Minnesota Department of Transportation

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MnDOT Policies

Unmanned Aircraft Systems (UAS)

MnDOT Policy #OE006
Revised: January 29, 2025

View/print signed policy (PDF)

Office of Aeronautics sUAS Operations Manual

Please go to the MnDOT Org Chart to find specific contact information: Org Chart.

Responsible Senior Officer: Deputy Commissioner/Chief Engineer
Policy Owner: Director, Office of Aeronautics
Policy Contact: Airport Operations Director, Office of Aeronautics

Policy statement

The Minnesota Department of Transportation (MnDOT) allows the use of an Unmanned Aircraft System (UAS) for MnDOT business purposes. The MnDOT Unmanned Aircraft Systems policy applies to operations by MnDOT employees and by third parties working on behalf of MnDOT. 

UAS operators must be licensed as required by Minnesota Statutes §360.018 and must comply with applicable federal requirements. MnDOT-owned UAS and UAS owned by third parties must registered as required by Minnesota Statutes §§360.511 - 360.67 and either 14 CFR §47 or 14 CFR §48. Aircraft must be insured as required by Minnesota Statutes §360.59. 

MnDOT Employees

MnDOT employees may not use personally owned UAS for MnDOT business purposes.

For UAS operation, MnDOT employees must:

  • comply with the MnDOT Office of Aeronautics sUAS Operations Manual and any district- or office-specific supplements;
  • in the event of an emergency, comply with the MnDOT Office of Aeronautics sUAS Operations Manual - Emergency Operations Section;
  • adhere to federal, state, and local laws regarding the use of UAS;
  • coordinate with the appropriate Tribal Nation before working within Indian Country; and
  • inform the Office of Aeronautics before any UAS purchase.

Third Parties

For UAS operation, third parties working on behalf of MnDOT must:

  • comply with the MnDOT Office of Aeronautics sUAS Operations Manual and any district- or office-specific supplements;
  • in the event of an emergency, comply with the MnDOT Office of Aeronautics sUAS Operations Manual - Emergency Operations Section;
  • adhere to federal, state, and local laws regarding the use of UAS;
  • coordinate with the appropriate Tribal Nation before working within Indian Country;
  • be licensed and registered as a commercial operation with the MnDOT Office of Aeronautics;
  • carry insurance as required by Minnesota Statutes §360.59;
  • provide the Office of Aeronautics with a detailed flight plan and risk assessment that addresses all aspects of the intended mission for approval prior to operations; and
  • prior to each operation, be approved by MnDOT Aeronautics as a third-party drone operator. At the discretion of the Office of Aeronautics, a blanket authorization as a third-party drone operator may be issued to a third party who has demonstrated the ability to conduct safe flights and compliance with MnDOT sUAS Operations Manual. This does not waive the need to provide a detailed flight plan and risk assessment prior to each mission.

Reason for policy

The Federal Aviation Administration and Minnesota Statutes and Administrative Rules provide the requirements for licensure, registration, and operation of Unmanned Aircraft Systems.

This policy:

  • ensures a standardized approach to UAS operations across MnDOT;
  • provides clear and concise information on the UAS application, purchase, and operation procedures;
  • identifies roles and responsibilities; and
  • ensures compliance with federal, state, and local laws, rules, regulations, and ordinances.

Applicability

All MnDOT employees and third parties working on behalf of MnDOT must comply with this policy.

Key stakeholders with responsibilities under this policy include:

  • Office of Aeronautics
  • Office of Communications and Public Engagement/District Public Affairs Coordinators
  • Districts and Offices
  • Employees and Third Parties operating Unmanned Aircraft Systems (Pilots)

Definitions

Flight (UAS Flight)

An individual operation of an Unmanned Aircraft System from takeoff to landing.

Note: Each flight must have defined parameters for area of operation, altitudes, flight path and length of flight.

Indian Country

As defined in 18 United States Code section 1151, Indian country includes reservations, allotments, and dependent Indian communities. Indian country may include off-reservation land.

Note: See the Indian Country Guidance and the MnDOT Tribal Map Application for additional information.

Mission (UAS Mission)

The specific details and justification for the particular use of a particular unmanned aircraft.

Examples of missions include bridge inspections, aerial photography, salt pile measurements, etc.

Operation (UAS Operation)

A specific task with a specific purpose, timeframe, and defined location.

Note: An operation may require multiple flights to complete.

Pilot (UAS Pilot)

The designated operator of an Unmanned Aircraft System.

Note: UAS pilots must meet the FAA requirements for the type of operation they are conducting. Pilots flying under 14 CFR §107 must be certificated as remote pilots with a small UAS rating. If the operation is being conducted under a Certificate of Authorization (COA), then the pilot additionally must meet the requirements as required by the COA. All MnDOT staff piloting small UAS are required to have a remote pilot certificate with small UAS rating issued by the FAA. Additional training will be required to comply with a COA or Operations Manual.

Unmanned Aircraft Vehicle (UAV)

The flying portion of an Unmanned Aircraft System (UAS), flown by a qualified pilot via a ground control system, or autonomously through use of an on-board computer, communication links and any additional equipment that is necessary for the UAV to operate safely.

Note: The use of the term “unmanned” is not intended to be exclusive. It is the terminology used in federal regulations to describe remotely operated aircraft.

Unmanned Aircraft System (UAS)

An Unmanned Aircraft Vehicle (UAV) and all the associated support equipment, control station, data links, telemetry, communications and navigation equipment necessary to operate the aircraft.

Responsibilities

Office of Aeronautics

  • Review and approve UAS use requests, flight plans, risk assessments, and pilot credentials for all use of UAS flown by MnDOT staff or third parties.
  • Track MnDOT purchases of UAS.
  • Review and approve Certificate of Authorization (COA) applications before transmittal to the Federal Aviation Administration (FAA).
  • Review and approve district- and office- specific supplements to the MnDOT Office of Aeronautics sUAS Operations Manual.
  • Ensure compliance and identify opportunities for improvement of MnDOT UAS operations.
  • Serve as liaison between the district or office and the FAA for waivers and airspace authorizations. Review and approve waiver applications prior to transmittal to the FAA.
  • Serve as liaison for communication between districts and offices and the FAA.
  • Assist districts and offices that are pursuing or contracting for UAS services, as needed.
  • Provide pilot, mission, and standardization training as presented in the MnDOT Office of Aeronautics sUAS Operations Manual.

Office of Communications and Public Engagement/District Public Affairs Coordinators

  • Provide media coordination for missions to ensure clear, consistent messages about MnDOT use of UAS

Offices and Districts

  • Designate a point of contact for UAS operations within the district or office.
  • Comply with the MnDOT Office of Aeronautics sUAS Operations Manual. Office and districts may prepare district- or office-specific supplements for review and approval by the Office of Aeronautics.
  • Monitor the operations of MnDOT-owned UAS to ensure that flights are being conducted in accordance with the MnDOT Office of Aeronautics sUAS Operations Manual and any office- or district-specific supplements.
  • Ensure that all contracts and subcontracts for UAS activities include a provision to follow the MnDOT Office of Aeronautics sUAS Operations Manual.
  • Inform the Office of Aeronautics prior to any UAS purchase.
  • Purchase and maintain insurance for the UAS.
  • Register office- or district-owned UAS with the FAA and the MnDOT Office of Aeronautics to ensure compliance with state statutes and rules.
  • For flights in Indian Country, ensure coordination with the Tribal Nation  before each flight.
  • Ensure employees authorized to use a UAS read, understand, and follow this policy.
  • Work with the Office of Aeronautics to submit to the FAA applications for waivers and airspace authorizations.
  • If the district or office receives communications from the FAA, the point of contact must contact the Office of Aeronautics before responding.
  • Store, retain, and dispose of UAS video files according to the agency Record Retention Schedule.

Employees and Third Parties operating Unmanned Aircraft Systems (Pilots)

  • Read, understand, and follow this policy and the MnDOT Office of Aeronautics sUAS Operations Manual and any district- or office-specific supplements, all FAA, state, and local regulations, and the instructions provided by the UAS manufacturer.
  • Follow the restrictions laid out in the UAS Use Application and supporting documentation.
  • Report all incidents and/or accidents to the Office of Aeronautics according to the MnDOT Office of Aeronautics sUAS Operations Manual.

Policy Owner (Director, Office of Aeronautics)

  • Review the policy every two years, or sooner as necessary, to ensure the policy remains up to date. 
  • Ensure the MnDOT Office of Aeronautics sUAS Operations Manual, forms, supporting documents, and training associated with the policy remain current.
  • Monitor state, federal, enterprise, agency, or other requirements that apply to the policy or procedures.
  • Consult with the Office of Chief Counsel to ensure the policy and procedures remain compliant with all state, federal, enterprise, agency, or other requirements.
  • Ensure that necessary approvals by state or federal agencies are obtained before changes to the policy or procedures are implemented.
  • Work with the Policy Coordinator to revise the policy and/or confirm its accuracy.
  • Communicate policy revisions, reviews, and retirements to stakeholders.

Resources and related information

Processes, Procedures, and Instructions

Resources

History and updates

Adopted

June 18, 2015

Revised

  • First Revision: July 29, 2016 (template update only)
  • Second Revision: April 3, 2018
  • Third Revision: July 1, 2020 (also renumbered as #OE006)
  • Fourth Revision: January 29, 2025

Policy Review

This policy's next scheduled review is due January 2027.