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

Response 506110181

Personal information

First name

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Chris

Last name

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Thompson

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

Please provide any additional comments:

Drones less than 250g should not require registration like in the USA.

Drones under 2kg for sport / recreational model aircraft purposes should not be individually registered but should be registered in the name of the pilot. Ie all such drones used by one pilot would have the same registration.

All over 2kg registration should be mandatory and by individual machine as well as per pilot

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 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 For specific operations	All RPA All RPA

Please provide any additional comments:

Under 100g no need for any proficiency or training requirement.

Under 250g no need for any proficiency test or training but recommended.

Under 2kg and over 250g for sport and recreation proficiency test makes sense but who does the testing. Requirements for 500g acro mode racing drones are vastly different from autonomous Phantom type machines. For sport and rec, an experienced MAAA pilot can do basic training. For commercial sub 2kg work proficiency and a basic test is needed.

Over 2kg proficicency should be demonstrated

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:

Perhaps for some classes of drones but not all.

Racing drones - sub 1kg typically 500g - do not carry GPS or mag and cannot autonomously fly. There are zero incidents as far as I know with these being reported to casa. The software we use has no such functionality nor is it needed. We dont fly high. They should not be required to geofence.

Likewise any drone under 250g it's pointless to require this.

So I think weight and autonomous capability matter. I'd say no requirement under 1kg without autonomous capability (eg racing drones), preferred for sub 2kg, mandatory over 2kg or commercial.

Frankly I think it's pointless it will be a nightmare to manage the code, faulty gps registration will be a major issue, and automated falling or flying home creates more problems from uncontrolled crashes.

Also commercial people will need to overrride to do certain work. Who controls the override?

Frankly I just don't think it will work. Manufacturers won't provide the files. Users will disable it. Small quads can't do it.

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.

By law enforcement officers only and only in relation to criminal or terrorist activity.

No problem with that.

Otherwise should be an offence to interfere with a drone in flight as the harm potential from a crash is non trivial.

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

None it should be a police or counter terrorism function.

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.

I think you need more nuanced rules for sub 1kg racing drones, sub 250g drones generally, and sub 100g drones.

Sport flying of any model aircraft under 1kg with a flight ceiling not exceeding 45m agl is very very safe indeed.

Members of MAAA and like organisations flying within their guidelines in particular are exceptionally safe and should be able to fly sub 1kg anywhere except approach and departure as currently for model aircraft.

Casa also should relax night flyin restrictions for sub 1kg model aircraft when the model is illuminated with LED's such that visibility is better or as good as daytime. Many parks are deserted at night and well illuminated drones much easier to see. Fpv cameras with night vision make it very safe to fly both LOS and FPV under Maaa guidelines again under 45m AGL.

CASA needs to worry about stuff over 1kg not the sub 1kg space, even less about sub 250g, and not at all about sub 100g

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.

I am an active racing drone pilot and I shoot simple holiday videos. I feel concerned that this wonderful hobby with great economic and teaching benefits to students and kids about robotics, electronics, flight etc etc will be stomped on. The sub 45m Agl airspace should not have A320's or helicopters in it. The sub 1kg space is exceptionally safe. Bird strikes are massively more a real problem than drones.

I am a safe responsible pilot with hundreds of hours flight experience with my quads. I feel very confident that many are like me. Those of us who fly safely and responsibly should not be blocked from what we do.