WHS-PRO-018 Remotely Piloted Aircraft Procedure
This procedure documents how James Cook University (JCU) manages authorised operations of Remotely Piloted Aircraft (RPA) and Model Aircraft (MA) so that operations are carried out safely and comply with all applicable rules, laws and regulations.
This Procedure applies to all JCU RPA/MA operations.
The Procedure applies to all JCU staff, students (including higher degree by research candidates) and volunteers involved in JCU RPA/MA operations.
Any JCU RPA/MA operation, regardless of its purpose, and regardless of the type, size or weight of the RPA/MA used, must be authorised in accordance with this Procedure.
Aircraft Landing Area
Aeronautical Radio Operator Certificate
Aviation Reference Number
Civil Aviation Safety Authority
Civil Aviation Safety Regulation
Size of RPA is Sub 250 grams
Remote Operator Certificate
Remote Pilot License
Remotely Piloted Aircraft
Standard Operating Conditions
Visual Flight Rules
Visual line of sight
Non Licensed Operators responsible for the operation and safety of Excluded RPA’s (type 2 operation). Operators must obtain accreditation from CASA prior to performing any Excluded RPA operations.
An RPA operated under prescribed conditions that does not require a CASA authorisation in the form of an RPA operator’s certificate (ReOC) and / or a Remote Pilot License (RePL).
A person operating a model aircraft weighing less than 250g for education purposes only.
A non-regulatory term for RPA operations that require authorisation in the form of a ReOC and RePL (i.e. operator’s certificate and license).
JCU Pilot Register
Means the register managed by the Dean, Research which contains details of Accredited Operators and Licensed Pilots..
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 work, research and education. This includes any flying hours required to be logged by Licensed Pilots for licensing requirements.
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.
Licensed Pilot responsible for the operation and safety of the aircraft during flight time
An aircraft that is used for sport or recreational purposes and which cannot carry a person. For the purposes of JCU, model aircraft refers to a micro-drone (less than 250g) that is used for educational purposes.
Assists with RPA operations and reports to the Pilot.
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.
Table of Contents
1 Duty, Obligations and Responsibilities
To protect the safety of the operator and other people, JCU RPA’s must only be operated in accordance with this Procedure. Education and training of JCU staff and students in the operation of RPAs can reduce the risks associated with these activities. Each person involved in RPA activities has a responsibility to ensure the health and safety of themselves and others.
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.
1.2 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 on JCU premises and/or for a JCU purpose unless specifically employed by JCU to do so, such as in the case of contractors.
1.3 Dean, Research
The Dean, Research has a JCU-wide oversight of JCU RPA operations. More specifically, he/she is responsible for the following:
- Providing the necessary resources so that all RPA operations can be carried out safely and in compliance with applicable legislation;
- Maintaining the JCU RPA Register to ensure currency of all RPAs listed thereon;
- Maintaining the JCU Pilot Register to ensure currency of licenses/accreditation for all Licensed Pilots and Accredited Operators thereon;
- Ensuring all RPAs are listed in the JCU register for the JCU’s aviation insurance policy;
- Ensuring all Licensed Pilots and Accredited Operators are listed on JCU’s aviation insurance policy.
1.4 Chief Pilot
For some types of RPA operations, JCU must operate under a Remote Operator Certificate (ReOC) to operate RPA’s.
JCU does not hold a ReOC. Where required, JCU will engage an external company to utilise their ReOC, providing the business holding the ReOC can manage the activity and all conditions of the Operations Manual are followed.
The Chief Pilot is nominated under the ReOC, and must be a suitably qualified and experienced RPA operator. The Chief Pilot is responsible for ensuring JCU RPA operations are conducted in compliance with the Civil Aviation Act 1988 (Cth) and the Civil Aviation Safety Regulation (CASR).
The Chief Pilot reports to the Civil Aviation Safety Authority (CASA) and the Dean, Research as well as other regulatory bodies as required.
1.5 Remote Pilot Types
Licensed Pilots (<2kgs RPA not under the SOC and >2kg RPA; must operate under a ReOC provider);
Accredited Operator (<2kgs RPA under the standard operating conditions (SOC)); and
Fun Flyers (<250g RPA for education purposes only).
The Licensed Pilot / Accredited Operator / Fun Flyer is the person who manipulates the flight controls of a RPA/MA.
The Accredited Operator is registered with CASA and has passed all CASA requirements, the Licensed Pilot operates under a ReOC provider and the Fun Flyer can operate micro-drones (<250g) for educational purposes without Licenses and are not required to register with CASA.
All pilots are 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;
- obtaining their own Aviation Reference Number (ARN) (type 1 & 2 operations only);
- ensuring RPA’s are registered under the JCU ARN, when appropriate to do so (type 1 & 2 operations only). Do not register the RPA yourself, this must be completed by sending the RPA information to RPAS@jcu.edu.au;
- 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.
1.6 Maintenance Personnel
Any JCU staff member or student who manages a RPA is responsible for the maintenance of the RPA.
JCU staff involved in the RPA maintenance of included RPA’s (refer to type 1 operations section 2.3) will report to the ReOC Chief Maintenance Controller and regulatory bodies when maintaining RPA’s registered with a ReOC.
Any staff member / student involved in the maintenance of RPA’s have the following functions and responsibilities:
- complete all maintenance in accordance with the manufacturer’s instructions;
- when applicable, record and notify the appropriate ReOC provider Chief Maintenance Controller of all defects found during maintenance; and
- follow manufacturer's instructions, recommendations and bulletins.
1.7 Non-Controlling Observer
A Non-Controlling Observer is a JCU staff member / student / volunteer who assists and reports to the Licensed Pilot or Accredited Operator during flight operations.
Non-Controlling Observers have the following functions and responsibilities:
- to not interfere with the flying operation of the Licensed Pilot / Accredited Operator;
- to assist the Licensed Pilot / Accredited Operator with any emergency if requested;
- to assist the Licensed Pilot / Accredited Operator 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.
2 Types of Operations
2.1 What are Standard Operating Conditions (SOC)?
The RPA/MA 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 as defined by a CASA-verified drone safety app;
- 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).
2.2 JCU Operation Types
2.2.1 Operation Type 1 – Included RPA (requires a Licensed Pilot and must be operated under an externally contracted ReOC):
RPA’s weighing more than 2kgs; OR
RPA’s weighing less than 2kg RPA not operated under the SOC
2.2.2 Operation Type 2 - Excluded RPA (micro and very small drones) (requires an accredited operator):
RPA’s weighing up to 2kg (classed as RPA) (micro and very small drones) that are operated under the SOC.
2.2.3 Operation Type 3 – Model Aircraft (micro drones used for education and operated under the SOC) (Fun Flyer - does not have any licensing or accreditation requirements):
Model Aircraft weighing less than 250g and operated for educational purposes only (fly for fun).
This type of operation is classed as non-commercial (flying for fun).
2.3 Operation Type 1
This type of operation includes:
- Operating RPA’s weighing less than 2kg and not operating the under SOC; or
- Operating RPA’s weighing more than 2kgs.
2.3.1 Approval process to Undertake JCU RPA Operation
JCU staff and students wishing to undertake JCU RPA operation should contact RPAS@jcu.edu.au with any queries on this Procedure.
JCU staff and students undertaking JCU RPA operations must ensure they are authorised by the appropriate personnel prior to operation. Contact RPAS@jcu.edu.au.
All Type 1 RPA JCU operation requests must be submitted to an externally contracted Chief Pilot. This includes all documented risk assessments, flight plans and database entries necessary for review and approval.
Special operations may require extra time for approval. This is to allow for exemptions to be issued by CASA, ensure appropriate documentation and training are in place, and all updates and maintenance on affected RPAs has been completed (if required).
2.3.2 Licensing and Training Requirements – Licensed Pilots
For those activities that require a Licensed Pilot, the Chief Pilot in conjunction with the Dean, Research authorises the Licensed Pilot to carry out a JCU RPA operation.
A Licensed Pilot will report to an externally contracted Chief Pilot, the Dean, Research and regulatory bodies as required.
To obtain a Remotely Operated Aircraft Pilot License, JCU staff and students should first contact an externally contracted ReOC provider. The relevant JCU staff member, or student, will then be contacted by the ReOC providers Chief Pilot, to commence the licensing process.
The Licensed Pilot may be required to complete additional licensing and training as directed by the ReOC Provider.
Each Licensed Pilot will be qualified on a class of RPAs. Any changes will need to be approved and CASA will issue the relevant Remotely Operated Aircraft Pilot License to reflect new RPA types and weights class that may be operated by the Licensed Pilot. After the CASA updates are confirmed, the license will be updated.
2.3.3 JCU Licensed Pilot Register and Insurance Policy
The Licensed Pilot must email 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.
2.3.4 Chief Pilot Role
A Chief Pilot will review the flight plan and risk assess the proposed JCU RPA operation. A 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 go to the CASA web site.
2.4 Operation Type 2 – Excluded RPA
This type of operation includes:
- RPA weighing less than 2kg being operated under the SOC.
2.4.1 JCU registration process to Undertake JCU RPA Type 2 Operations
JCU staff and students wishing to undertake JCU RPA Type 2 operations should contact RPAS@jcu.edu.au with any queries on this Procedure.
JCU staff and students undertaking JCU RPA Type 2 operations must submit their proposed operation and general mission plan (refer to 2.4.8) to RPAS@jcu.edu.au.
2.4.2 Individual ARN
An ARN allows CASA to transact directly with an individual RPA Operator. Individual’s need an individual ARN to access the myCASA portal to obtain accreditation.
An ARN application for an individual can be made through the CASA website. The applicant will need to provide CASA with proof of identity. Details of acceptable identity documents are available on the CASA website.
Do not register RPA’s (i.e. the aircraft) under individual ARN’s. RPA’s must be registered through the JCU ARN (refer to Section 2.6).
2.4.3 Licensing and Training Requirements
When flying RPA’s weighing less than 2kg and operating under the standard operating conditions (SOC) Operators do not require a Remote Pilot License, but must obtain an operator’s accreditation from CASA.
RPA operator accreditation involves viewing a short safety video, reading the educational material and successfully completing an online quiz to test knowledge of the standard RPA operating conditions and RPA safety rules. Accreditation can be completed online through the myCASA portal. Accreditation is free and is valid for three years.
If you hold a Remote Pilot License (RePL) you are not required to hold operator accreditation.
2.4.4 Age limit
Accredited Operator must be 16 years or older.
2.4.5 JCU Pilot Register and Insurance Policy
All JCU Accredited Operators must be listed on the JCU Pilot Register and noted on JCU’s Remotely Piloted Aircraft System insurance policy (refer Section 2.7). The 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.
2.4.6 RPA requirements
Registration with JCU:
- The JCU Accredited Operator must ensure that the RPA is registered with JCU Insurance before it can be flown (excluding micro drones being used for educational purposes refer to type 3 operations).
Maintenance of RPA:
- It is also the responsibly of the JCU Accredited Operator to 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. Micro drones being used for educational purposes are excluded from this requirement refer to type 3 operations.
2.4.7 General Mission Plan and Field Trip Module
It is the responsibility of the JCU Accredited Operator to prepare a general mission plan and include that within the Field Trip Module. The Field Trip Module is located within JCU’s WHS RiskWare software. The plan should include information about the local area and any hazards. It should also contain procedures in case of emergency (e.g. recovery of RPA).
2.4.8 Where can I fly?
It is the responsibility of the JCU Accredited Operator to download one of the CASA approved drone safety apps to help decide where flights can take place.
2.4.9 On Site Requirements
When arriving onsite to carry out a JCU RPA operation, the following shall be conducted by the Accredited Operator:
- site familiarisation to identify hazards and launch / recovery areas (primary and emergency);
- a safety briefing to all personnel involved and spectating nearby;
- a Pre-Flight Checklist that is specific to the RPA being used (WHS-PRO-CHK-018a Pre-Flight Checklist for <2kg SOC);
- safely conducting the RPA operations; and
- post-Flight checklists that is specific to the RPA being used (WHS-PRO-CHK-018b Post-Flight Checklist for <2kg SOC).
2.4.10 Post Flight Requirements
On completion of a JCU RPA operation, Accredited Operators shall log the flights (WHS-PRO-FORM-018c CASA Form 1483 – RPA Flying Hours Log Book) and battery use, update aircraft records, report any defects and abnormalities to maintenance personnel and report any other useful information that may affect the safety of future flights with the RPA. Micro drones being used for educational purposes are excluded from this requirement refer to type 3 operations.
All activities which do not satisfy the above criteria will require a Remote Pilot License and fall under Operation Type 1.
2.5 Operation Type 3
Operating under 250g RPA, under SOC conditions and for educational purposes.
There are no CASA accreditation or RPA registration requirements for this type of operation. JCU does not require this type of operation to be added to JCU Insurance or logged through RPAS@jcu.edu.au.
2.5.1 Approval process to Undertake JCU RPA Operation
JCU staff and students wishing to undertake JCU RPA operations should contact firstname.lastname@example.org with any queries on this Procedure.
2.6 RPA Requirements
2.6.1 Approved JCU RPA
All RPA’s used in JCU RPA operations by JCU staff and students must be:
- owned by JCU;
- registered under the JCU’s ARN (similar to motor vehicles, it is compulsory that all RPA’s are registered with CASA). RPA registration is valid for 12 months;
- 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. This section does not apply to external contractors who are formally engaged by JCU to conduct inspections / photography using their company RPA/s.
2.6.2 Maintenance of RPA
- Those RPAs registered with ReOC providers will follow all maintenance requirements instructed by the ReOC provider. This applies to Type 1 operations only.
- RPAs not registered with a ReOC provider will be maintained by designated JCU maintenance personnel (or the manager of the RPA) and will follow the manufacturer’s specifications.
- If a manufacturer does not provide details concerning the scheduling of maintenance, or the information is not relevant, a schedule may be developed based upon similar craft and best practice.
- The maintenance personnel will ensure maintenance schedules that have been developed for an RPAS are followed and recorded. A copy of the schedule should be kept with the RPA as well as an inspection record.
- All components of an RPAS are subject to ongoing ‘on condition’ monitoring through the pre-flight and post-flight inspections.
- The pre-flight and post–flight inspections are used to identify damage, wear, malfunction or unserviceability, and any defects found during these inspections will be recorded on a Defect and Maintenance Log.
- Maintenance personnel will monitor the failure rate of each RPAS. Components must be repaired or replaced where they show signs of unserviceability, abnormality or damage unless the damage is insignificant to the operation of the RPAS (e.g. scratches or cosmetic damage).
- Avionic and control system software is only to be updated after the version has been confirmed as being stable. A post maintenance test flight, in a controlled and safe location, must be completed as part of the maintenance activity whenever a software or firmware update is applied.
- Where an issue arises with a new software / firmware version, the component is to be rolled back to the previous stable version before the RPAS is used in commercial operations.
- Records of firmware or software updates will be documented in the maintenance log and include details of any test flights and version numbers relevant to the update.
- It is the responsibility of all person(s) involved in the operation of RPAS to report defects as they occur and record the maintenance they have conducted on the RPAS.
All Licensed Pilots and Accredited Operators operating under type 1 and 2 conditions must be listed on JCU’s Remotely Piloted Aircraft System insurance policy before they can be operated.
All RPA’s and associated equipment operated by the Licensed Pilot / Accredited Operator must be listed on JCU’s Remotely Piloted Aircraft System insurance policy before they can be flown.
Pilots / Operators and aircraft information will need to be updated annually by February each year. The previous year’s pilot and aircraft listings will be removed from the insurance cover and will require the Pilot / Operator to contact email@example.com and firstname.lastname@example.org to arrange cover. Insurance cover is only in place once confirmation has been received.
2.8 Drug and Alcohol Management
Drugs and alcohol testing may occur at any time by CASA or the ReOC Provider in accordance with their safety management systems.
Pilots / Operators / Flyers should make themselves familiar with their rights and obligations under the CASA regulations. Information on random drug and alcohol testing can be found on the CASA website under Safety Management.
As a guide, drugs or alcohol should not be consumed 8 hours prior to or during any period of planning or executing JCU RPA operations.
2.9 Incident Reporting
In the event of any incident, the Pilot / Operator / Flyer 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.
- document and photograph all aspects of the incident immediately and report the incident;
- assist with an investigation of the incident if required and ensure processes and documentation is amended to incorporate recommendations as a result; and
- follow the additional requirements outlined in the WHS-PRO-005 Incident and Hazard Management Procedure.
Additional to the requirements of WHS-PRO-005 WHS Incident and Hazard Management Procedure, incidents and accidents involving RPA operations may be reportable to the Australian Transport Safety Bureau (ATSB).
The ATSB require immediately reportable and routine reportable matters to be reported as soon as is reasonably practicable.
2.9.1 Immediately reportable matters
An immediately reportable matter is a serious safety matter including accidents involving death, serious injury or significant damage to the RPA. Immediately reportable matters may include where a person is seriously injured by an RPA; a collision with another aircraft (including another RPA); where the RPA has been seriously damaged; or, other matters where it may be necessary for the ATSB to attend the operational area immediately to collect evidence for safety analysis. The ATSB must be contacted by phone as soon as reasonably practicable, with a follow up written report submitted within 72 hours.
2.9.2 Routinely reportable matters
A routinely reportable matter is something that has not had a serious outcome and does not require an immediate report but could have impacted the safety of aviation. Routinely reportable matters may include a non-serious injury to a person; a near miss with another aircraft (including another RPA); an issue controlling the RPA such as a loss of control; non-serious damage to the RPA; or, other matters where aviation safety could be enhanced by the ATSB collecting the incident data. A written report should be submitted within 72 hours.
2.9.3 Who is required to make a report to ATSB
The Dean, Research, in consultation with the purchaser/pilot of the RPA is responsible for reporting the incident to ATSB. Details on how to make a report about an incident or accident can be found on the ATSB website.
2.10 Non-JCU Licensed Pilots / Accredited Operators
Non-JCU Licensed Pilots / Accredited Operators must not operate on behalf of JCU or operate any JCU owned RPA’s without the prior written approval – contact email@example.com.
2.11 RPA Operations conducted on / over JCU Property
RPA operations on / over JCU premises must have prior written approval. Permission and approval to fly over JCU premises must be sought by emailing firstname.lastname@example.org. Type 3 Operations (less than 250g RPA’s operated for educational purposes) are exempt from this requirement.
2.12 RPA not owned by JCU
RPAs that are not owned by JCU must not be used over JCU premises and/or by JCU staff / student / volunteers conducting JCU work / research / study.
Where contractors are engaged for specific JCU RPA tasks, copies of CASA licenses, ReOC certificates, insurances, safety plans and CASA approvals will be sent to JCU insurance for approval.
2.13 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.
Related policy instruments
Related forms and registers
JCU Pilot Register
JCU RPA Register
Other related documents and legislation
NOTE: Printed copies of this procedure are uncontrolled, and currency can only be assured at the time of printing.
Deputy Vice Chancellor, Services and Resources
Date for next Major Review
Procedure updated in accordance with legislation changes. Addition of Type 3 Operations and change of titles for operators of RPA and MA (Licensed Pilots / Accredited Operators / Fun Flyers).
Principal Technical Advisor, WHS Unit and Advanced Analytical Centre, Senior Research Officer
Major review. Procedure arranged and amended in accordance with legislation changes.
Principal Technical Advisor, WHS Unit
Amended to reflect changes in legislation.
HSE System Officer
HSE System Officer
Remotely piloted aircraft, RPA, Drones, Model Aircraft