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

The number of drones being flown by private individuals is of great concern to us as a helicopter operator.
CASA obviously believes that by restricting drone to 400 feet above ground they have guaranteed satisfactory separation between drones and other aircraft. As a helicoper aerial work operator, everything we do is BELOW 400 feet and it is only a matter of time before there is a catastrophic accident with a drone hitting a low level aircraft conducting aerial work.
Commercial drone operators are not our main concern. They have signed up to be a registered operator in general because they want to do the right thing and will in general abide by the rules. Private individuals flying drones are our number one problem. The only way to ensure compliance is to ensure the penalties are large enough to discourage breaching the rules. To make this an effective strategy you need to be able to track down the owner/operator of the drone - this requires mandatory registration of ALL drones.

A sub 2kg drone definitely still has the capability to catastrophically damage a helicopter by hitting the tail rotor. Registration should be mandatory for drones over 250g.

Registration should be at point of sale with an amnesty period for current drone operators to retrospectively register and requirements to transfer ownership if a drone is sold or given away.

Registrations should contain sufficient information to gurantee a drone operator can be identified and tracked down when rule breaches are determined in order to issue fines/penalties.

All drones should be required to be marked with such information to allow teh matching of the drone with its registered owner - whether this is actual contat details or a registration mark is unimportant.

It should be mandatory for ALL drone operators to have to pass a test ensuring knowledge of the requirements of CASR Part 101.

This could be conducted at the time of registration.

A demonstration of proficiency should be mandatory for operators of drones over 2kg as the consequences of breaches in regulations for these aircraft when in conflict with GA aircraft are far more significant.

My yes answer has limitations:

I believe geofencing should be mandatory for all drones to exclude them from all areas of high aircraft traffic density e.g. in the vicinity of aerodromes and areas of frequent low level GA aircraft operations.

As the technology develops GA aircraft operators should be able to register with CASA an area of low level operations which can then be geofenced to prevent drones from operating within that area with suitable consultation with other interested parties.

In the recent past we had a situation where a notam was issued converting a large area near our home base to a prohibited area for 4 days due to the registration of low level drone operations. The area concerned was a National Park and we as a helicoper operator had several jobs booked in that same area during the period of exclusion. This came at significant cost to the company - we were not notified or consulted prior to the day of activation - this is a completely unsatisfactory procedure. A consultation process should be mandatory.

Counter drone technologies should be allowed to be used by law enforcement agencies, other government organisations.
The use of these technologies by private entities should be restricted to thise assessed as having a valid need to exclude drones from the area e.g. security purposes or a true safety need (privately registered heliports or airfields etc).
The possible installation of these technologies into aircraft to knock conflicting drones out of the sky (or return to home etc) would be a fantastic capability to develop also.

As I have said before the regulation of registered and licenced drone users is the control of a group who are already invested in conducting operations in a safe manner.

Unregistered private individuals are the greatest concern to us. Education is wonderful but I believe the consequnces of breaching the rules need to be huge to deter unlawful and unsafe operation - in short CASA needs to carry aRedacted text big stick and make the fines and/or other punishments/penalties a serious deterent (e.g. >$10,000 per offence and to include imprisonment as an option).

The consequesces of a private drone operator breaching the rules for us, as a low level GA operator, carry the very possible outcomes of the destruction of our aircraft and the death of our crew and passengers - slightly more serious than the $1500 fine the operator may receive if they are caught in breach!

I do not envy CASA the job of successfully managing the explosion of the use of drones. The horse has already bolted on that one and there is no reeling it back.

As I have repeatedly said our concern is the seemingly blase attitude that by restricting drones to <400 feet the problem is largely solved. It is far from solved and it is, I beleive, only a matter of time until one of our low level aircraft is hit by a drone as our area of operations is always well below 400 feet.

A drone operator can be operating well within all the rules, conducting what they believe to be a completely safe operation when they are actually in direct conflict with our, also competely legal, operation. This is an issue that requires immediate attention.