Proposed policy amendments to Part 101 MOS registration, accreditation and transitional provisions - (CD 2014US)

The Part 101 MOS amendments are not clear and concise and as such will not be understandable to many stakeholders. Both the RPAS Industry and model aircraft flyer are regarding it as the continued "over-regulation” by CASA.

There is no evidence of the need of the proposed increased layers of regulation that will increase compliance costs associated with compliance and for what many may view as ambiguous and or unnecessary, for example for the new CASA approvals etc regarding model aircraft 20% modification. Again we are not aware of any evidence of this ever being a safety mater. However there evidence showing over regulation that is not clear is can create safety risks.

Questions that must be addressed by CASA in responding to industry and stakeholders:
1. On what evidence and safety case is CASA basing the need for more regulations as pursuant to the policy amendments to Part 101 MOS?
2. What are the performance indicators and or criteria CASA uses to justify the increase in regulations, administrative burden and costs to the RPAS industry and model aircraft flyers as well as CASA themselves?
3. How is CASA meeting their obligation of industry and stakeholder consultations going forward?