Response 106456744

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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
Ticked I agree
I do not agree (please specify why below)
Comments
I was presuming for 12.01 (3), perhaps incorrectly, that CASA were going to supply a registration identification number for each registered RPA. For consistancy, surely the use of a single CASA provided registration number would be simpler than trying to work out what serial number belongs to what registered drone when being queried by authorities.

Regarding 13.01 and in keeping with overseas regulations, would it not be a good idea to display this registration number on the outside of the RPA, allowing a single registration identification mark to be used both by domestic and visiting RPAs. A registration mark including the identity of the home country (i.e VH-nnnnnnn) could then be used internationally, encouraging the global use of a single registration mark rather than having to display multiple registrations for different countries. This would result in less objections from users to having to affix multiple registrations to the outside of their RPA.

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
It needs to be spelt out in 1.04 (2) that the registered gross weight on take-off must be greater than the RPA plus any combination of attached optional equipment such as camers/lens, parachute systems, flotation devices, navigation lights, etc. Any additional equipment that causes the RPA to exceed the registered gross weight on take-off will be concidered to be an "unacceptable modification".