Recordkeeping and Reporting Procedures

Recordkeeping and Reporting Procedures

Draft prepared with Paperwing from the proposed Part 108 rule (90 FR 38212). Check it against the final rule before you submit.

This document applies to all aerial survey operations that Mesa Ridge Aerial Survey ("the Company") flies under its proposed Part 108 operating permit. The operations supervisor, Confirm: operations supervisor name, owns this process and is the Company's FAA point of contact.

Records kept and retention periods

The Company keeps the records below. Each retention period starts on the date the record is created, or on the date of the flight for flight records. If one record serves two purposes, the Company keeps it for the longer period.

Tailoring to this operation

• Coordinator ratio. The Company plans to fly 3 aircraft per flight coordinator, which equals the manufacturer's maximum ratio of 3. Flight records must show which aircraft each flight coordinator controlled, so the Company can show that no flight exceeded 3. The Company will keep its FAA-acceptable method for multiple aircraft per coordinator on file once the FAA accepts it.
• Experience minimums. Personnel records must show each flight coordinator's 5 hours on Confirm: aircraft make and model and 5 hours in the preceding 12 calendar months.
• Population Category 2. The Company keeps a record that its command-and-control link does not use an unlicensed Part 15 radio, Confirm: radio model and frequency band. It also keeps a dated record of each survey area's population category check against the LandScan USA data refreshed each August 1.
• Airspace. The Company flies outside controlled airspace and at Category 2, so it does not currently use a proposed Part 146 automated data service provider. If it starts using one, it will keep that provider's deconfliction and conformance records with the flight records.
• Hazmat. The Company does not carry hazardous materials, so it does not keep hazmat training records.

Supporting records (Company policy). The Company also keeps the records below for the permit's 24-month validity plus 24 months:

• copies of every report sent to the FAA, with receipts
• the aircraft's airworthiness acceptance (manufacturer declaration of compliance)
• annual cybersecurity policy reviews

Monthly aggregate flight data

The Company sends aggregate flight data to the FAA at least one time each calendar month. The operations supervisor is responsible for this report.

1. On the first business day of each month, export the flight records for the previous calendar month.
2. Use Confirm: flight log software name for the export.
3. Make sure each flight record shows the date, flight time, aircraft serial number, and flight coordinator.
4. Count the total flights, total flight hours, and number of aircraft that flew.
5. Add the data fields that the FAA specifies: Confirm: FAA data fields and format.
6. Make sure no flight coordinator controlled more than 3 aircraft at one time.
7. If a flight record shows more than 3 aircraft for one flight coordinator, tell the operations supervisor immediately.

CAUTION: Do not delete or change the original flight records. Changes to the original records can cause permanent data loss.

8. If a flight record is not complete, write the correction in a separate correction log.
9. Get the approval of the operations supervisor before you send the report.
10. Send the report to the FAA through Confirm: FAA submission method.
11. Keep a copy of the report and the FAA receipt with the flight records.

Annual list of aircraft registration and serial numbers

The Company sends a list of its aircraft registration numbers and serial numbers to the FAA at least every 12 calendar months. The Company flies up to 6 aircraft at one time. The list must show all aircraft in the fleet, Confirm: total fleet size.

1. Put the send date, Confirm: annual send date, in the Company compliance calendar.
2. Thirty days before the send date, get the current aircraft list from the maintenance records.
3. Do a physical check of the data plate on each aircraft.
4. Make sure the serial number on each aircraft agrees with the maintenance records.
5. Make sure each aircraft has a current FAA registration.
6. Make sure each aircraft broadcasts Remote ID.
7. Make sure each aircraft model has FAA airworthiness acceptance.
8. Write the list as a table with registration number, serial number, and Confirm: aircraft make and model.
9. Show the aircraft that the Company added or removed since the last list.
10. Get the approval of the operations supervisor.
11. Send the list to the FAA through Confirm: FAA submission method.
12. Keep a copy of the list and the FAA receipt.
13. If the Company adds or removes an aircraft, update the master list within 5 business days.

Event and emergency deviation reports (10 days)

The Company sends a report to the FAA within 10 days after an event or an emergency deviation. This procedure uses the FAA definitions of these terms, Confirm: final rule definitions. The Company target is 7 days, which gives a margin before the limit.

WARNING: A damaged aircraft battery can catch fire. Keep people away from the aircraft until it is safe.

1. If an event or emergency deviation occurs, make the affected aircraft safe.
2. Make the other aircraft of that flight coordinator safe before you do the next step.
3. Tell the operations supervisor immediately.
4. Save the ground control station logs and the command-and-control link logs.
5. Write the time, location, aircraft serial number, and flight coordinator name.
6. Get written statements from the flight coordinator and other crew within 24 hours.
7. Write the report on Confirm: FAA report form or method.
8. Get the approval of the operations supervisor.
9. Send the report to the FAA within 10 days after the event.
10. Write the send date in the event log.
11. Keep the report, statements, and logs with the flight records.
12. If the event shows a procedure problem, update the procedure and train the crew.

The operations supervisor holds final authority. If the operations supervisor changes, the Company tells the FAA within 10 days.

Security occurrence reports (96 hours)

The Company sends a security occurrence report within 96 hours. The Company also reports cybersecurity breaches within 96 hours. The definition and the start of the 96-hour period come from the final rule, Confirm: definition and start point. The Company target is 72 hours.

Possible occurrences for review include theft of an aircraft, access to a ground control station without permission, and threats to crew.

WARNING: Do not approach a person who threatens the crew. Move to a safe area.

1. If a person is in danger, call 911 before you do other steps.
2. If you find a possible security occurrence, tell the operations supervisor immediately.
3. Write the time that the Company found the occurrence.
4. Keep the aircraft, ground control station, and logs in their current condition.
5. If the occurrence affects Company computers or data, tell Confirm: cybersecurity lead name.

CAUTION: Do not turn off the affected ground control station. A shutdown can erase evidence in its memory.

6. Disconnect the affected ground control station from the network.
7. Write the report on Confirm: form and recipient, FAA, TSA, or both.
8. Get the approval of the operations supervisor.
9. Send the report within 96 hours.
10. Keep a copy of the report and the receipt.
11. After you send the report, do a review of the Company cybersecurity policies.

The Company also reviews its cybersecurity policies at least one time each year.

Storing and producing records on request

Where records live. The Company keeps all records electronically in Confirm: records system name. Paper originals, such as signed statements, are scanned within 2 business days and kept in Confirm: physical storage location.

Protection. Only the operations supervisor and staff the operations supervisor names can access the system. Access follows the Company cybersecurity policies. The system is backed up daily to Confirm: backup location, which is separate from the main system.

Organization. Records are filed by type: flight, maintenance, aircraft life, personnel, duty and rest, reports, and security. Within each type, records are filed by date and then by aircraft serial number or person. This lets the Company find any record quickly.

Producing records when the FAA asks

1. The operations supervisor receives the request and logs the date, the requester, and the records requested.
2. The operations supervisor collects the records and checks that they are complete.
3. The operations supervisor sends the records in the format requested, or makes them available for inspection at Confirm: Company address.
4. The Company logs what it provided and when.

The Company's target is to produce records within Confirm: Company target, for example 2 business days. This is a Company goal, not an FAA deadline.

Disposal. Each quarter, the operations supervisor reviews records that have passed their retention period and deletes them. Records tied to an open event, security occurrence, or FAA inquiry are kept until that matter closes, even if their retention period has passed.

Permit renewal. The operating permit is valid for 24 months. Before renewal, the operations supervisor confirms that every monthly report and annual aircraft list for the permit period was sent and filed.