. approved by the CRP, and
  2. approved by the relevant University space owner, where the UAS is to be operated indoors on a University campus.

(24) For University marketing or promotional purposes conducted on or outside a University campus, the Director, Marketing must be consulted prior to UAS operation approval.

(25) Additional approvals, including human ethics approval or CASA approvals, may also be required, depending on the nature and scope of the activity, and whether the drone is autonomous or remotely piloted.

During and Post-Flight Requirements

(26) All UAS must be operated strictly in accordance with all relevant laws and regulations, and any conditions of approval outlined in this policy.

(27) All flight logs must be uploaded to the UAS Management System or attached to the flight plan at the completion of the operation.

(28) The UAS pilot must report any incident occurring during operation of the UAS in accordance with the University's Accident, Injury, Incident, Hazard Reporting and Investigation Policy and the University's ReOC's Operations Manual (Staff login required).

(29) All data collected must be managed in accordance with the Records and Archives Management Policy.

Insurance

(30) All UAS operated for University activities by University employees or students who are University-approved UAS pilots are covered by University insurances.

(31) All other UAS pilots authorised to operate UAS under this policy must arrange their own insurance at their own expense.

Privacy and Workplace Surveillance

(32) Operation of UAS on University campuses (including on University land or within buildings) may involve the capture of images of individuals. Operators of UAS must comply with the policies, procedures and guidelines to meet the University's legal obligations relating to privacy and workplace surveillance, including the Privacy and Personal Information Protection Act 1998 and Workplace Surveillance Act 2005.

(33) UAS pilots are prohibited from operating UAS to conduct workplace surveillance, or to collect, store or use personal information about individuals (including images) in breach of the University's Privacy Policy and Privacy Management Plan.

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Section 5 - Associated Information 

(34) This policy should be read in conjunction with other relevant laws and University policies, which include, but are not limited to:

  1. Accident, Injury, Incident, Hazard Reporting and Investigation Policy
  2. Civil Aviation Safety Regulations 1998
  3. Emergency Response Guidelines
  4. Hazard Identification, Risk Assessment and Control Procedures
  5. Health Safety and Wellbeing Policy
  6. Part 101 (Unmanned Aircraft and Rockets) Manual of Standards 2019
  7. Privacy and Personal Information Protection Act 1998 (NSW)
  8. Privacy Management Plan
  9. Privacy Policy
  10. Procurement Policy 
  11. Records and Archives Management Policy
  12. Responsible Conduct of Research Procedures - Animal Research Ethics 
  13. Risk Management Policy
  14. Workplace Surveillance Act 2005
  15. Workplace Surveillance Policy