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:
The documents consulted on were:
Each standard scenario details:
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:
Of the 44 responses received:
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:
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.
View submitted responses where consent has been given to publish the response.
CASA is developing guidance to help remotely piloted aircraft operator’s certificate (ReOC) holders wanting to conduct remotely piloted aircraft systems (RPAS) operations beyond visual line of sight (BVLOS).
We have developed several draft standard scenarios to provide clarity about the minimum evidence and information requirements.
We are seeking technical feedback on the first set of scenarios for:
These documents are:
How we assess risk
CASA assesses BVLOS applications using the specific operations risk assessment (SORA) process.
The SORA provides the minimum technical, operational and organisational requirements an operator must provide for an acceptable safety case.
The standard scenarios in the guidance material are intended for use by ReOC holders and cover RPAS operations that meet predefined criteria and comply with the methods and principles of the SORA.
SORA was developed by Joint Authorities for Rulemaking of Unmanned Systems (JARUS).
These guidance documents are applicable to RPAS operations in Australian airspace only.
CASA recognises the valuable contribution that community and industry consultation makes to the regulatory development process. For this reason, we are seeking feedback on whether the draft documents provide adequate guidance for the preparation of a BVLOS approval application across a variety of operational contexts and work as intended.
A copy of each draft guidance document is provided below and on the survey page alongside the question to which they are related.
It is important that you read the guidance documents before providing your feedback.
Comments should be submitted through the online response form.
What happens next
At the end of the response period for public comment, we will review each comment and submission received. We will make all submissions publicly available on the CASA website, unless you request your submission remain confidential. We will also publish a Summary of Consultation which summarises the feedback received, outlines any intended changes and details our plans for the guidance.
Feedback will be used to inform the final release of each standard scenario, which will be published to the CASA website. If significant feedback about a particular scenario is received, CASA may choose to conduct further consultation about that scenario. This may result in a delayed release for that scenario.
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