Proposed Part 101 Chief Remote Pilot Licence Instructor and other matters - (CD 2401US)

The Part 101 Manual of Standards (MOS) consultation was open for public consultation from 1 to 28 February 2024. The consultation sought feedback on:

• proposed Chief Remote Pilot Licence (RePL) Instructor (CRI) framework
• improved standards
• transitional requirements
• other minor amendments.

We received 14 submissions from a variety of remotely piloted aircraft (RPA) training organisations and operators.

About this consultation

We are proposing to amend the Part 101 MOS to provide:

• more fit-for-purpose standards
• flexibility within the RePL instructor qualification framework
• clarity of the requirements for RPA operations near aerodromes.

Feedback on these proposed changes was sought including:

• implementation and consequential matters
• impact to training organisations and their personnel
• any other issues that may arise from these amendments.

This consultation has now closed.

There were 14 responses. Nine respondents consented to CASA publishing their feedback, while 5 requested their submissions remain confidential.

The responses represented the remotely piloted community across: RePL training organisations (8), Remotely Piloted Aircraft Operator's Certificate (ReOC) holders (3), and RePL pilots/instructors (1), while 2 respondents marked themselves as ‘other’.

Eleven respondents stated they are representing an organisation, while 3 respondents identified as personal views.

Summary of feedback

In assessing whether industry agreed the proposed changes will benefit RePL training organisations and their personnel, 8 respondents expressed agreement, while 4 disagreed, and 2 respondents chose not to provide a response.

Feedback focused on issues relating to RePL training regulations specifically raising concerns regarding RPA global positioning system (GPS) requirements and advocating for transparent revisions to the syllabus. Recognition of overseas training providers was also highlighted.

Training organisations expressed concern that the introduction of the CRI position would impact resources due to internal changes and alterations required to manuals and training materials. While some respondents believe they already meet the requirements, others anticipate significant increases in workload. Three respondents expressed intent to nominate someone other than the organisations CRP for the CRI position.

We appreciate the valuable contributions made by industry and acknowledge the significance of the feedback to inform and shape the consultation process.

We intend to implement the introduction of the CRI position, along with the other proposed amendments consulted in CD 2401US - Proposed Part 101 Chief Remote Pilot Licence Instructor and other matters with the following changes:

Extended commencement date

Based on stakeholder feedback, we will provide RePL training organisations more time to prepare for the changes.

Commencement of the introduction of the CRI position is to be delayed to 10 July 2024.

The additional time will assist RePL training organisations to identify and review:

• qualification and experience requirements
• potential CRI candidates
• operational documentation requirements and amendments.

Alignment of deemed CRI requirement dates

We will simplify transition arrangements and align the deemed CRI qualification transition date to 10 January 2025. A person that is the deemed CRI will be required to hold qualifications and experience as prescribed in subsection 2.29A(3) of the amended Part 101 MOS by 10 January 2025.

Alternate qualifications recognition

We will also introduce an amendment to provide flexibility for us to assess and approve a person who does not hold the qualifications prescribed in paragraph 2.29A(3)(c) of the amended Part 101 MOS, based on their alternate qualifications and experience.

Next steps

We are committed to working with industry stakeholders to provide clarification on various aspects of the proposed changes, including:

• timeline of changes
• qualification requirements
• the assessment process for those involved.

We will communicate this information with training organisations and RePL holders and provide guidance.

We will consider incorporating a work program review that will be aimed at clarifying the proposed regulatory structure for RePL training and will have a focus on establishing clear standards and reassessing the syllabus.