Research and development pathways for uncrewed aircraft operations – (DP 2521US) - Feedback on research and development pathways for uncrewed aircraft operations Discussion Paper 2512US - Civil Aviation Safety Authority

General

Question 1. Does this Discussion Paper (DP) accurately reflect industry concerns?

Yes No

If you have selected ‘no’, please provide details as to points that you consider are incorrect or misinterpreted, and include information about relevant issues that have not been covered in the paper.

R&D pathways for micro, very small, small and medium Remotely Piloted Aircraft (RPA)

Question 2. What are the challenges that industry participants conducting R&D operations with micro, very small, small and medium RPA have experienced with the ReOC framework, including, what you have observed or experienced to be overly burdensome requirements that may be viewed as adding minimal safety benefits?

Comments

Authorisation

Question 3. Do existing authorisation arrangements described at paragraphs 4.1 – 4.4 of the DP pose any barriers to R&D operations?

Yes No

If you have selected ‘yes’, please elaborate on the barriers that you face and any amendments to the framework that you consider could address these barriers.

Registration

Question 4. Do existing registration requirements described at paragraph 4.5 of the DP pose any barriers to R&D operations?

Yes No

If you have selected ‘yes’, please elaborate on the barriers that you face and any amendments to the framework that you consider could address these barriers.

Information and Guidance

Question 5. Is there sufficient industry awareness of how R&D operations are enabled, and may be conducted, under the current Part 101 of the Civil Aviation Safety Regulations 1998 framework?

Yes No

If you have selected ‘no’, we welcome suggestions on how CASA can improve industry awareness regarding available pathways for R&D operations.

Streamlined regulatory requirements for a greater range of R&D operations

Question 6. Do you agree that the initiatives described at paragraph 5.2 of the DP would improve pathways for R&D operations?

Yes No

Question 7. What are other broad initiatives that CASA could focus on to support and enable R&D operations within our remit as the aviation safety regulator?

Comments

Expanding the small RPA excluded category

Question 8. Do you support the expansion of the small RPA excluded category (paragraph 5.3 of the DP) so that RPA heavier than 2 kg but not heavier than 25 kg, could be flown as ‘excluded RPA’ for renumeration: within standard operating conditions of either or both options below.

Without a ReOC or a RePL over land that is owned or occupied by the RPA owner. The remote pilot would need to hold RPA operator accreditation (as is currently the case).

Yes No Not applicable to me

Please explain reasons for your selection

b. Without a ReOC but with a RePL if the RPA is operated over land that is not owned or occupied by the RPA owner.

Yes No Not applicable to me

Please explain reasons for your selection.

Guidance for new and complex applications

Question 9. What additional steps can CASA take to assist applicants seeking advice on pathways for novel or advanced R&D operations (paragraph 5.5 of the DP)?

Comments

Sandboxes

Question 10. Do you agree the sandbox type arrangements discussed in Chapter 6 of the DP meet its objectives of supporting industry and regulatory innovation?

Yes No

If you have selected ‘no’, please explain where the gaps are and what CASA could do differently.

Improvements to regulatory arrangements for flight testing

Question 11. If the initiatives described in Chapter 4 and Chapter 5 of the DP are implemented, are there still procedural barriers that are unduly onerous and disproportionate to the safety risks that should be addressed to support public flight test facilities?

Comments

Question 12. What are the types of operations that you are likely to conduct at a public flight test facility and what are your expectations of CASA’s approval processes for these operations?

Please indicate ‘not applicable’ if you don’t expect to use a public flight test facility.

Not applicable

Comments