Draft guidance for RPAS BVLOS operations

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.