Proposed amendments to Part 101 CASR and MOS - Unmanned aircraft and rockets - (PP 2107US)

If there is clear, qualified and verified evidence that an operator has performed their RPA activities and caused harm or damage then an authorized member of the State or Federal police should obtain such!
No random testing!
If the operator is outside 101 then other actions should be perused!

Only if their is CLEAR evidence of lack of 'Duty of Care', and then by a member of the State or Federal police!

CASA appears to put the ReOC license in some higher status, it is only the radio component!
ALL generic Business activity should be conducted under a DAMP and RPA is no exception.
To put this in a CASA obligatory list is applying conditions that are already in place!

WHY only ReOC, this make no sense. If CASA is implying that anyone flying medium and Large RPA is only a ReOC holder?
DAMP is a generic and social need. It should be under the generic laws and of no concern to CASA.
Those who peruse RPA activities while under the influence of drugs are not going to worry about CASA regulations!

Indoor spaces implies there are NO apertures that would allow unmanned aircraft to escape!
The risk of an RPA flying through a 800mm door, that is open, is so low it's a ridiculous!

The definitions are so grey?
How high is the ceiling? Is there audience space? is it netted?
I think this is an attempt to over regulate when a simple 'using a RPA without due respect for duty of care' is more that adequate, of course with appropriate evidence of such.

A 'duty of care' mandate should be adequate.
The current regulations concerning RPA activities ae more than sufficient!
Else, as long as the frame works are set by experienced persons and Not a random interpretation by an administration assistant.
Does CASA have the qualified staff who are experienced with the operation of RPA capable of making a plausible decision in a timely manner?
It concerns me that no acceptable risk management operations has shown ANY risk in the use of RPA. There has been no DEATHS or SERIOUS injury, No major damage to property.
If these have been done then please publicly published the results!

There should be no qualification to who conducts research and development!
I am an individual who conducts personal research and development for my own interests and education.
Is the intent to restrict my innovation, modification, research and development?
My fleet of RPA is manufactured by myself. There are no serial numbers, no corporate foundations. They seldom stay in the same configuration, mechanically or software for long!
MOST of the current status of RPA is founded on work done by hobbyists. Some of the current software used by 'professional users' is still open source, developed by enthusiasts. By imply ANY inclusion/exclusion you will severely damage further advances!

WHY these categories? It is implying that those who are undertaking R&D on larger RPA are more qualified, responsible or competent!

large RPA have their challenges but less their smaller types: small RPA are prone to environmental changes that make them more of a challenge to use.

Using included and excluded in the same question is confusing and poorly applied!

WHY ReOC, yes it has the radio component but this is no reason for exclusivity!

Over regulation with get out clauses!

The 'duty of care' mandate applies!

Any one who intends to use this for nefarious activities is not going to bother with any conditions of use!

Asking for comments on a wordy clause is distracting and putting a limitation on informed response!
BVLOS is an mode of operation that has been performed by many enthusiast for years. Using First Person View (FPV) has NOT been an issue! There has not been any 'published' evidence of Death or Injury caused by BVLOS.

Paranoia of the possible consequences of this mode of operation, loss of privacy, spying and other consequences are quite possible any means other than BVLOS!
As long as 101 regulations are complied with there are no implication as to why BVLOS should not be allowed!

Any operator who wants to risk their equipment by ignoring the specification, environment and their experience level is not going to worry about these regulation!
Who is going to monitor, police these activities!
Over regulation or regulation for regulation sake. This is a ridicules set of 'get out clause' if something goes wrong!
As long as 101, in its basic mandate if followed then there should be not need for these conditional and confusing agendum's.

Agree BUT:
The use of mobile phones should be a support service, not the primary!
The implication that mobile phone coverage is a given, is dangerous!

The primary communication method should be by licensed ACMA equipment!

No public radio system such as Citizen Band (CB) which is prone to jamming, hostile use and poor coverage should be considered safe!

Why implement a set of conditions that in essence already exists?
Obtaining the RePL required the verification of competence by the examiner!

This opens up the possibility of NON experienced staff and ley persons the use of Large RPA, without supervision and in a situation where others are spectating.
Totally a Bad idea!

This opens up the possibility of NON experienced staff and ley persons the use of Large RPA, without supervision and in a situation where others are spectating.
Totally a Bad idea!
They might be able to repair them but that does not mean they can operate them!
Only experienced operators should operate medium to large RPA!

Making regulation clear and concise is always a positive.
Most of CASA regulations appear to be authored by those with little or no experience of the use of RPA.
They appear to be responses to imagined possibilities and seldom appear to be peer reviewed, this leads to duplications, implied possibilities and ignorance of the facts!
It appears that there has never been a true risk analysis of RPA use and over regulation based on the above is rampant!

‘a person who is not directly associated with the operation of the RPA’. Should read 'other than a person who is not directly associated with the operation of the RPA’.
There is a possible, trainee, navigation, observer and camera gimbal operator!
Again as long as 101 is being applied there is no need for further qualification!

Why a such ridiculous qualification, disqualifications in the regulations?
As long as ANYONE is applying 101 then being a ReOC holder is irrelevant!

Large RPA not the issue! Any one who operates a large RPA has a major commitment to use it in a safe and responsible way.
Those who use it other wise and in nefarious objectives don't care and regulations.

This whole set of regulations is convoluted, wordy, authored by those who seek a reason to blame someone or restrict safe and valuable use of RPA.
There is a belief that these regulations are based on the need to secure the lower airspace, current enjoyed by model aircraft enthusiasts for over one hundred years, to the exclusive use of commercial enterprise! These regulations are oppressive to legitimate users! No evidence exists to show RPA are dangerous in any mode, weight or use that makes them subjective to such restrictions! Next CASA will be set to stop Cricket, just in case a ball might 'fly' in to a window!

101 in it's native, original, format was more than adequate in covering these situation.
Seeking to apply wordy conditional sub clause just give someone a job in CASA!
Yes I'm getting sarcastic because these regulation are getting stupid!

(Copy of above)101 in it's native, original, format was more than adequate in covering these situation.
Seeking to apply wordy conditional sub clause just give someone a job in CASA!
Yes I'm getting sarcastic because these regulation are getting stupid!

Using a swam of RPA is a very unique operation and governed by regulation outside these policies.
(copy of above) AND
101 in it's native, original, format was more than adequate in covering these situation.
Seeking to apply wordy conditional sub clause just give someone a job in CASA!
Yes I'm getting sarcastic because these regulation are getting stupid!

101 in it's native, original, format was more than adequate in covering these situation.

Anyone operating a RPA in conditions beyond their experience or the RPA specifications is not going to worry about CASA regulations!

101 in it's native, original, format was more than adequate in covering these situation.
The need of RePL is the only statement needed!

Makes sense!

I am concerned that there appears to be NO risk management done!
RPA activities are supper safe and no evidence is apparent to show other wise.

All current hysteria is based of conjecture, hearsay and superstition!

Please publish the verified evidence to show other wise!

So, if a computer is to be used to show risk what is the program base for the analysis?

Not without CLEAR and written, verified evidence that can stand up to a defamation case in court!
Other wise any complaint for any ley person (currently called a Carron) could cause unnecessary stress and loss of use!

CASA should peruse investigations but take no action until the conditions below are verified:
That operator is operating out side of conventional law or part 101 and with CLEAR and written, verified evidence that can stand up to a defamation case in court!

Other wise any complaint for any ley person (currently called a Carron) could cause unnecessary stress and loss of use!

The subject of the complaint should be notified of the complaint and shown any evidence of an alleged incident within a reasonable time period, say two weeks, else circumstance may change and supporting justification is lost!

If clear and verified evidence is available to support the action!
And if the holder is give sufficient time and resources to support or correct the complaint!
And if a verified problem is identified a warning should be issued and adequate support provided to correct the problem or miss-interpretation of the regulation!

That is CASA's mandate!

Agree if such infringement is a direct and knowing action.
If such an infringement is an accidental action and no nefarious intent was made then the operator should be give some leniency, education and minor penalty; dependent on the type of aerodromes, their use and location.
Obviously if the aerodrome is in constant use or seldom used the accidental infringement penalty is subject to intent and risk!

It clarifies a conditional use, that's always positive!

I'm only concerned with operation's and free use of current AGL limits, else is outside my area of knowledge!

Unless the records were for engineering or development purpose the implication for use in infringements would be difficult to manage to an evidential level and subject to volatile circumstance and conditions!
Any conclusions made from data stored would be open to many interpretations!
Any record keeping device adds complexity, weight and mission endurance limitations as well as possible interference with the Control systems used.
BAD idea!

RePL holder is quite well defined! Is a part license to a ReOC which is only an additional radio component! If the ReOC is involved with Business, or other professional activities that is their intent. An RePL is a operator who has been verified competent to use a RPA to a certain weight!
An operator is anyone who controls an RPA, irrespective of the weight!

It seems like a high status position for a basic administration role?
It appears to have no authority?
It appears to have no powers of investigation of safety risk analysis.

They hold the license and the value of their operations equipment and any staff.
Their loss in not compiling with practices and procedures is apparent.
Their individual liability to not operate in a safe and secure method is answerable to all and not just CASA.

I can't see what records need keeping!
Business account information perhaps but operational data?
Management of batteries and other consumables again perhaps but CASA does not need this information.
I feel CASA is trying to apply manned aircraft needs to low risk RPA and this just adds to compilations that are unwarranted! Until, if ever, RPA become a serious risk then NO.

NO DOCUMENTATION! NO NEED TO REDIFIN policy intent!

If no infringements are reported and no evidence of safety liability is shown stop micromanaging a activity that is quite capable of looking after its own interests!

CASA appears to be looking for any excuse to restrict current activities. There is no need to rearrange the deck chairs the ship is NOT sinking!

CASA is a safety orientated organization!
RPA have little or no evidence of unsafe operations!
WHY is CASA applying regulation, conditions and directives that appear to have no significant point in addressing non existent safety issues?

Most of the regulations are wordy, convolute and repetitive. They show little or no knowledge of the subject matter.
They are obviously politically motivated to address unwarranted concerns of the general public and the interests of the commercial users!

I'm concerned with 'or' at the end of the subparagraph!

But who is qualified to judge my competency?
I use my RPA regularly but for research and development.
I have been a RPA user manufacturer, most of my life and constructed and flown Multirotor vehicles for over ten years, from micro to large (<7Kg) I have flow FPV, mission planed flight and many other modes.
When and how often is someone going to 'test' my competence.
I have a RePL because it was the responsible thing to do. It cost me a considerable amount of money.
I am retired and don't intend to fly for profit or gain.
None of my RPA are serial numbered, none remain in one construct for long having been modified and repaired.

But who is qualified to judge my competency?
See above!

But who is qualified to judge my competency?
This is an imposition on my conditions obtained when I gained my license!
Any one who trusts me to use THEIR RPA should take the responsibility for their equipment!
If they don't trust me then don't let me!

Why and when?
Doe's this imply I have to go and get retested?
At who's cost.
My competency was tested when I obtained my license!
I, and you must take my word, am very experienced with multirotor craft.
There is no need to test competency of a RePL holder. If the owner or organization whish a RePL holder to control their equipment it is their judgement about competency and risk.
Leave me to control my own equipment at my risk!

Yes it's un warranted.
The competency to use a RPA is the risk of the owner to permit.
As long as 101 are complied with!

Any level of competency training step that encourages license achievement is positive!
(ex adult electronics/radio equipment instructor)

Basic understanding of flight maps, NOTAMS and weather is necessary for BVLOS!

What qualifies them to asses competency?
They may not have used or seen, a RPA since they gained their license.
I know of Chief Remote Pilot, a ReOC holder, who is a name only holder and has not been involved since they gained their qualification. Their organization is in the public domain and leave the RPA activities to RePL staff!

I assume this is a role within CASA?
I would be welcomed change to know someone is actually going to review the necessary competency needs of the RePL
I hope that they are experienced in RPA from a practical level and are will in to take comments from users like myself and not be commercially orientated!

They need to have competency in using a RPA and understand the practical need of the RPA environment!

They need to have competency in using a RPA and understand the practical need of the RPA environment!
It is very important that they are experienced users of RPA, know the enthusiasts and commercial use of RPA.
Most basics and advances in RPA use have come for enthusiasts, university research and this is fostered most applications of RPA.
NOT continuing to acknowledge and support the enthusiasts who provide open source software development, material use and construction methods will seriously damage innovation and development of the RPA world.
As an enthusiast I am one of the majority users of RPA (apparently near 90%) yet we seem to be ignored by representation at national level. What representation we have is also commercially biased!
Over regulation of RPA will seriously hinder enthusiastic advances in RPA at a loss to all.
The Chief RePL Instructor and his seniors MUST pay attention to this, encourage enthusiast to obtain the RePL and keep the cost of doing so low!

As above and copied below, the need for this position is imperative. the quicker the better as long as the needs below are acknowledged.
They need to have competency in using a RPA and understand the practical need of the RPA environment!
It is very important that they are experienced users of RPA, know the enthusiasts and commercial use of RPA.
Most basics and advances in RPA use have come for enthusiasts, university research and this is fostered most applications of RPA.
NOT continuing to acknowledge and support the enthusiasts who provide open source software development, material use and construction methods will seriously damage innovation and development of the RPA world.
As an enthusiast I am one of the majority users of RPA (apparently near 90%) yet we seem to be ignored by representation at national level. What representation we have is also commercially biased!
Over regulation of RPA will seriously hinder enthusiastic advances in RPA at a loss to all.
The Chief RePL Instructor and his seniors MUST pay attention to this, encourage enthusiast to obtain the RePL and keep the cost of doing so low!

I don't agree with this. It's a massive jump from 250gm to a possible 7Kg RPA without qualification of competency!
BUT I feel there is a need to increase the current weight limit of 250gms for non licensed use as it is too restrictive!
A better limit would be 1Kg with a limit of 3S on the battery size and maximum of four motors, this limits the power considerably and so the speed. This would encourage the development of autonomous vehicles, a highly needed learning need of RPA future use!
Planning auto use for surveying, crop observation, etc. is a skill that need to be developed.
This would provide schools and higher education establishments an excellent educational tool.

I see this as an advantage but multilingual personal should be encouraged.
Any need for a translator or foreign language training material should be available.
Obtaining a RePL must not be dissimilatory!
Any hindrance to obtaining a license must be eliminated!

Semantics!

My course contents where excessively weighed down information required by trainee manned aircraft pilots!
Some information was important, How to read Air maps, weather patterns and NOTAMS but other information was not necessary!

Agreed but as the safety risk level has not been defined what level of safety is considered necessary of of a higher level?
Much of the safety issues are unfounded and lead by hysteria generated by unqualified people!

Theory and practical training must be interlinked. If unrelated to the theory subject, giving a break in theory only sessions is very important to concentration levels.
(Ex adult educator)

Appears to be a good balance!

CASA assumes that the Chief Remote Pilot is a hands on currently experienced member of the team! My experience is that they a name only!
EVLOS proficiency checks? who sets the standards and who supervises them.
EVLOS is a steep learning curve that should be achieved slowly and proficiency gained by all of the team.

CASA is trying to dominate every aspect of RPA use!
CASA should only be addressing safety issues.
The user owner are quite well aware of the individual operational needs of their equipment and the type of fuel and operation at a practical level.

If this is reference to the course material and not individual courses? As soon as possible

Agree, some common sense must be applied and trust in the instructor to know the responsibility and implications of all environmental are taught to students.

Common sense applies again. The operator must use their experience to use the RPA in a safe way. Appropriate distances are a trust given when applied.

CASA has a responsibility to the majority user! Industry is a minor users and will expand only from the ranks of the enthusiast ranks.
WE innovate, develop, stretch the operability and application, design, research methods and materials.
IGNOR us and industry will stagnate!

Most of the tech used by the military was born from the hobby based innovation.
Model aircraft made man flight advance at a massive rate.
Multirotor craft have done far more due to the enthusiasts yet you are ignoring our contribution and future development.

CASA regulations a still too complex and limiting!

PAY MORE TRIBUTE TO THE ENTHUSIASTS WHO HAVE GIVEN INDUSTY THESE TOOLS.
PUBLISH A FULL RISK ANAYSIS OF THE DANGERS OF RPA.
RPA DO NOT POSE A SECURITY RISK.
THERE ARE MANY OTHER WAYS TO INVADE PRIVACY.
DOMESTIC RPA DO NOT POSE A THREAT TO MANNED FLIGHT.

CASA not recognizing the majority users of RPA, declaring very restrictive use of airspace that was once open to all with out just cause based on hysteria.

The weight limit on small RPA specifically multirotor craft to 250gm.
Should be higher to allow use of autonomous RPA with video and telemetry links for the education and innovation of all.

AND RESTRICTING THE AGE LIMIT. There is no need, young kids have been playing large engine model aircraft for decades, me included, and survived.
Remove the age limit, it has no basis!

Restrictive fly sites.
These are usually club sites nominated by authoritarian members who treat multirotor members as lesser humans and dictate operating times for multirotor users that are totally unusable. CASA has fostered dictatorships!