Drone discussion paper - Review of RPAS operations (DP 1708OS) - Civil Aviation Safety Authority

Response 1032603864

Personal information

Do your views officially represent those of an organisation?

If yes, please specify the organisation:

Coptercam Pty Ltd

Should all RPA be registered?

Select your preferred registration options.

	None	Above a specific size/weight	For specific operations	All RPA
By RPA Please select all that apply	None Ticked None	Above a specific size/weight Above a specific size/weight	For specific operations For specific operations	All RPA All RPA
By RPA owner Please select all that apply	None None	Above a specific size/weight Ticked Above a specific size/weight	For specific operations Ticked For specific operations	All RPA All RPA
By RPA operator Please select all that apply	None None	Above a specific size/weight Ticked Above a specific size/weight	For specific operations Ticked For specific operations	All RPA All RPA

Please provide any additional comments:

Registration imposes a cost to all parties but does not reduce the likelihood or consequence of an accident involving an RPA. A rule requiring registration is likely to be ignored by those individuals who will not comply with existing safety regulations. Therefore registration will penalise those who are law abiding.

Should all RPA users be required to meet training / proficiency criteria?

Select your preferred training and proficiency options.

	None	Above a specific size/weight	For specific operations	All RPA
Training Please select all that apply	None None	Above a specific size/weight Ticked Above a specific size/weight	For specific operations Ticked For specific operations	All RPA All RPA
Demonstration of proficiency Please select all that apply	None None	Above a specific size/weight Ticked Above a specific size/weight	For specific operations Ticked For specific operations	All RPA All RPA

Please provide any additional comments:

RPA technology has evolved so far that pilot skill has little bearing with regard to competence to operate an RPA. In even of the RPA technology failing, there is little an remote pilot can do. A sensefly ebee is a good example of a automated drone there requires no model aircraft flying skills, just good planning skills. Clearly if a risk assessment has determined that a small RPA poses low risk, training and proficiency requirements creates an unnecessary cost. Model aircraft requiring more pilot skills have been operating for decades without training and proficiency requirements.

Should the introduction of geo-fencing be mandated?

Should CASA mandate the introduction of geo-fencing options to limit the operation of RPA in certain areas?

Please select one item

Yes

Please provide your comments:

People who do not comply with regulations, will either circumvent or use drone technology that bypasses any restriction. Additional regulation only affects law abiding operators.

What should be done about 'counter-drone' technology?

Provide your views on the ways in which counter-drone technologies should be managed and in what circumstances they should be used.

None

Specify any particular aspects of counter-drone technology or its potential uses to which CASA should be devoting more attention.

None

Are we doing enough of the right things?

CASA seeks your view on the way in which we are approaching regulation of RPA in Australia today and for the future.

CASA should focus on integration of RPA into manned aircraft operations so that they can co-exist. RPA technology is expected to deliver benefits and therefore CASA should be encouraging RPA adoption rather then restricting it. An example might include powerline inspections done by RPA reduces risk of a helicopter crew safety or working at heights risks.

General comments

Please provide any final comments about CASA's review of RPA operations. You can use the comments box or upload a file submission.

The introduction of the excluded RPA category was a good step in the right direction. It made no sense to make commercial RPA operators jump through hoops for operating the same RPA as hobbyist. Many operator certificate holders only want regulation as a barrier to entry, the same way the taxi industry fought against ride sharing. We believe that the more the public see the benefits of wider adoption of RPA, there will be less panic about perceived privacy and safety concerns.