Response 244994275

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Personal information

Last name

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Roche

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)
Comments
If you ask for too much information you will likely get nothing, defeating the purpose of the recording exercise. No matter what kind of aircraft is being operated, time is important in order to operate safely and effectively. This level of data collection will decrease the safety of UAV operations by distraction.
It would appear this amendment is more about litigation than safety.
Competent piloting and situational awareness are the most important factors for safe operation of UAVs. Crashes are not as critical for UAVs as collisions. Awareness of other aircraft is especially crucial, considering the pilots vantage point, on the ground. Distraction from these two tasks by excessive tick lists, will cause a decrease in safety stands.

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
The intention should be Air Safety. Do you believe being less concise will improve the CASA objective?

General comments

Do you have any additional comments about the proposed policy?

Comments
The purpose of these changes would appear to be higher accountability and not safety. While this understandable the methodology is not demonstrably correct. Practical scenarios based on experimental piloting in a variety of situations, with a disregard for lay experts, would deliver much better stand procedure requirements.