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Policy HSE-PRO-018 Remotely Piloted Aircraft Procedure
HSE-PRO-018 Remotely Piloted Aircraft Procedure
Table of Contents
The purpose of this procedure is to ensure James Cook University (JCU) manages authorised operations of Remotely Piloted Aircraft (RPA) so that all operations are carried out safely and comply with all applicable rules, laws and regulations.
Flyfreely is a Townsville based business which provides individuals and organisations with a range of RPA services.
JCU has entered into an arrangement with Flyfreely where JCU will operate RPAs under Flyfreely’s Remote Operators Certificate.
This Procedure applies to all JCU RPA Operations.
The Procedure provides information for all JCU staff and students involved in JCU RPA Operations to ensure JCU staff and students conduct all JCU RPA Operations in a safe manner.
Any JCU RPA Operation, regardless of its purpose, and regardless of the type, size or weight of the RPA used, must be authorised in accordance with this Procedure.
Above Ground Level
Aircraft Landing Area
Aeronautical Radio Operator Certificate
Civil Aviation Safety Authority
Civil Aviation Safety Regulation
Flight Radio Operator Licence
Size of RPA is Sub 100 gram
Remotely Piloted Aircraft
Remotely Piloted Aircraft System
Unmanned Aerial Vehicle
Visual Flight Rules
JCU Pilot Register
means the register managed by the Dean, Research which contains details of the licensed Remote Pilots-In-Command.
means all land, waterways, buildings or other sites which are owned and/or operated by JCU or could reasonably be considered to be under the control of JCU.
means any purpose in connection with the operation of JCU including research and education. This includes any flying hours required to be logged by Remote Pilots-In-Command for licensing requirements.
JCU RPA Operations
means any operation of an RPA, including flying, maintaining, or modifying an RPA on JCU Premises and/or for a JCU Purpose. For the avoidance of doubt JCU RPA Operations include Normal Operations, Proceduralised Operations and Special Operations.
JCU RPA Register
Means the register managed by the Dean, Research and contains a list of all approved RPAs that are authorised to be used in JCU RPA Operations.
RPA operations that meet the following requirements:
means information or an opinion (including information or an opinion forming part of a database) whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent or can reasonably be ascertained, from the information or opinion
Any RPA operation that has a complete set of procedures specific to that location or style of operation. This includes, but is not limited to:
RPA operations that require exemptions, permissions or approvals by CASA beyond that defined as a Normal or Proceduralised operation. These may include, but are not limited to:
Standard Operating Conditions
As defined in CASR 101 as RPA operations that:
5 Duty, Obligations and Responsibilities
Flying RPAs can be a dangerous activity. Education and training of JCU staff and students in the operation of RPAs can reduce the risks associated with these activities.
Although JCU operates RPAs under the Flyfeely’s Remote Operators Certificate, JCU has a duty to ensure:
- the health and safety of workers and others during all JCU RPA Operations; and
- that all JCU RPA Operations being conducted comply with all applicable rules, laws and regulations.
5.2 JCU staff and students
JCU staff and students must comply with this Procedure before commencing a JCU RPA Operation.
Visitors to JCU are not authorised to fly RPAs under any circumstances on JCU Premises and/or for a JCU Purpose.
5.3 Dean, Research
The Dean, Research has a JCU-wide oversight of JCU RPA Operations. More specifically, he/she is responsible for the following:
- Maintaining the JCU RPA Register to ensure currency of all RPAs listed thereon;
- Maintaining the JCU Pilot Register to ensure currency of licenses for all qualified Remote Pilots-In-Command thereon;
- Ensuring all RPAs are listed in the Flyfreely data base and noted on JCU’s aviation insurance policy;
- Ensuring all Remote Pilot Operators and Remote Pilots-In-Command are listed on JCU’s aviation insurance policy.
- Ensuring all RPAs are maintained to required standards.
5.4 Chief Pilot
The Chief Pilot is a suitably qualified and experienced RPA operator who is responsible for ensuring all JCU RPA Operations are conducted in compliance with the Civil Aviation Act 1988 (Cth) and the CASR.
The Chief Pilot is a Flyfreely employee and reports to the Managing Director of Flyfreely, CASA and the Dean, Research as well as other regulatory bodies as required.
The Chief Pilot is also responsible for:
- maintaining a record of qualifications held by each Remote Pilot-In-Command;
- having control of all controller training and operational matters affecting the safety of all JCU RPA Operations;
- maintaining a complete and up-to-date reference library of operational documents as required by CASA for the class of operations conducted by JCU;
- being responsible for all communication between JCU, Flyfreely and CASA; and
- reviewing and approving applicable flight plans.
5.5 Chief Maintenance Controller
The Chief Maintenance Controller controls all RPA maintenance on behalf of JCU.
The Maintenance Controller is a Flyfreely employee and reports to the Managing Director of Flyfreely, the Dean, Research and CASA.
The Chief Maintenance Controller is also responsible for:
- ensuring personnel performing maintenance on the RPAs are competent by keeping records of personnel permitted to perform maintenance;
- developing, enforcing and monitoring RPAs maintenance standards;
- maintaining a record of RPAs unserviceability, RPAs hours, cycles and other information relevant to the scheduling of maintenance;
- ensuring maintenance activities are conducted in accordance with the procedures specified in the Maintenance Manual;
- liaising with CASA with regard to all maintenance and technical issues relating to all JCU owned RPAs;
- following manufacturer's instructions, recommendations and bulletins;
- determining more efficient, safer, economical and time minimising procedures and processes;
- assessing how new payloads interact with the RPA electrically, mechanically and structurally;
- ensuring that all payloads or modifications are attached to the RPA (both passive and active) conform with the RPA’s specification; and
- approving all new payloads and determining if the payload will be approved for the Remote Pilot-in-Command to swap off and on.
5.6 Remote Pilot Operators and Remote Pilot-in-Command
The Remote Pilot Operator or Remote Pilot-In-Command is a JCU staff member or student authorised to undertake a JCU RPA Operation.
The Remote Pliot Operator or Remote Pilot-in-Command is responsible for:
- the safe flying of the RPA;
- ensuring the RPA under his or her control is operated in accordance with this Procedure;
- ensuring that each flight is conducted according to any law, rule, regulation or conditions required for that flight;
- carry his or her own identification or if applicable CASA issued Remote Pilot License with him or her on operations;
- ensuring logbooks, insurance and data base logs remain up-to-date;
- conducting safe operations from pre-flight, start-up, during flight and after landing until after shutdown and storage of the RPA; and
- completing a risk assessment prior to and during JCU RPA Operations to ensure control mechanisms remain effective throughout the mission.
When flying RPA’s under 2kg and under standard operating conditions Remote Pilot Operators may conduct activities (i.e a Remote Pilot Licence may not be required) if eligibility as an excluded RPA is established. The following criteria must be satisfied:
The RPA is operated:
- by visual line of sight (VLOS) only - close enough to see, maintain orientation and achieve accurate flight and tracking;
- no higher than 120 m (400 feet) above ground level;
- during daytime only - not after sunset.
The RPA is not operated:
- any closer than 30 m from people not associated with the flight (i.e.Any person who is not charged with duties essential to the safe operation of a remotely piloted aircraft);
- in a prohibited area or restricted area;
- in a restricted area that is classified as RA3;
- over populous areas;
- within 5.5 km (3 NM) of a controlled aerodrome - one with an operating control tower;
- in the area of a public safety operation without the approval of a person in charge of the operation;
Only 1 RPA flown per pilot at any one time.
For clarification on any of these points refer to CASA advisory circular AC101-10 Remotely piloted aircraft systems- operation of excluded RPA (other than model aircraft).
In addition the remote pilot in command must also:
- be listed on the JCU Pilot Register and noted on JCU’s Remotely Piloted Aircraft System insurance policy (refer Section 9). The Remote Pilot Operator must contact the RPAS@jcu.edu.au to ensure he or she is listed on the JCU Pilot Register before undertaking a JCU RPA Operation.
- notify CASA five business days before the first operation, using JCU’s ARN number 216007. CASA’s authorisation to fly must be emailed to RPAS@jcu.edu.au.
- attach to, or insert into, their aircraft a fire-proof identification ‘plate’ or − write the identification details in indelible ink on the aircraft. (Identification need only be in place during flight time).
- maintain aircraft records that show: − time-in-service − maintenance history − any defects and abnormalities that affect operations − any incidents or accidents − any other useful information that may affect the safety of future flights with the RPA.
- prepare a mission plan for each flight of an RPA and send that plan to RPAS@jcu.edu.au. The plan should include information about the local area and any hazards. It should also contain procedures about planned emergency flight profiles in the event of a lost data link. Depending on system capabilities, these profiles should include either an: − RPA automated transit to a pre-designated recovery area, followed by an automated recovery or − RPA automated transit to a pre-designated recovery area, followed by activation of a flight termination system.
All activities which do not satisfy the above criteria will require a Remote Pilot Licence
For those activities which require a Remote Pilot Licence the Chief Pilot in conjunction with the Dean, Research authorises the Remote Pilot-in-Command to carry out a JCU RPA Operation.
A Remote Pilot-in-Command will report to the Chief Pilot, the Dean, Research and regulatory bodies as required.
To obtain a (UAV) a Remote Pilot License, JCU staff and students should first email firstname.lastname@example.org. The relevant JCU staff member or student will then be contacted by the Chief Pilot to commence the licensing process.
When flying RPA’s over 2kg or in NON exempt areas a Remote Pilot-In-Command must satisfy the following requirements:
- hold a current Remote Pilot License issued by CASA or have successfully completed Flyfreely’s Remotely Piloted Training Course;
- hold a current AROC or FROL. If a FROL is held, an appropriate and current medical is also required;
- have a minimum of 5 hours’ experience on the type of RPA to be used (under supervision);
- have demonstrated competency in flight to the Chief Pilot, Chief Training Officer or Pilot nominated and authorised by the Chief Pilot; and
- have demonstrated a good sense of safety.
In addition, for Special Operations, the Remote Pilot-in-Command must satisfy the following additional requirements:
- internal training for the type of ‘special’ operation;
- appropriate endorsement on internal license; and
- demonstrated competency in flying RPAs to the satisfaction of the Chief Pilot.
Each Remote Pilots-In-Command will be qualified on a class of RPAs. Any changes will need to be approved and CASA will issue the relevant Remote Pilot License to reflect new RPA types and weights class that may be operated by the Remote Pilot-In-Command. After the CASA updates are confirmed, the Remote Pilot License will be updated.
Upon induction, Remote Pilots-In-Command will receive digital copies of all operations, flight and maintenance manuals and associated documents/software to appropriately plan, execute and log JCU RPA Operations.
The Remote Pilot-In-Command must be listed on the JCU Pilot Register and noted on JCU’s Remotely Piloted Aircraft System insurance policy. The Remote Pilot-In-Command must contact the RPAS@jcu.edu.au to ensure he or she is listed on the JCU Pilot Register and noted on JCU’s Remotely Piloted Aircraft System insurance policy before undertaking a JCU RPA Operation.
To ensure Remote Pilots-In-Command maintain an adequate level of competency in operating an RPA, they will be subject to initial and annual evaluations (knowledge and flight competency) by the Chief Pilot and the Dean, Research.
5.7 Maintenance Personnel
The Maintenance Personnel maintain the RPAs.
Maintenance Personnel are JCU employees and will report to the Chief Maintenance Controller and regulatory bodies.
The Maintenance Personnel have the following functions and responsibilities:
- to complete all maintenance to the best of their technical ability;
- notify the Chief Maintenance Controller of any and all defects found during any maintenance;
- follow manufacturer's instructions, recommendations and bulletins; and
- determine more efficient, safer, economical and time minimising procedures and processes and notify the Chief Maintenance Controller of the new methods before implementing.
5.8 Payload Specialist / Non-Controlling Observer
The Payload Specialist / Non-Controlling Observer are JCU employees and report to the Remote Pilot-in-Command.
The Payload Specialist / Non-Controlling Observer have the following functions and responsibilities:
- to not interfere with the flying operation of the Remote Pilot-in-Command;
- to assist the Remote Pilot-in-Command with any emergency if requested or directed by the Remote Pilot-in-Command;
- to assist the Remote Pilot-in-Command with observations of potential hazards both to the RPA and the general public; and
- maintain knowledge of how to activate the failsafe mechanism of the RPA.
6 RPA Operations
6.1 Approval process to Undertake JCU RPA Operation
JCU staff and students undertaking JCU RPA Operations must ensure they are authorised by the appropriate personnel prior to operation.
JCU staff and students wishing to undertake a JCU RPA Operation should contact the Dean, Research in the first instance with any queries on this Procedure.
All excluded RPA JCU Operation requests must notify CASA 5 business days before the first operation and satisfy the criteria listed in section 5.6 for Remote Pilot Operators.
All non excluded RPA JCU Operation requests must first be submitted to email@example.com. This includes all documentation risk assessments, flight plans and database entries necessary for review and approval.
For all Normal and Proceduralised operations, approval requests must be submitted at least 1 week (7 calendar days) in advance of the JCU RPA Operation.
All Special Operations will require a minimum of 2 months (63 calendar days) for approval. This is to allow for exemptions to be issued by CASA, ensure appropriate documentation and training is in place, and all updates and maintenance on affected RPAs has been completed (if required).
The Chief Pilot will review the flight plan and risk assess the proposed JCU RPA Operation. The Chief Pilot may provide:
- approval for the JCU RPA Operation;
- additional information or identification of risks prior to approval;
- additional required steps to be undertaken prior to, or during the mission; and
- additional requirements on the operation such as, but not limited to:
- phone calls to controlling authorities;
- radio broadcasts;
- flight parameter requirements;
- flight path requirements; and
- crew requirements.
For additional information on the approval process, JCU staff and students can email firstname.lastname@example.org.
All RPA’s used in JCU RPA Operations by JCU staff and students must be:
- owned by JCU;
- listed in Flyfreely’s data base;
- noted on JCU’s insurance policy; and
- listed on the JCU RPA Register,
before the JCU RPA Operation can be undertaken.
All RPAs to be used in JCU RPA Operations must be purchased using a purchase requisition and the approved process that is outlined in FMPM 711 – Procurement Procedure.
Non JCU owned RPAs are not to be used for JCU RPA Operations unless approved by email@example.com in advance of the operation.
JCU staff and students must complete the Planning Checklist for use of Remote Piloted Aircraft before carrying out a JCU RPA Operation.
7 On Site Requirements
When arriving onsite to carry out a JCU RPA Operation, the following shall be conducted by the Remote Pilot Operator or Remote Pilot-in-Command:
- site familiarisation to identify hazards and launch and recovery areas (primary and emergency);
- on-site risk assessment / job safety assessment (OP-0017-FRM-Job Safety Assessment (SC)) in iAuditor also available on the JCU website),
- a safety briefing to all personnel involved and spectating nearby;
- a Pre-Flight Checklist that is specific to the RPA being used;
- a ‘Take 5’ prior to all individual flights/sorties;
- safely conducting the RPA operations; and
- Post-Flight checklists that is specific to the RPA being used.
For education, outreach, research and training purposes, micro-drones (<100g MTOW; Reference: CASR 101.G - 101.375 or reference as a “micro” size) operations shall be conducted such that:
- the Chief Pilot is to be aware of operations with the Sub 100 gram systems via email to firstname.lastname@example.org;
- a Pre-Flight Risk assessment (FL-0038-FRM-Pre-Flight Risk Assessment(SC)) is required to be completed prior to the operations taking place;
- the Pre-Flight Risk assessment (FL-0038-FRM-Pre-Flight Risk Assessment(SC)) should be reviewed on site and a standard Take 5 is to be conducted;
- the sub 100 gram RPA operation must be supervised by an JCU authorised Pilot in Command but other Personnel may operate and control the RPA;
- a briefing must be issued to other personnel ensuring they are aware that though small, these RPA can still cause injury including damage to eyes from the fast spinning props and burns or electrocution from batteries that are mis-handled; and
- a risk assessment (via RiskWare) may still be required by JCU policy for the broader activity.
Any maintenance conducted onsite will require MA-0003-REP-In-Field Maintenance Request (in iAuditor also available on the JCU website) to be completed. This is submitted and needs to be forwarded to email@example.com to be logged with the RPA maintenance records.
8 Post Flight Requirements
On completing a JCU RPA Operation, the Remote Pilot-In-Command shall log the flights and battery use in the Flyfreely database. The Remote Pilot-in-Command will notify the Chief Maintenance Controller (firstname.lastname@example.org ) of any required repair or maintenance to the RPA.
For the avoidance of doubt, any repairs and / or maintenance to the RPA must be undertaken only by the Maintenance Personnel.
All Remote Pilot Operators, Remote Pilots-In-Command must be approved by the insurer and listed on JCU’s Remotely Piloted Aircraft System insurance policy before they can undertake any JCU RPA operation.
All RPAs and associated equipment operated by the Remote Pilot Operator or Remote Pilot-In-Command must be approved by the insurer and listed on JCU’s Remotely Piloted Aircraft System insurance policy before they can be flown.
Insurance cover is not automatic and will require the Remote Pilot Operator or Remote Pilot-In-Command to contact email@example.com and firstname.lastname@example.org to arrange cover. Insurance cover is only in place once confirmation has been received from the insurer.
If a claim is made on JCU’s Remotely Piloted Aircraft System insurance policy as a result of a JCU RPA Operation, an excess may apply.
10 Drug and Alcohol Management
Drugs and alcohol testing may occur at any time.
Drugs or alcohol cannot be consumed 8 hours prior to planning or executing JCU RPA Operations.
JCU staff or students undertaking a JCU RPA operation who exceed the permitted level of 0.02 grams of alcohol in 210 litres of breath will be providing a positive test result and therefore will not be approved to undertake a JCU RPA Operation until a negative test result has been provided.
11 Incident Reporting
In the event of any incident, the Remote Pilot Operator, Remote Pilot-in-Command or the Non Controlled Observer are to report the incident by:
- 000 / 112 if anyone is injured;
- local air traffic controllers;
- Chief Pilot and / or Director-Divisional Operations and the Dean, Research; and
- any additional parties identified during the Pre-Flight Risk Assessment.
- documenting and photographing all aspects of the incident immediately and on location and report the incident using form OP-0012-FRM-Internal Incident Report (SC) in iAuditor also available on the JCU website;
- assisting with an investigation of the incident if required and ensuring processes and documentation is amended to incorporate recommendations as a result; and
- following the additional requirements outlined in the HSE-PRO-014 Incident and Hazard Management Procedure.
12 Field Trips
Any JCU RPA Operation approved for the purpose of study or research by JCU staff or students that is conducted off-campus may be considered a field trip. JCU field trips are to be managed in accordance with HSE-PRO-007 Field Trip Procedure in addition to this Procedure.
13 Non- JCU Remote Pilot Operators, Remote Pilots-In-Command and JCU Property
Non-JCU Remote Pilot Operators/Remote Pilots-In-Command must not operate on behalf of JCU or operate as, Remote Pilot Operators/Remote Pilot-in-Command any JCU owned RPA’s without the prior written approval from the Dean, Research and the Chief Pilot. For more details contact email@example.com.
Permission and approval to fly over JCU Premises must be sought by emailing firstname.lastname@example.org.
14 Private or Recreational Operations using JCU RPAs
RPAs that are not owned by JCU must not be used over JCU Premises and/or for a JCU Purpose for any reason under any circumstances by JCU staff and students or visitors to JCU.
15 Personal Information
JCU staff and students should be aware that Personal Information of third parties may be collected while undertaking JCU RPA Operations, for example, taking photographs of individuals. If JCU staff and students are concerned about the use of any video footage or photographs taken as a result of carrying out a JCU RPA Operation, they should contact the Dean, Research in the first instance for further advice prior to use of any such footage or photograph.
16 Related Documents, Legislation and Other Resources
16.1 Related Documents and Other Resources
FL-0001-MAN- Flight Manual
Australian Government Civil Aviation Safety Authority
Advisory Circular AC 101-10 Remotely piloted aircraft systems – operation of excluded RPA (other than model aircraft)
JCU RPA Register
JCU Pilot Register
16.2 Regulatory Authorities and Other Relevant Entities
Air Services Australia
Australian Defence Force
16.3 Related Legislation, Codes of Practice and Standards
NOTE: Printed copies of this procedure are uncontrolled, and currency can only be assured at the time of printing.
17.1 Approval Details
Deputy Vice Chancellor, Services and Resources
Date for next Major Review
17.2 Revision History
NOTE: A minor amendment will not result in a change of the next major review date.
Approval date - the date the Policy Sponsor approved the establishment, minor or major amendment or disestablishment
Implementation Date - the date the procedure was published in the Policy Library and is the date the procedure takes effect
Amended to reflect changes in legislation.
HSE System Officer
HSE System Officer
Remotely piloted aircraft
Health, Safety and Environment Advisory Committee (HSEAC)