22 Jan Excluded Category Record Keeping – MOS 101
Excluded Category Manual Of Standards 101 (MOS101) – Record Keeping
Excluded category operators are permitted to utilise RPAs (remotely piloted aircraft or drones) up to 150kg in total weight to conduct commercial operations. The Civil Aviation Safety Authority (CASA) has provided clear guidance on how this can be achieved for micro RPA (100 g or less), small RPA (101g – 2kg) and for operators who want to operate an RPA larger than 2kg over their own land. This can be found on the CASA website along with excluded category record keeping requirements. The vast majority of excluded category operators will be utilising very small RPAs (101 g – 2kgs) in total weight to perform their commercial flights. However, landowners are permitted to utilise RPA with a greater overall weight of (2.01kg – 25kgs) and even RPA weighing (25.01kg – 150kgs) provided the owner, operator of the RPA holds a Remote Pilots Licence (RePL) or the operator flying on the owner’s behalf holds a RePL.
The Manual of Standards (MOS 101) comes into effect in coming months and includes some efforts to align the record-keeping of excluded category operations with licenced operators operating under an Operators Certificate (ReOC). It requires some excluded category record keeping as per the Manual of Standards (MOS 101). Firstly, the CASA portal supports the notification requirements laid out in MOS 101 Division 10.4 for excluded category operations. This is a compulsory step before operating any RPA within the excluded category. It is a notice to CASA that you intend to operate an RPA in the excluded category. An example of a notification is shown below which states you are required to have an electronic or hardcopy with you when you are out on a job. It also says that there is a 5 business day wait before the notification comes into effect.
(Credit: Civil Aviation Safety Authority, CASA)
In addition, excluded operators of small (2.01kg – 25kg) and medium (25.01kg – 150kg) RPAs are required to keep records in accordance with MOS 101 Division 10.3. For operations of very small RPA (between 101g – 2kgs), other than notification, there are no defined record keeping requirements for excluded operations. However, all operations must be conducted under the standard operating conditions often referred to as the SOC’s (A summary of the SOC’s can be seen below). CASA has provided a summary of the excluded record keeping requirements which is available on the CASA website.
Although there is no mandated requirement to keep records for RPA operations of a drone in the very small category (101g – 2kgs) there are benefits to keeping records. A technical log will benefit you if you try to sell an RPA as it shows how you have cared for your RPA. The pilot logbook records your RPA experience, how regularly you fly and what you have done which will assist if you decide to achieve your remote pilot’s licence or RePL into the future.
RPAS Operational Log
This must be kept for RPA that fall into the small category (2.01kg – 25kg) and medium category (25.01kg – 150kg) for at least 3 years. A simple table or spreadsheet, an example is shown below, could be kept for each flight to fulfil this requirement:
The operational log needs to be completed after the flight or series of flights that occurred on that day at the same location / operating area.
Remote Pilot Log
This is only mandatory for medium excluded RPA operations (RPA weighing between 25.01kg – 150kg) although this would be considered best practice no matter what category of RPA is flown. The operator must ensure that when flying a medium-sized RPA (25.01kg – 150kg) a remote pilot log is maintained to record his or her accumulated flight time operating excluded category RPA. This information has already been captured by the operational log. Therefore the remote pilot needs to maintain their logbook on a regular basis which is kept for at least 3 years. CASA has provided a CASA RPA Logbook format.
RPAS Technical Log
This is only mandatory for medium excluded RPAs operations (RPA weighing 25.01kg – 150kg). Again, a simple table or spreadsheet, an example is shown below, could be kept for each RPA to fulfil this requirement:
RPAS Excluded Category Record Keeping
The technical log needs to be kept for 7 years and be provided to CASA upon request or to a person requesting the log i.e. someone buying the RPA from you.
Where to Keep your records – Excluded Category Record Keeping
To complete these records will take the pilot approximately 5 minutes, if templates are set up in a system like google docs/sheets which is free, ensuring compliance. These records can be stored in paper or electronic form. Definition 5, shown below, has some requirements about electronic record-keeping that they must be unalterable. This could be a very simple, low-cost solution such as scanned records or PDFs stored to a cloud drive such as OneDrive, Google Drive, etc or at the other end of the scale an electronic documents management system for your fleet of drones. This will all depend on the size and scale of your excluded operation.
Finally, remember your notification is not valid forever and has to be updated every 3 years. You also need to keep your notification accurate by letting CASA know of any changes to your name, address, etc. within 21 days of them occurring.
Enjoy your safe and successful RPAS operations.
Manual Of Standards 101 (MOS 101) Chapter 10 Definitions for RPAS Excluded Category Record Keeping
- Configuration of an RPA mentioned in MOS 101 Chapter 10 is comprised of the RPA’s airframe, engines and motors, and all of the flight control system hardware for the RPA. Note: The configuration of an RPA does not include propellers, rotors or batteries.
- A Small excluded RPA is an RPA which has a gross weight of between 2.01-25kg.
- A Medium excluded RPA is an RPA which has a gross weight of between 25.01-150kg.
- The operation, for an RPA, means a single flight of the RPA, or a series of similar or related flights of the RPA on the same day.
- Record includes an electronic record but only when:
- the electronic record is created in a form that makes the record unalterable after the record has been made; and
- if an erroneous electronic record is created — the correction of the electronic record is in the form of an electronic record which identifies the error and corrects it.
- Unique identification mark for an RPA is the number and/or letters that the operator gives to each configuration of the RPA that he or she operates.
Summary of Standard Operating Conditions
The SOC’s are:
- You must be able to see the drone without the use of binoculars, FPV or similar equipment. The drone cannot be flown behind trees or buildings, or in clouds where you cannot see the drone.
- The drone must not be flown above 400feet / 120meters above the ground; if you fly off the top of a building you cannot fly 400feet / 120meters above the top of the building.
- You can only fly the drone during the day; dawn to sunset.
- You cannot fly within 30 meters of people, over the top of people or in a populous area.
- You can only fly 1 drone at a time.
- Don’t fly within 5.5km or in the approach and departure path of an airport that has an active air traffic control service (unless the flight is entirely indoors), in a restricted area (unless approved by the agency controlling the restricted area), or over an emergency operation (bushfires or flashing blue lights don’t fly there)
You need to understand the SOC’s in detail as there are some provisions which make some operations easier or by changing the drone size, you change the rules that apply. An RPA must never be operated in a manner that is hazardous to another person, vehicle or aircraft; so if you think the operation is a hazard to someone else do something to change the risk and be a safe responsible member of the drone industry.