RPAS Pilot-in-Command

RPAS Pilot-in-Command


This article examines three interrelated topics:

  • Training of new remote pilots to fly remotely piloted aircraft systems (RPA/RPAS), known as small unmanned aircraft systems (sUA/sUAS) in some countries;
  • The role and responsibilities of the experienced remote pilot who qualifies to serve as a remote pilot-in-command (RPIC) of RPAS; and,
  • Attributes and duties that distinguish the RPIC from the pilot-in-command (PIC) of a multicrew manned aircraft.

In many professional settings, RPICs accept responsibility for nearly all risk mitigation during a specific RPAS mission. Similar to captains of commercial air transport aircraft, they primarily manage flights while remote pilots (and less qualified pilots) directly manipulate the flight controls and adjust the RPA’s level of automation/autonomy under the RPIC’s command.

In complex missions, several crewmembers follow the RPIC’s instructions and commands. The RPIC’s crew may include a remote pilot directly operating the RPA (as noted); one or more RPICs standing by to accept handover of the entire mission; one or more visual observers; a mission payload operator/sensor operator; subject matter experts who advise the RPIC, and perhaps an operator’s observer.

Civil aviation authorities (CAAs) that have implemented this distinction in crewmember authority use alternative terms. For example, the U.K. CAA defines an RPAS commander as “a trained and competent person who is responsible for the conduct and safety of a specific flight and for supervising the person in direct control of the RPAS. His duties are equivalent to those of an aircraft commander.”

Regarding RPIC training and licensing, EUROCONTROL said in 2012 specifications for military RPA flights in non-segregated civilian airspace that “training for an RPA pilot-in-command will depend primarily upon the capability of an RPA and its mission profile.”


In a 2011 ICAO circular, ICAO stated — predicting military RPICs — that, “The pilot-in-command of a manned aircraft is responsible for detecting and avoiding potential collisions and other hazards. … The same requirement will exist for the remote pilot of an RPA. Technology to provide the remote pilot with sufficient knowledge of the aircraft’s environment to fulfil the responsibility must be incorporated into the aircraft with counterpart components located at the remote pilot station.”

The Eurocontol specfications cited above said, “Notwithstanding any pre-programmed mission autonomy, the primary mode of operation of an RPA for the purposes of ATM [air traffic management] should entail oversight by the [RPAS] pilot-in-command, who should at all times be able to intervene in the management of its flight. However, in the event of total loss of control data-link between the pilot-in-command and the RPA, a back-up mode of operation should enable the RPA to revert to autonomous flight that is designed to ensure the safety of other airspace users.”

ICAO standards and recommended practices include the following definitions:

  • Remotely-piloted aircraft system (RPAS) — A set of configurable elements consisting of a remotely-piloted aircraft, its associated remote pilot station(s), the required command and control links and any other system elements as may be required, at any point during flight operation. (ICAO Circular 328, Unmanned Aircraft Systems);
  • Remotely piloted aircraft (RPA) — An unmanned aircraft which is piloted from a remote pilot station [i.e., operated with no pilot on board and] expected to be integrated into the air traffic management system equally as manned aircraft [and for which] real-time piloting control is provided by a licensed remote pilot. (ICAO Annex 2, Rules of the Air)

According to The ICAO UAS Toolkit website, the typical RPAS comprises:

  • An RPA;
  • Human-operated remote pilot station(s) usually located on the ground or on a ship, but which may be aboard another airborne platform; and,
  • A command and control system — sometimes called a communication, command and control system — that includes data links and other system elements (e.g., instruments and transponders on satellites and/or terrestrial cable networks) that connect the remote pilot station(s) to the RPA.

PIC Concept for Manned Aircraft

For manned aviation, the European Union Aviation Safety Agency (EASA) defines the following roles in its Pilot-in-command responsibilities and authority document:

  • Pilot-in-command (PIC) — The pilot-in-command is responsible for the operation and safety of the aircraft and for the safety of all crew members, passengers and cargo on board. … For aeroplanes, [PIC responsibility lasts] from the moment the aeroplane is first ready to move for the purpose of taxiing prior to take-off, until the moment it comes to rest at the end of the flight and the engine(s) used as primary propulsion unit(s) is/are shut down).

RPIC Concept for RPAS

The U.S. Federal Aviation Administration (FAA) elaborated on its perspective of RPICs at a workshop titled “Pilot-in-Command Certification and Responsibilities,” part of the FAA UAS Symposium 2017, co-hosted by the FAA and the Association for Unmanned Vehicle Systems International (AUVSI).

The workshop focused on RPICs in relation to Federal Aviation Regulations (FARs) Part 107, Small Unmanned Aircraft Systems [sUAS]:

  • The responsibilities of the RPIC were summarized as “fly responsibly” — meaning “register your aircraft, preflight the aircraft and crew, assess the operating environment, designate the PIC and ‘be the PIC,’ adhere to operational rules, and fly safe.”
  • An RPIC’s preflight familiarization with each mission should cover local weather conditions, airspace and flight restrictions, location of people and property, and any ground hazards. This includes the preflight briefing and post-flight briefing of the mission crew about the operating conditions, emergency procedures, contingency procedures, roles and responsibilities, and potential hazards.
  • An RPIC ensures that all control links are working properly, there is enough available power, and that anything attached or carried is secure and does not adversely affect the flight characteristics or controllability.
  • According to another presentation, FAA’s policy is to trust the remote pilot who qualifies for a given mission “to accept responsibility for and [be] the final authority as to the operation of the UAS; to ensure the aircraft will not harm people, property or other aircraft in the event of a loss of control; to adhere to all applicable [FARs]; and to be able to direct the sUAS to ensure compliance with [FARs]. … The RPIC may deviate from any rule to the extent necessary to address an in-flight emergency requiring immediate action.” No RPIC may “operate in a careless or reckless manner so as to endanger the life or property of another.”
  • RPIC training, education and compliance has to be combined with maintaining good health, pursuing professional knowledge, being fully in control, making good decisions, and exercising a high degree of responsibility and command authority that lives up to airline passengers' safety expectations of captain-PICs.

Risks in Flying RPAs

EUROCONTROL described in 2012 the following risk factors and practical challenges for RPICs related to the inherent differences of manned vs. unmanned aircraft systems. The researchers’ case study anticipated that military RPICs increasingly would fly outside segregated airspace, suggesting the following issues:

  • “Effective traffic avoidance and collision avoidance probably represent the greatest technical challenge confronting the routine operation of RPAs outside segregated airspace. The hierarchy for the application of traffic avoidance and collision avoidance for an RPA should be: ATC — traffic avoidance, pilot-in-command — traffic avoidance and collision avoidance, and autonomous operation — collision avoidance;
  • “The rules for VFR flight pose a problem for an RPA insofar as it may be difficult for the [RPIC] to assess whether the visibility and distance from cloud equate to VMC [visual meteorological conditions]. If an RPA is unable to establish that it is in VMC, it could fly IFR [under instrument flight rules] if properly equipped, although this would constrain its freedom of operation;
  • “[The RPIC] will require technical assistance to detect and avoid conflicting traffic with the same degree of assurance as a manned aircraft flying VFR. Thus provided for, he could then be responsible for the safe conduct of a flight, unless loss of control data-link made it impracticable, at which point an automatic system would take over to ensure collision avoidance;
  • Sense-and-avoid technology — performing a collision-avoidance function autonomously if traffic avoidance has failed for whatever reason — “is essential to the safe operation of RPAs outside segregated airspace;
  • “Where an RPA pilot-in-command is responsible for separation, he should, except for aerodrome operations, maintain a minimum distance of 0.5 nm horizontally or 500 ft vertically between his RPA and other airspace users, regardless of how the conflicting traffic was detected and irrespective of whether or not he was prompted by a [sense-and-avoid] system;
  • “RPA emergency procedures should mirror those for manned aircraft wherever possible. [RPA exceptions] may include use of an emergency recovery procedure or a flight termination system, either autonomously or managed by the RPA pilot-in-command.; and,
  • “When an RPA is not operating under the control of its pilot-in-command, the latter should inform the relevant ATC authority as soon as possible, including details of the contingency plan which the RPA will be executing. In addition, the [RPA itself] should indicate such loss of control to ATC.”

Examples of RPIC Responsibilities

An ICAO manual cites the following examples of RPIC duties unlike those familiar to PICs of manned aircraft:

  • The RPIC is responsible for immediately terminating the flight of an RPA upon deciding that this action is warranted by events, circumstances or reassessment of risk;
  • The RPAS operator should have Standard Operating Procedures (SOPs) that assign responsibility to the RPIC for ensuring that any type of handover of the RPAS adheres to procedures in the operations manual and/or flight manual; and,
  • The RPIC’s assignments should explicitly specify responsibility for updating all documents after each flight segment (i.e., the RPA journey log book and RPAS maintenance logs).

In the United States, FARs Part 107 specifies that an RPIC must be designated before or during the flight. The RPIC is “directly responsible for and is the final authority as to the operation of the sUAS,” and the RPIC must ensure that the sUA will pose no undue hazard to other people, other aircraft or other property in the event of a loss of control of the aircraft for any reason.

The RPIC also must ensure that the visual observer is able to see the sUA in the manner described in the rules. Also, the RPIC, any person (such as a remote pilot) who manipulates the flight controls of the sUAS, and the visual observer “must coordinate to … scan the airspace where the sUAS is operating for any potential collision hazard, and maintain awareness of the position of the sUA through direct visual observation.”

Part 107 also states, “A person may not operate or act as a remote pilot in command or visual observer in the operation of more than one unmanned aircraft at the same time.”

Accidents and Incidents

  • Loss of control involving remotely piloted aircraft Pulse Aerospace Vapor 55, UAV0734, 4 km NE of Ballina/Byron Gateway Airport, NSW, on 28 September 2016. According to the Australian Transport Safety Bureau (ATSB Investigation AO-2016-128): “A Pulse Aerospace Vapor 55 remotely piloted aircraft was operating a test flight at Lighthouse Beach, Ballina, NSW. After flying using manual inputs from the pilot for about seven minutes, the data-link signal was lost. Thirty seconds later, the aircraft entered the ‘home’ flight mode, and commenced tracking to the programmed home position at an altitude of 154 ft.

“However, rather than tracking where the pilot expected, the aircraft headed NNE of the start position. In the home flight mode, the aircraft did not respond to the control inputs made by the remote pilot, and the pilot subsequently lost sight of it. The aircraft was not found despite an extensive search.”

  • Loss of operator control involving an Aeronavics SkyJib 8 remotely piloted aircraft near the Melbourne Cricket Ground, Melbourne, Victoria, on 29 March 2015. According to the ATSB Investigation AO-2015-035: “The RPAS was operating as part of the media coverage of the International Cricket Council World Cup Final at the Melbourne Cricket Ground. About two minutes into the flight, with the Aeronavics SkyJib 8 RPAS over the northern roof of Hisense Arena, the operating crew lost control of the aircraft. “The crew commenced alternate recovery procedures, but were unable to re-establish control. The aircraft ultimately collided with terrain just to the south of Rod Laver Arena. There were no injuries to people on the ground, and no damage to other property, but the aircraft and associated equipment were substantially damaged.”

Best Practices for RPICs

According to best practices described in 2017 for RPAS missions inspecting infrastructure of U.S. electric utility companies, RPICs prepare and conduct crew briefings for complex missions based on:

  • A safety checklist covering identified hazard details and mitigation actions such as “overall mission profile hazards, crew status check, no careless or reckless operations, no carriage of hazardous materials, populated area, vegetation, [tall] structures, traffic along roadways, birds and wildlife on the ground, manned and unmanned aircraft, and emergency situations;”
  • A contingency plan checklist covering “RPA battery depletion, ditching procedures, fuel deletions, hazardous weather, hostile environment [e.g., air traffic or public activity causes a hazard], loss of communications, loss of RPA control signal, loss of direct visual observation of RPA, loss of global positioning system signal, loss of situational awareness, privacy impacts [public complaint], and RPAS failure;”
  • An emergency contact checklist for normal missions and contingencies that reasonably can be envisioned, comprising:
    • An administrative checklist incorporating a brief mission profile, safety plan and equipment target review with imagery and maps/charts;
    • Risk mitigation rules for crewmembers, bystanders and crowds in the vicinity of the RPAS;
    • An environment and hazards checklist covering flight operating area, local weather conditions, clouds, precipitation, sun effect on visibility of RPA, temperature and local wind data;
    • An RPA preflight inspection checklist (including airframe, batteries, fuel, payload and gross weight; and,
    • A control systems checklist (including communications, navigation and accessories).
  • A flight operations–execution checklist with the following subsections:
    • Mission profile;
    • Route check for obstructions;
    • RPAS final launch preparations;
    • Final crew briefing for launch;
    • Software loading;
    • Power on to RPA, lights, datalink and control link;
    • Memory aids for flight path and instrument/sensor monitoring, mission termination with manual or automated return to base; and,
    • A mission-conclusion checklist for post-flight tasks, including securing data/imagery, flight logbook entries and RPA maintenance log entries.


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