CASA Consultation Hub

This consultation asked industry and stakeholders to identify any effects from implementing the proposed changes to the Part 60 Manual of Standards (MOS). The consultation has now closed, and a summary of the feedback is provided below.

About this consultation

Prior to the consultation, CASA had informal feedback from industry stakeholders indicating that the changes were appropriate and are welcome. CASA noted this feedback when developing the policy for the changes and, to gain perspective from the widest possible audience, undertook formal consultation.

The consultation asked respondents if the proposed changes provided sufficient time to make upgrades to upset prevention and recovery training (UPRT) capable devices and if it would present any safety issues. Further, the consultation asked if the addition of a CASA qualification system as a standard would lead to inadequate devices becoming qualified.

Respondents were also asked to provide input on any additional issues they would like considered by the post implementation review.

There was 1 response to the discussion paper. The respondent represented a flight crew training and checking organisation and requested their submission be confidential.

Summary of feedback

The respondent indicated they supported the change providing additional time to make the upgrades to UPRT capabilities. Of note, the respondent indicated that without the proposed change, operators would likely bear significant costs and would face other operational impacts. For example, the respondent highlighted that without the proposed changes, UPRT would not be able to be integrated into recurrent training (which is undesirable for both CASA and operators) and mandatory training would be outsourced to other countries.

Regarding the proposed addition of FSD-1 as a qualification standard, the respondent was also supportive. The respondent noted the significant costs required to meet the latest alternative qualification standard, which for an older device would be prohibitive, and would deliver additional training activities for UPRT.

Next steps

Overall, through the formal consultation survey and from informal feedback, industry stakeholders have strongly supported the proposed changes. As a result, CASA will now undertake to implement the changes for the Part 60 MOS to reflect the proposals.

We recently invited feedback on guidance material for remotely piloted aircraft operator’s certificate (ReOC) holders who conduct operations beyond visual line of sight (BVLOS).

We asked you to comment on:

• 5 BVLOS standard scenarios
• guidance material developed by CASA.

The documents consulted on were:

• Draft Standard Scenario application and documents – guidance material
• Draft AU-STS 1: Applicant response – BVLOS operations near a vertical object(s) with a controlled ground environment
• Draft AU-STS 2: Applicant response – BVLOS operations near a vertical object(s) with a sparsely populated ground environment
• Draft AU-STS 4: Applicant response – BVLOS operations in a remote area within 3 NM of a registered or certified non-controlled aerodrome
• Draft AU-STS 6: Applicant response – BVLOS operations in remote Australian airspace (below 400 ft AGL)
• Draft AU-STS 7: Applicant response – BVLOS operations in remote Australian airspace (400 ft AGL to 5000 ft AMSL).

Each standard scenario details:

• a type of operation
• the required operational mitigations
• information needed to apply to CASA.

These standard scenarios use the Specific Operations Risk Assessment (SORA) developed by the Joint Authorities for Rulemaking on Unmanned Systems (JARUS). The SORA is an internationally recognised risk assessment method.

We received 44 responses to the consultation:

• 18 ReOC holders
• 1 RPAS training organisation
• 9 commercial or professional RPAS pilots
• 2 sport or recreational drone pilots
• 2 government organisations
• 1 identified themself as ‘other aviation’
• 11 identified themselves as other, with backgrounds ranging from RPA manufacturing, technology development, and engineering.

Of the 44 responses received:

• 25 provided feedback for an organisation
• 19 provided personal feedback

CASA values the feedback from all respondents.

Your feedback

Responses to the consultation were positive. Most respondents found the standard scenarios either usable or requiring minor changes.

The feedback also revealed some common questions and themes about the scenarios. These included:

• whether a ReOC holder needs approval from CASA if an operation is carried out in alignment with a published standard scenario
• whether a 1:1 ground risk buffer is enough to ensure safe operations
• the definition and meaning of the 'J-curve'
• the impacts continuing evolution of the SORA will have on these scenarios in the future

In addition, several respondents commented on the IREX qualification needed to meet the aeronautical knowledge requirements in CASR 101.300 (4) (a).  It was noted that the IREX felt like an unnecessary burden for the standard scenarios and may not be fit for purpose. Safety concerns were also raised about electronic conspicuity requirements for non-remotely piloted aircraft.

We considered all feedback provided and incorporated or further clarified in this summary of consultation.

CASA approval is required for any BVLOS operation. The purpose of the standard scenarios is to lessen the time and resource burden on ReOC holders in the application process. The scenarios do not replace the need for a ReOC holder to seek CASA approval to operate BVLOS.

The 1:1 ground risk buffer detailed in the scenarios is the minimum buffer set out in the JARUS SORA. This buffer will not be suitable for all operations. The ReOC holder must show in their application that this buffer is enough or apply a larger buffer, where needed.

CASA acknowledges the documents provided did not define the term ‘J-curve’ in the context of the standard scenarios. This definition will be in the final versions.

The standard scenarios used the latest iteration of the SORA (at the time of publication). JARUS is continuing to develop and improve the SORA method. CASA will update the standard scenarios to align with the latest international standards and Australian regulations, when required.

CASR 101.300 (4) (a) mandates the remote pilot in command (RPIC) must hold an IREX qualification. This is beyond the scope of this consultation. This regulation was developed to allow medium and large RPA to operate BVLOS in the same airspace as piloted aircraft in the future. An IREX qualification would be essential to make sure these operations are safe. Some alleviations are already available in legislative instrument EX46/21. Separately, CASA is considering other pathways for remote pilots to gain the knowledge and skills needed for lower risk BVLOS operations.

We have noted feedback raised about the electronic conspicuity requirements for non-remotely piloted aircraft. This is beyond the scope of this consultation. 

What to expect

We will publish the final documents by the end of August 2021. Following their release, we will review the standard scenarios to find out if they have been useful guidance for BVLOS operations. We will make any updates or changes as required.

We will also aim to develop new scenarios based on your feedback. We will review the scenarios to ensure international consistency with our own standards and any new advice from JARUS.

Your feedback on the standard scenarios will be helpful in guiding the direction of the RPAS and Advanced Air Mobility strategic regulatory roadmap. This roadmap will aim to give industry a clear understanding of the future direction of RPAS regulations in Australia. The BVLOS standard scenarios are a step towards streamlining and improving the application process for complex operations in Australian airspace.

From 13 January 2021 to 10 February 2021, aerodrome and aircraft landing area operators, planning authorities, pilots, persons involved in the design, construction and operation of wind farms and wind monitoring masts and internal CASA personnel were invited to review and provide feedback on the suitability of guidance material on matters that should be considered when assessing a wind turbine development so that all necessary measures can be taken to protect aviation safety.

We received a total of 6 responses, all from different areas of industry. Three respondents consented to having their comments published, 2 did not give their consent and one respondent was a CASA officer.

Summary of feedback

Most respondents recommended changes that were editorial in nature.

Several matters were raised that required further consideration and clarification, including:

• Aeronautical studies commissioned by wind farm proponents can lack independence and down-play the extent and impact of the wind farm proposal on aviation activities. There is potential need for an independent accredited auditor to review aeronautical assessments to ensure non-biased assessments are being provided to CASA.
• Inclusion of more detail in the 'early review by proponent' stage to ensure proponents do not miss uncertified aerodromes and aircraft landing areas nearby to proposed sites.
• Providing clear guidance on what conditions and criteria CASA will base advice upon when aviation hazard lighting is recommended.

The need for the Department of Infrastructure, Transport, Regional Development and Communications to update the National Airports Safeguarding Framework Guideline D: Managing Wind Turbine Risk to Aircraft to reflect current windfarm technology was noted.

Next steps

All comments provided by industry have been carefully considered and where appropriate, incorporated into the AC. The AC 139.E-05 v1.0 - Obstacles (wind farms) outside the vicinity of a CASA certified aerodrome is now available on the advisory circular page of the CASA website.