CASA delays MOS transition for RPA Operators

In response to the current COVID-19 disruptions, CASA has delayed the record-keeping requirements introduced by the Part 101 Manual of Standards for RPA operators by six months.

The Part 101 Manual of Standards transition date slated for the 10th April 2020 is quickly approaching for all RPA operators. In the current times, many organisations are currently protecting themselves from the impacts of COVID-19. Yesterday (24th March 2020) the Civil Aviation Safety Authority announced an extension in the requirements to transition to the new record-keeping regime detailed in the Part 101 Manual of Standards. The extension is for a period of six months from the original date of 10th April 2020 giving a reprieve to those that have not adequately prepared to date. Remote Operator Certificates have also been extended for a period of six months

There are still components of the Part 101 Manual of Standards that will come into effect on the 10th April 2020 such as the changes to operating around aerodromes. These components still require changes to operational documentation to reflect the new requirements.

Current requirements see records kept for

  • Job safety assessments
  • Risk assessments
  • Aircraft flight times
  • Remote Pilot logs
  • Chief Pilot proficiency checks

These records are reasonably easy to maintain regardless of the method used to record them (paper or digital) and form part of the day to day activities of RPA Operators.

repl upgrades

The new record-keeping requirements introduced by the Part 101 Manual of Standards are similar to the present requirements but call for additional details to be recorded and dictate that records are kept for a minimum of seven years. The timeframe on its own makes a paper-based system burdensome on the RPA operator. The records that must be kept are:

RPAS operational release

The operational release is similar to the current requirement to prepare and keep a job safety assessment prior to operation commencement. The operational release involves a set of defined details that must be retained prior to the operation commencement. These details include

  • The nature and purpose of the operation
  • Unique RPA identifier
  • Remote Pilot Station for the operation
  • Dates and times of the operation
  • Location of launch and recovery
  • The maximum height above ground level of the operation including the maximum permitted height of the operation
  • Full name and Aviation Reference Number of any participating Remote Pilots
  • Full name and duties of any individual involved in the operation who is not a Remote Pilot (not applicable to <2kg operations)
  • Whether the operation is to be conducted Visual Line of Sight, Extended Visual Line of Sight or Beyond Visual Line of Sight
  • Any approvals that relate to the operation (not applicable to <2kg operations)
  • Certification the RPA is serviceable for the flight activity

The flight must not take place until a copy of the approved RPAS operational release has been provided to the Remote Pilot.

RPAS Operational log

The operational log forms an actual of the events that took place during the RPA operation. It includes all of the items previously recorded in the operational release as well as:

  • Flight route for Beyond Visual Line of Sight operations
  • Details of flight segments and heights at which the segment was flown
  • Whether the RPA was serviceable after the final flight of the day
  • Nature of any unserviceability

The operational release and operational log can be maintained as one document

Remote Pilot Log

The RPA operator is now responsible for ensuring Remote Pilot’s keep a Remote Pilot Logbook detailing accumulated flight time operating RPA. The log must also include:

  • Unique RPA identifier
  • Date, location and duration of each flight
  • Accumulated flight times for
      • Visual Line of Sight
      • Extended Visual Line of Sight
      • Beyond Visual Line of Sight
      • Night operations
      • Simulated flight times

RPAS technical log

The maintenance controller of an RPA operator must ensure that the following information is retained in relation to the maintenance of the RPAS:

  • Unique identifier
  • Minimum and maximum gross weight
  • Total flight time (component-time recording exists for RPAS >25kg)
  • Maintenance schedule (>2kg)
  • Maintenance carried out (>2kg)
  • Calendar date or total time in service of next maintenance item
  • Clearing of any defects recorded for the aircraft
  • Description, serviceability and limitations of fitted failsafe devices

Records of qualification and competency

Where a person performs a duty other than a Remote Pilot in relation to the safety of RPA operations (eg. observer) and gains a competency the following items are to be recorded

  • Record of the qualification or competency
  • A copy is to be issued to the person before exercising the priveledges of the qualification/competency

Chief Pilot records

The Chief Remote Pilot is responsible for the overall safety and compliance of the organisation and must keep records to that effect, including:

  • Records that demonstrate the Chief Remote Pilot is performing their duties
      • Ensuring compliance with applicable legislation
      • Maintaining a record of qualifications
      • Monitoring standards and proficiency fo each Remote Pilot
      • Maintaining complete and up-to-date operational documentation
  • Job Safety Assessments
  • Risk Management Plan (where applicable)
  • Operational flight plans where issued
  • A copy of any NAIPS, NOTAM or AIS briefing as produced for the operation
  • Details of any payload/cargo requiring special handling


drone apps for chief remote pilot

The quickest and easiest way to be compliant with the Part 101 Manual of Standards requirement is to use an off-the-shelf product which has the compliance built-in such as AVCRM.

Should an off-the-shelf product be used as part of compliance it needs to be integrated into the companies operational documentation and staff trained on its use. This is a reasonably straight forward process.


Now is a great time to review operational documentation to ensure compliance with the current regulations and changes coming with the Part 101 Manual of Standards. It is also a great time to determine if the current business structure is working as RPAS operations scale and travel restrictions limit on-site visits. Structures featuring Senior Base Pilots delegating components of the Chief Remote Pilot role, such as inductions and proficiency checks are often beneficial to larger or remote organisations.

Aviassist is here to help ensure your organisation is running as smooth and complaint as possible. We offer a range of training for Chief Remote Pilot/Senior Base Pilot (now available online live) as well as operational documentation updates, auditing and approval application services.

Check out the full course calendar Find Courses

Copyright © 2024 Aviassist Terms & Conditions ABN 98 164 557 877 CASA UOC # 0117 Powered by WordPress & WooCommerce Website by OX