Response 71912745

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CubePilot Pty Ltd

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?

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Ticked I agree
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?

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Ticked I agree
I do not agree (please specify why below)

General comments

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Comments
My only real concern is the “unacceptable modifications” section

We don’t deal with off the shelf RTF toys.

We do autopilots that are at the core of the majority of Non DJI RPAS in Australia and around the world.

The 20% of gross weight will simply change depending on payloads fitted.

I would think that a simple... if modified outside the terms of the vehicles operation manual should suffice here?

For example, a farm drone with a max takeoff weight of 25KG may have a tank that is half that load.. and may fly camera missions at 12KG etc.

Not to mention research and development work, where a vehicle can change completely from one flight to the next. Surely some R&D exclusions need to exist