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Australian Certified UAV Operators Association
Feedback on the proposed policy amendments to Part 101 MOS registration, accreditation and transitional provisions.
Question 1 - Do you agree that the Part 101 MOS amendments reflect the change in policy as set out in the summary of proposed change and will work as intended?
Please select one item
I agree
Ticked
I do not agree (please specify why below)
Question 2 - Do you agree that the Part 101 MOS amendments will not result in unintended consequences?
Please select one item
I agree
Ticked
I do not agree (please specify why below)
Comments
We refer to the amendment in respect of students enrolled in Remote Pilot Licence (RePL) courses between 3 April 2020 and 10 October 2020, having until 31 January 2021, to complete all aspects of the course under the syllabi as is in force before 10 October 2020.
We propose that:
(a) Chapter 2, other than paragraph 2.30(2)(c) in Division 2.7 be delayed until 30 June 2021, however training organisations approved by CASA under the new syllabi may provide training pursuant to the new syllabi once approved by CASA to do so.
(b) students enrolled between 3 April 2020 and 30 June 2021 have until 30 June 2021 to complete the course under the current syllabi.
CASA’s proposed delay to 31 January 2021 is too short in consideration of restrictions pursuant to COVID-19 which have caused significant delay and difficulties for both course providers and students.
We also understand that CASA is still in the process of approving the new syllabi of a number of training providers means that a date of 10 October 2020 for training providers to be offering training under the new syllabi is unsuitable as some training organisations will yet to have approval to teach under the new syllabi.
Moreover, school students who have had their courses delayed to date are likely to be unable to resume their course until 2021. With the new school terms commencing on or about 30 January 2021, these students will not have an adequate opportunity to complete their RePL under the current curriculum by 31 January 2021.