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Remotely Piloted Aircraft (RPA) Flying and Management Policy

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Section 1 - Overview

(1) This Policy is designed to facilitate the management and use of Remotely Piloted Aircraft (RPA) or drones, over UNE’s Armidale Campus, the University’s associated rural properties, and research field sites (ie. University certified zones).

(2) This Policy recognises the University’s commitment to the use of innovative technologies such as drones to support academic research, teaching, management of facilities, and the promotion of corporate events, while providing a framework to ensure regulatory compliance with RPA and the Civil Aviation Act 1988 as well as Civil Aviation Regulations 1988. Application of the Policy, its associated Procedures and Fact Sheets (providing authoritative advice about specific aspects of drone flying in particular circumstances) further highlights this commitment and also provides reassurance about the University’s approach to the protection of personal information (images of individuals) and the health and safety of University Representatives, students, and members of the public.

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Section 2 - Scope

(3) RPA/drone flying will only be undertaken by RPA pilots authorised by the University's identified Remote Operator Certificate (ReOC) service provider. 

(4) RPA pilots flying under the auspices of the ReOC service provider and engaged to operate under approved UNE RPA operational projects, must hold the following:

  1. CASA issued Aeronautical Radio Operator Certificate (AROC);
  2. CASA issued Remote Pilot Licence (RePL); 
  3. Pass any CASA endorsed/required tests to accompany the use of RPAs;
  4. Undertake RPA type training and testing (with endorsed authority to fly) as required, to ensure pilot currency, competency and compliance within the imposed licence restrictions and conditions of the aircraft being flown;
  5. Undertake CASA approved RePL licence level upgrades to enable flight of RPA in a higher level weight category; and
  6. Any other CASA requirements that come into effect following the approval and publication of this Policy.

(5) The University prohibits the operation of any RPA over the UNE Armidale Campus and flight zones by anyone, including third parties, without the knowledge and endorsement of the ReOC service provider.

(6) RPA operation for the purposes of emergency and crisis management within UNE certified zones, is permitted by agreement with the ReOC service provider and UNE, under a strictly controlled standing arrangement to allow these operations to occur as required and for UNE to provide documentation after the event.

(7) Any RPA operated on campus or within University certified zones must be operated in accordance with all relevant CASA rules and regulations, and all other Federal State and local laws, rules and regulations.

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Section 3 - Policy

Provision of ReOC Services

(8) The ReOC service provider and any associated subcontractors providing support to approved UNE RPA operational projects must provide and use their own RPA equipment, as listed and registered for flight and maintenance within their own ReOC or ReOC service provider’s documentation. If a project requires the specific use of a UNE owned RPA, servicing and maintenance of the RPA will be outsourced to the ReOC service provider and undertaken in accordance with the provider’s requirements (except for delegated battery charging onsite by the RPA owner).

(9) The ReOC service provider will retain responsibility for setting up airspace, and for the logging and management of all RPA flights over University certified zones. All outdoor RPA flights must be approved in accordance with the ReOC’s Operations manual.

(10) It is the responsibility of the ReOC service provider to ensure UNE Safety, Security and Information is provided with information about impending RPA flights and where appropriate, any visits to UNE sites by third parties for RPA operations.

(11) Training associated with the Work Health and Safety of UNE Representatives involved with RPA operational projects, will be conducted by the University’s ReOC service provider.

Data and Intellectual Property

(12) Any data collected by an approved RPA pilot within an approved UNE RPA operational project remains the property of UNE. Additionally, UNE retains the Intellectual Property rights or an unlimited and unrestricted licence to use the material recorded and produced within the operational project in perpetuity.

(13) Unless of a sensitive or confidential nature, all materials recorded and produced within UNE RPA operational projects, conducted on or outside of a UNE certified zone, should be made available to evaluate suitability for the purpose, for marketing or promotion, and for the general use of the University.

(14) Any sharing of RPA data between areas of the University should be clearly articulated and agreed to prior to collection, and the ReOC service provider should be made aware of the arrangement for sharing to occur accordingly.

(15) In the event of a malfunction or incident involving an RPA, the RPA and mobile device used to fly it will be stored securely until such time as data captured during its operation can be downloaded for investigation. All data, including images and video captured on the onboard storage device and all telemetry recorded on the mobile device while the flight was in progress, will be made available to UNE and any investigative authorities as required for evaluation of the flight to assist in assessing the issues surrounding the flight.

(16) All data collected for approved UNE RPA operational projects is to be managed in accordance with the University’s Records Management Rule.

Procurement

(17) Procurement of all RPA equipment must be conducted in accordance with the UNE Procurement Policy and Procurement Procedures.

(18) All UNE owned RPAs (irrespective of size or cost) are to be registered with Financial Performance and Analytical Services, listed on the University’s asset register, and also be listed with the ReOC service provider (for service and maintenance).

(19) All UNE owned RPA will be issued with a unique asset registration label, which must be attached and displayed on the RPA at all times. This label must not be placed on top of the RPA, rather, it must be placed in a clearly visible location on the side or underside of the RPA. If the label becomes lost, damaged or unreadable, it must be replaced immediately.

(20) RPAs owned and maintained by the ReOC service provider must be registered to the provider, or, in the case of subcontracting arrangements, to third-party provider companies. All RPAs operated by organisations external to UNE must be clearly labelled in accordance with the RPA’s owner company, identifying the ARN of the RPA owner as a minimum requirement.

Insurance and Liability

(21) The ReOC service provider is responsible for ensuring appropriate insurance cover is in place for pilots and any equipment owned and used by their company in the provision of RPA services to UNE. Insurance will be arranged by the ReOC service provider at their own cost. The service provider will provide proof of cover to UNE in the form of a liability certificate of currency to the agreed value determined between the ReOC service provider and the University’s Financial Performance and Analytical Services area.

(22) UNE will be responsible for insuring its own RPAs and associated equipment.

Privacy and Workplace Surveillance

(23) RPA pilots are prohibited from operating RPA to conduct workplace surveillance or to collect, store or use personal information about individuals (including images) that would contravene the University’s Privacy Management Plan in any way.

Authority and Compliance

(24) Compliance with this Policy and any of its associated documents ensures that RPA flying will be undertaken by approved RPA pilots operating under the auspices or with the approval of the University’s identified ReOC provider, supporting UNE RPA Operational Projects. This provides assurance that all pilots used are trained and licenced to a minimum required standard and known level of skill and competency, using equipment that is maintained under a defined system with record keeping and reporting capacity, and that all individual flights are ultimately approved by a CASA registered ReOC operator.

(25) Any use or operations of RPAs not in accordance with this policy, is prohibited. Non-compliance with this policy may result in legal or other action being undertaken by or on behalf of the University.

(26) The Vice-Chancellor and Chief Executive Officer makes this policy.

(27) University Representatives and students must observe it in relation to University matters.

(28) The University’s Chief Operating Officer as the Policy Administrator, is authorised to make procedures and guidelines for the operation of this University policy. The procedures and guidelines must be compatible with the provisions of this policy.

(29) This policy operates as and from the Effective Date.

(30) Previous policy documents and related documents relating to the operation of RPAs are replaced and have no further operation from the Effective Date of this new policy.

(31) Notwithstanding the other provisions of this policy, the Vice-Chancellor and Chief Executive Officer may approve an exception to this policy where the Vice-Chancellor and Chief Executive Officer determines the application of the policy would otherwise lead to an unfair, unreasonable or absurd outcome. Approvals by the Vice-Chancellor and Chief Executive Officer under this clause must be documented in writing and must state the reason for the exception.

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Section 4 - Definitions Specific to This Policy

(32) AROC means Aeronautical Radio Operators Certificate. This qualification is issued by CASA to an individual pilot upon successful completion of the required course.

(33) CASA – means the Civil Aviation Safety Authority of Australia, which is an independent statutory body, established to regulate civil aircraft operations in Australia and the operation of Australian aircraft outside of Australia.

(34) Drone – means the popular and widely accepted name applied to an RPA.

(35) ReOC means Remotely Piloted Aircraft Operator’s Certificate. This certification is issued by CASA to an organisation, which authorises that organisation’s Chief Pilot, to evaluate and approve an RePL holder’s application for individual flights, and maintains a central register of those approved individual flights. ReOC is the official term applied by CASA.

(36) RePL – means Remotely Piloted Aircraft – Pilot Licence, or more simply, Remote Pilot Licence. This qualification is issued by CASA to an individual pilot upon successful completion of the required course. RePL is the official term applied by CASA.

(37) RPA – means Remotely Piloted Aircraft, usually either a fixed wing or multirotor format, which is also popularly referred to as a drone. RPA is the official term applied by CASA.