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Unmanned Aircraft Systems policy

Chapter 7860

Revised January 2022; September 23, 2025

Unmanned aircraft systems (UAS), commonly referred to as "drones," offer opportunities for teaching and research and provide the University community with valuable experiences in a wide range of academic disciplines. Operation of UAS is regulated by the Federal Aviation Administration (FAA) and by federal, state, and local laws. Anyone who seeks to operate UAS on Kansas State University property or at any University-sponsored event must receive approval in advance in accordance with this policy.

Table of Contents

.010 Definitions
.020 Policy Requirements
.025 Procurement and Use Restrictions — Countries of Concern
.030 Procedures for Obtaining UAS Flight Approval
.040 Resources
.050 Contacts

.010 Definitions

"44807 exemption" An FAA exemption under Section 44807 allowing operations not permitted under 14 CFR Part 107.

"Certificate of Authorization (COA)" A certificate granted by the FAA outlining specific conditions for flight; may be issued for public UAS operations or under a 44807 exemption.

"Emergency" An urgent situation where action is taken to promote the safety and security of persons and/or property.

"Invitee" Individuals or entities who visit Kansas State University property by invitation of a faculty or staff member or registered student organization for a University benefit.

"Licensee" Individuals or entities who visit Kansas State University property for their own benefit and are not invited by a faculty or staff member.

"Part 107" The FAA regulation governing operation of small UAS; operators must hold an FAA Remote Pilot certificate.

"Reasonable expectation of privacy" Locations where there is an objective expectation of privacy (e.g., restrooms, locker rooms, residence halls, private offices, health/medical facilities).

"Recreational Aircraft" An unmanned aircraft flown purely for personal enjoyment under 49 U.S.C. 44809 and TRUST requirements.

"University property" Any land, grounds, buildings, or facilities owned, leased, or used by K-State per formal agreements, including University-owned streets, sidewalks, and bike paths.

"University-sponsored event" Any K-State sanctioned, hosted, or controlled event, including academic meetings, athletic events, and promotional gatherings.

"Unmanned aircraft system (UAS)" Any remotely operated or controlled aircraft intended to fly within the National Airspace System or inside of University owned/controlled buildings; includes aircraft and associated elements.

"Countries of Concern" China, Russia, Iran, North Korea, Cuba, and Venezuela; this list may be updated by federal/state authorities or the University to align with applicable law.

"FASC-prohibited unmanned aircraft system" An unmanned aircraft system manufactured or assembled by an American Security Drone Act–covered foreign entity as listed by the Federal Acquisition Security Council and published in SAM (System for Award Management).

"Critical components" Essential parts, systems, or technologies of a UAS necessary for core functions (e.g., flight control, communications, data transmission, navigation, imaging), including the software/firmware that controls these functions. These components may create risks to the confidentiality, integrity, or availability of University data.

"Associated elements" Additional components, accessories, or subsystems that interact with or support operation of a UAS (e.g., batteries/chargers, external sensors/payloads, remote viewing or storage devices, cloud services, APIs). Associated elements may also introduce risks to data confidentiality, integrity, or availability.

.020 Policy Requirements

  1. The Designated Approval Authority (DAA) processes requests for UAS activities consistent with applicable laws and University policy (Direct of Facilities University-wide; UAS Flight Operations Manager for K-State Salina).
  2. All FAA regulations; federal, state, and local laws; and applicable University policies must be followed. UAS operated in violation of law or this policy are subject to grounding.
  3. University-owned UAS will be operated under FAA authorization (Part 107, Section 44807, or COA). Employees should operate University-owned or -leased UAS for University purposes unless otherwise approved with appropriate insurance.
  4. Operation of any UAS on University property or at any University-sponsored event requires prior approval by the DAA; the UAS Advisory Committee (UASAC) provides guidance.
  5. UAS may not be used to monitor or record activities where there is a reasonable expectation of privacy; additional restrictions apply for areas serving minors.
  6. Individuals or organizations operating a UAS in violation of law or policy may be directed to cease operations immediately; violations will be referred to the appropriate University process. Temporary Flight Restrictions (TFRs) and University No Drone Zones may be issued.
  7. KSU Police Department and/or safety response personnel may be exempt from this policy during emergencies consistent with departmental protocols.
  8. Procurement Compliance: All UAS procurements and any acquisition of associated elements or critical components must comply with section .025 of this policy.

.025 Procurement and Use Restrictions — Countries of Concern

To align with federal and state law, Kansas State University prohibits procurement and, where applicable, operation of UAS and associated elements from Countries of Concern. These requirements apply to all University departments, programs, and activities, including federally and state‑funded projects, research, instruction, athletics, marketing and public safety operations.

  1. Federal Requirements
    • FAR 52.240-1 (Nov 2024) implements the American Security Drone Act of 2023 (ASDA) and prohibits: (i) delivering any Federal Acquisition Security Council (FASC)‑prohibited UAS; and, on or after December 22, 2025, (ii) operating a FASC‑prohibited UAS in performance of a contract; and (iii) using Federal funds to procure or operate a FASC‑prohibited UAS.
    • A FASC‑prohibited UAS is one manufactured or assembled by an ASDA‑covered foreign entity.
    • Section 889 of the FY2019 NDAA (FAR 52.204‑25) prohibits contracting for, and contracting with entities that use, certain covered telecommunications and video‑surveillance equipment and services (e.g., Huawei, ZTE, Hytera, Hikvision, Dahua). While Section 889 does not itself list DJI, agencies may restrict DJI and similar UAS vendors under other authorities (e.g., ASDA/FAR 52.240‑1) and program‑specific guidance; units must ensure UAS ecosystems (aircraft, cameras, radios, links, cloud) do not incorporate Section 889‑covered components.
  1. State Requirements (Kansas House Sub. for SB 9, 2025)
    • Effective July 1, 2025, Kansas governmental agencies (including state universities) are prohibited from purchasing or acquiring drones, or related services, maintenance agreements, or equipment, whose critical components were produced in a Country of Concern or produced/owned by any foreign principal from a Country of Concern.
    • Existing equipment acquired prior to July 1, 2025 may continue to be used and maintained with previously acquired replacement parts. Replacement of critical components may use parts acquired prior to July 1, 2027; acquisition of new foreign‑principal components is prohibited unless conditions specified by state authorities are met.
  1. University Prohibitions (applies regardless of funding source)
    • Kansas State University prohibits procurement or operation of any UAS, and associated elements, that are manufactured or assembled by entities based in Countries of Concern, or that contain critical components manufactured in Countries of Concern, unless an approved exception applies (see subsection E).
    • This prohibition applies to both newly acquired and existing systems when used with federal funds on or after December 22, 2025, and to all state‑funded procurements as of July 1, 2025.
  1. Due Diligence and Documentation
    • Prior to purchase, units must document vendor attestations and screening of manufacturers and critical components against ASDA‑covered entity list and any University‑maintained list of Countries of Concern vendors/components.
    • Purchase requests must include a bill of materials or equivalently detailed statement identifying origin of critical components where feasible.
    • For research projects, consult Export Controls prior to purchase, design, modification, or operation of UAS or components.
  1. Exceptions and Waivers
    • Federal: Exceptions require written approval by the DAA in consultation with Procurement, Export Controls, the Office of the AVPR (ORICS), the Office of General Counsel, and—where federal funds are involved—an agency exemption/exception/waiver expressly stated in the contract (per FAR 52.240‑1).
    • State: House Sub. for SB 9 provides continued use of existing equipment and replacement with parts acquired prior to July 1, 2027. It does not establish a general waiver for new purchases by governmental agencies; the University will follow any implementing guidance or exception criteria issued by the Adjutant General or other state authorities. Absent such state guidance, new purchases that would violate SB 9 are not permitted.
  1. Enforcement
    • Non‑compliance may result in suspension of purchasing privileges, removal from approved operator lists, corrective/disciplinary action up to and including termination, and reporting to federal/state authorities as required.
    • Non‑compliant equipment may be sequestered or disabled until brought into compliance or decommissioned.
  1. Transition and Remediation
    • Inventory Review: Units maintaining UAS must inventory platforms, controllers, batteries/chargers, cameras/gimbals, radios, data links, and software/firmware to identify any components from Countries of Concern.
    • Mitigation Plans: For any affected equipment, develop a mitigation or replacement plan. Use of federal funds with affected equipment after December 22, 2025 is prohibited absent an express waiver.
    • Data Security: For any legacy systems permitted for limited use, ensure offline operation where practicable and disable cloud sync, remote diagnostics, and telemetry to foreign servers.

.030 Procedures for Obtaining UAS Flight Approval

Individuals or organizations seeking to operate a UAS on University property or at a University‑sponsored event must submit a completed UAS Request Form to the DAA at least two weeks in advance (three weeks for licensees). Approvals must be carried on‑person during operations. Export Controls consultation is required where indicated in .020 and .025.

  1. Include: (i) Remote Pilot or TRUST certificate; (ii) any COA or 44807 documentation; (iii) insurance meeting minimums; and (iv) vendor hold‑harmless and additional insured requirements for vendors/invitees.
  2. Public UAS operations requiring a COA waiver should coordinate with the Applied Aviation Research Center (AARC); allow 120 days for FAA processing.
  3. Recreational/model aircraft on University property must be approved through the same DAA process and should meet .030.5 insurance recommendations.

.040 Resources

.050 Contacts

  • Designated Approval Authority — Director of Facilities Customer Service (University-wide, excluding K-State Salina)
  • K-State Salina — UAS Flight Operations Manager
  • Export Controls Compliance Officer
  • Applied Aviation Research Center (AARC) — coordination for COAs