Response 252324000

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Mann

Do your views officially represent those of an organisation?

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UAVAIR

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
Currently "The first proposed transitional provision will allow any student who commenced a RePL course
on or after 3 April 2020 and before 10 October 2020, will have, under the relevant syllabi as is in
force before 10 October 2020, until not later than 31 January 2021, to complete all aspects of
the course including examinations and assessments"

As UAVAIR delivers to over 300 plus RePL training to students in High Schools during term 4. (October till December ).

If the flight test is cancelled due to weather or other reasons then the flight test is normally postponed to the next school year.

UAVAIR recommends extending the transition date the 30th June 2021


UAVAIR also feels that the intention to extend MOS paragraph 2.30 (2) (c) in Division 2.7 RePL Training Course Instructors. is too long, uneccecy and does not enable quality RPAS training to start inline with the objectives of the MOSS. It also penalises thoes like UAVAIR who have invested in their staff to meet these requirements ( Even with COVID 19)
UAVAIR recommends extending the transition date to only the 30th June 2021

Question 2 - Do you agree that the Part 101 MOS amendments will not result in unintended consequences?

Please select one item
Ticked I agree
I do not agree (please specify why below)