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

This testing should only be conducted by CASA after a reportable incident as part of the investigation process.
Each ReOC has a drug and alcohol policy for the organisation.
A company will also have a drug and alcohol policy that would give them the powers to conduct targeted drug and alcohol testing if it suspected an employee was under the influence of such substances.

Whether this is actually required at this level given that most of the SSAA's are related to manned aircraft. I am not sure how many ReOC holders would be conducting this type of activity on a regular basis.
Reading the document it would be the maintenance and issuing release to service documentation for aircraft (RPA).

This policy is directed towards the manned aviation industry and does not take in to account that a majority of ReOC holders are not conducting SSAA's where they would pose any significant threat to manned aviation or the public.
Reliance should be placed on each ReOC holders Drug and Alcohol policy in their operations manual.
Maybe this part of the document could be updated to include some part of the DAMP ie: the requirement for drug and alcohol testing prior to the commencement of any SSAA activity.

I agree this is a great move forward as these operations pose no significant threat to manned aviation or the the public given the nature of the controlled space.
I was however unable to access either of the draft regulations to read them, booth went to a dead link.

Again I was unable to read these documents.

The SORA application process needs to be simplified and streamlined for BVLOS operations.
Include EVLOS permissions in a standard MOS similar to the night operations permission.

Emesent is continually conducting research and development to improve our product.
This testing requires many very small operations.
The current methodology for RPA operations requires a lot of work on our behalf to conduct what sometimes may be a 1 minute flight not more than 5m from the ground.
It would be good for this framework to include businesses that conduct this type of activity.

As above.

Any removal of duplication is a good thing.

Some operations require an RPA to be closer to a subject than 30 meters. This person does not have any duties directly related to the control or navigation of the RPA. But they are an essential part of the operation as far as the data being collected for the operation to be successful.
The current wording is sufficient allowing responsible operation of RPA whilst maintaining safety for the public.

I agree with this amendment.

As long as the system works. As I am still waiting for a solution to my drone registration issues.

Does electronic surveillance indicate that all RPA will need to carry an ADSB transceiver?

How will this affect Model Clubs? Will they be able to apply for exemptions? This is especially pertinent for glider clubs which will operate above 400ft AGL regularly.

Nil.

How woke of you.

Nil.

I feel they should have 5 hours on a airframe of the same weight class that they are getting the RePL for.
This would prevent somebody using a micro drone to achieve hours of operation.
Word as such.

Nil.

I feel anything other than one on one tuition results in poor ability.
When I was training it was always one on one and I had a buddy box to allow intervention if required.

There should be documented competency performed by the CRP for any delegated pilot to perform these checks.

As long as the one type of RPA is of the same weight class as the RePL that is being applied for.

nil

nil

nil

Simplified MOS

RPA relevant BVLOS training and testing.

More regulation for RePL training organisations.