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

Response 184396395

Personal information

First name

(Required)

Tony

Last name

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Morris

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 Ticked None	Above a specific size/weight Above a specific size/weight	For specific operations For specific operations	All RPA All RPA
By RPA operator 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

Please provide any additional comments:

I am a Part 61 Flight Crew licence holder in Single Engine Aeroplane category. I am a recreational RPA pilot.

In the absence of any evidence that model aircraft pose a threat to manned aircraft, I state my strong opinion that additional regulation of RPA hobbyists and commercial users is inappropriate. No doubt many respondents will claim that additional regulation will trade increased safety against an inconvenience. I make the claim that added regulation of RPA usage is not only inconvenient but adversely affects safety to our air space. I make this claim on the basis of: total absence of evidence of a threat having been posed. I therefore, adopt the null hypothesis that this proposed redundancy is itself, a specific type of safety threat.

The current Part 101 is appropriate and the incident record reflects that.

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 Ticked None	Above a specific size/weight Above a specific size/weight	For specific operations For specific operations	All RPA All RPA
Demonstration of proficiency 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

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:

I work for CSIRO, in formal software application development. The geo-fencing software will fail. Unless you achieve formal software verification, then please completely discard this proposal. You have an employee at CASA that is trained in formal software verification. He is also a PPL(A). You should ask him what is going to happen if you try this. Indeed, ask anyone with expertise in this area.

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.

Again, your software will fail. If you introduce this regulation, I will task one of my interns to undermine it within 48 hours. I guarantee you it can be done.

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

Nil.

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.

You are already doing the right thing. CASA does RPA regulation very well today. CASA seeks out public opinion such as this survey; again, an excellent idea.

Changing the current RPA regulation is going to hurt everyone. I fly manned single-engine aircraft, with PAX. I currently have absolutely zero concern about the safety of my aircraft or PAX as it pertains to model aircraft. That will change if redundant regulation is introduced.

If I am to suggest anything, seek out not only public opinion, but opinion in relevant areas of expertise.

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.

Thanks for asking. Keep it up.