The new Part 101 (Unmanned Aircraft and Rockets) Manual of Standards is coming into force on the 20th of April 2020 in Australia. The purpose of this article is to help the Nominated Personnel on an RPA Operators Certificate and Remote Pilots to understand their obligations under this new legislation.
Let’s start with some understanding of what is a Manual of Standards (MOS).
The Part 101 Manual of Standards is formed as part of regulation 101.028 of the Civil Aviation Safety Regulations 1998. This means it carries with it the obligations and penalties found in the Civil Aviation Safety Regulations.
This is different to a document such as an Advisory Circular which are advisory only and not strictly subject to penalties for breaches.
With this in mind, it is vital for all Chief Remote Pilots (CRP), Remote Pilots and Nominated Persons on a RPA Operators Certificate (ReOC) to understand their obligations under Part 101 Manual of Standards to avoid potential penalties.
In this series we will specifically examine the Record Keeping Requirements of Chapter 10 as it applies to RPA Operator Certificate (ReOC). This chapter of the Manual of Standards will place the largest burden on all ReOC holders. (Note: The application of the Manual of Standards to Excluded RPA or sub-2kg Included RPA exemptions will not be covered here.)
The key topics in each section which stakeholders should be aware of include the following,
Section 10.01 – Requirement for unalterable electronic records. Tracking configuration changes for such things as motor or flight controller changes amongst others.
Section 10.03 – Reiterates the requirements of the Civil Aviation Safety Regulations (CASR) for the Chief Remote Pilot to maintain the records and maintain operational standards for 7 years. For maintaining operational standards the wording is quite broad and no specific guidance is given on how to achieve this.
Section 10.04 – Defines the requirement for an Operational Release (an approval / authorisation from the Chief Remote Pilot) for before every operation and retain those records for 7 years.
Section 10.05 – Keeping a log of the operation including take off and landing location coordinates, the remote pilot station used plus many more for 7 years.
Section 10.06 – Maintaining a log of a Remote Pilots time including the specific RPA used and location of the operations.
Section 10.07 – Keep all maintenance details of an RPA including service times for individual motors and propellers for 7 years.
Section 10.08 – Requirement to keep all training records for 7 years.
The following series of articles will address how each of these sections applies to different roles within the organisation. These roles include the following,