The Chief Remote Pilot also have several obligations under the new Manual of Standards. Some obligations are new and have always been in the Regulations but are largely unknown by many Chief Remote Pilots. This is outlined in the MOS,

Section 10.03 (1) A certified RPA operator must ensure that its chief remote pilot keeps the following records:

(a) records which reasonably demonstrate that the chief remote pilot is regularly and consistently performing his or her functions and duties mentioned in paragraphs 101.342 (a), (b), (c) and (d) of CASR (chief remote pilot’s duties records);

Where Regulation 101.342 of CASR refers to the chief remote pilot obligations:

(a) ensuring the operator’s RPA operations are conducted in accordance with the civil aviation legislation;

(b) maintaining a record of the qualifications held by each person operating an RPA for the operator;

(c) monitoring the operational standards and proficiency of each person operating RPA for the operator; and

(d) maintaining a complete and up-to-date reference library of certain relevant operational documents

The exact requirements to ensure the Chief Remote Pilot satisfies each of the sub clauses outlined in Regulation 101.342 of the CASR are not directly stated in the Manual of Standards. However, they can be inferred by looking at the contents of each section. For example,

(a) ensuring the operator’s RPA operations are conducted in accordance with the civil aviation legislation;

This could be satisfied by using the RPAS Operational Record, RPAS Operational Release, RPAS Operational Log as evidence that the operation was planned and executed within the legislation.

Section 10.03(1)(b) the following RPAS operational record in relation to an RPA operation:

(i) if a job safety assessment is carried out in relation to the operation — a copy of the assessment;

(ii) if a risk management plan is produced for the operation — a copy of the plan;

(iii) if an operational flight plan is issued for the operation — a copy of the plan;

(iv) a copy of any NAIPS, NOTAM, or AIS briefing, document produced for the operation;

Section 10.04(1)(ii) the height (AGL):

(A) at which the RPA operation is to take place; and

(B) that is the maximum permitted height for the operation in accordance with the regulations and this MOS;

Section 10.04(1)(i) whether or not CASA has issued any instrument of approval, authorisation, direction, instruction, permission or exemption (however described) for the operation, and the full details of the instrument; Note The requirement to record full details of the instrument is met by including a copy of the instrument with the record.

Section 10.05(1)(d) the dates and times of the operation;

(e) the places, identified by specific location or global Cartesian coordinates, from which the RPA was:

(i) launched for the operation; and

(ii) landed and recovered at the end of the operation;

Likewise for 101.342(b)

(b) maintaining a record of the qualifications held by each person operating an RPA for the operator;

This requirement can be satisfied by Section 10.08 Records of qualification and competency

(1) This section applies if a person (the candidate):

(a) is employed by a certified RPA operator; and

(b) performs duties other than those of the remote pilot, in relation to the safety of RPA operations; and

(c) obtains a qualification or a competency in relation to the safe operation of an RPA.

(2) The certified RPA operator must:

(a) make a record (the record) of the person obtaining the qualification or competency; and

(b) provide a copy of the record to the person before the person exercises any privileges attributable to the

qualification or competency; and

(c) keep the record for at least 7 years after the day the person ceases to be employed by the operator.

However, for 101.342(c),

(c) monitoring the operational standards and proficiency of each person operating RPA for the operator; and

There doesn’t appears to be direct clause which directly addresses this topic. For example “Operational Standards” are not defined anywhere in the Manual of Standards. If one was to take this to mean is the Remote Pilot performing their duties within the regulations then indirect evidence such as the Operational Log, Remote Pilot Log and RPAS Technical Log could be used.

The Chief Remote Pilot would still need to maintain a record of when they reviewed this material as the direct evidence they have satisfied 101.342(c). How the Chief Remote Pilot should do this is not described in the Manual of Standards.

Finally for clause 101.342(d)

(d) maintaining a complete and up-to-date reference library of certain relevant operational documents

This requirement can be meet by keeping the Operations Manual, Procedures Library and RPAS documentation up to date and in an electronic form that is easy to access.

The above requirements demonstrate the Chief Remote Pilot has a wide breadth of responsibilities and obligations. Without an electronic system to manage all these obligations Chief Remote Pilots are likely to be quickly overwhelmed.

We have designed the FlyFreely platform to address the requirements of Chief Remote Pilots including the ability to registers to manage qualifications, approval mechanisms, review mechanisms and much more. This and other key features relevant to Chief Remote Pilots are detailed in our Part 101 MOS Compliance Guide. Fill in this form to obtain your copy today.