Operator, Pilot-in-command and UAS Crew

The contribution analyzes the legal framework for Unmanned Aircraft Systems (UAS) in the European Union, specifically through EU Regulation 2019/947. It explores the roles of the operator, the pilot-in-command (PIC), and the supporting crew, highlighting the regulation's risk-based and proportional approach. Key themes include: The UAS Operator: Defined as the central entity for organizational safety and compliance, the operator is responsible for systemic tasks like risk assessment, personnel training, and aircraft maintenance. This role is compared to the "accountable manager" in traditional aviation. The Remote Pilot-in-Command: While the operator manages the system, the PIC retains ultimate authority for the safe conduct of the flight. The analysis traces the legal evolution of the PIC from maritime and early aviation standards (like the 1919 Paris Convention) to modern remote operations. The "Lost Definition" of Crew: A significant gap exists in EU regulation, which lacks a formal definition for "UAS crew". This shifts the burden to the operator to define roles (such as observers or payload operators) within their own operations manuals. This flexibility contrasts with more rigid emerging ICAO standards. The Autonomous Frontier: The paper examines the coming paradigm shift from "automatic" to "autonomous" operations. As Artificial Intelligence (AI) begins making real-time safety decisions, the role of the human pilot may evolve from a direct controller to a "system supervisor," necessitating a major re-evaluation of liability and accountability frameworks. The contribution concludes that while the current EU framework is scalable, the rise of autonomy will require updated definitions and legal standards to maintain safety and clarity in a global aviation ecosystem