Drone discussion paper - Review of RPAS operations (DP 1708OS)

You have stated CASA there are about 50'000 RPA's out there being used for recreational purposes. Do you really think if you bring in mandatory registration you will get even 1/10th of those actually being registered? Especially if there's a fee? Please.

Put a realistic cap on for a second and think about it. So Joe Bloggs and his 12 yo son is all of a sudden going to register, do an online course and pay a yearly rego fee just to fly in his phantom in local park once a month? Good god guys. Honestly. What about a mini quad? Still qualifies as a very small RPA. Does this come under the same restrictions?

If you're going to try and implement a registration at least be realistic about it. Anyone who registers will no doubt do their best to abide by the laws. If I (for example) wasn't going to or had no intentions to fly by the law I simply wouldnt register. Its that easy. CASA don't even come close to having the required man power to enforce such an idea so I'd be very happy with my chances.

I agree that training and education are beneficial. Without a doubt. But obtaining an RePL and a ReOC costs thousands. In the vicinity and upwards of $5000. Is this a realistic figure for a 12 year old hobbyist who flies his phantom once a month in the local park? Of course not.
So where do you draw the line? In my opinion if training or assessment is going to be mandatory is has to be free. No if's or but's. Free. Because if its going to cost me more money what so ever to enjoy my RPA that I could have spent anywhere from $100 up to $10'000 on I wont do it. What for?
So how do you enforce it? in my opinion you cant. Like I stated in my previous slide CASA can't even hold a candle to the sheer amount of man power required to do so.

What would I do if I were you? Change the legislation so it accurately reflects your AC's first (because contrary to what you say it does not, your AC's are not law and are not enforceable). Once and only once the legislation has been updated, Introduce a free online "course" with a printable certificate at the end stating that xyz person is proficient with the current legislation and that he or she can show on demand to a suitable CASA official if asked.

I honestly don't even know where to start with this one guys.
So i'll just be blunt. Geo fencing won't work.
For staters, not every RPA has GPS to begin with, so already you're limited with the amount of RPA's that this will work with. And even if it does you will need to get every company that makes multi rotor flight controllers (I sincerely hope you have someone on your team who does in fact know there are more RPA manufactures other than DJI right??) to implement it. That's going to be an epic fail. You can't target DJI for example and not make 3DR or gopro or boeing or parrot or any of the hundreds of other manufactures place geo fencing into their systems as well. Not to mention the stand alone GPS systems that are placed into custom RPA builds.
What about trained operators with commercial ops that are within a restricted area? You would then need those same manufactures to remove geo fencing for individual areas on individual RPA's to allow an op with your (CASA) approval.

You guys really have no idea how massive this whole geo fencing argument is. It simply WILL NOT WORK.

The police force are not aware or up to date on current CASR 101 legislation and certainly should NOT have the power to shoot/catch or otherwise down a drone because they think its breaking the law.

The only people that should have these technologies are trained CASA staff and the army for use on counter terrorism forces.

There are much better avenues for CASA to be focussing on besides "counter drone technology" like fixing up the hack job of current CASR 101 legislation.

Stats are the key. Not knee jerk reactions to ridiculous scenarios. How many planes have been downed by drones? None.

Please make hard evidence, statistics and good ol common sense the focus on whatever regulation changes you make in the future. This technology is only going to get bigger and better. We need to embrace it. It has the potential to save lives and enrich many others.

Think about all aspects of drone use. Racing, recreational,aerial photography, commercial etc etc. Don't make it hard or expensive to enjoy this hobby. You will only get the middle finger if you do.

You brought out your "can i fly there" app and have said its based someone using it for the sub 2kg exemption commercial ops. Why? Your discussion paper clearly states the vast majority of RPA users are hobbyists, so why wouldnt your app target them? Especially considering the overwhelming majority have no idea about CASR 101.

The answer is simple, because as of right now the legislation allows hobbyists to fly in more places (less than 400ft AGL) than someone for commercial ops under a ReOC (101.070 and 101.075). There is nothing legally stopping someone flying an RPA along the fence line of kingsford smith international airport as long as they aren't in the take off or departure lanes. Does that not sound ridiculous to you? It does to me, but I wouldnt be breaking any legislation if I did.
The entirety of 101.F doesnt apply to me and 101.G really doesn't say much either as it is clearly well out of date and geared towards model aircraft long before multirotors became as popular as they are now (ie 101.395).

So please guys, whatever you come up with, use common sense and logic. I fear however it's not common enough these days and as with most government departments, are far to slow to react with emerging technologies and that the pigeon has well and truely, flown the coup.

Good luck.