Proposed RPAS operations over or near people - (PP 2609US)

Policy Proposal 2609US – Section 5.1

We are proposing to seek additional operational details to support an application, through a submitted concept of operations (CONOPS) or responses to questions on the application form (this only applies to OONP pathways that require a CASA approval).

A CONOPS is a document, scaled according to the circumstances and risks, that describes what an applicant for a CASA approval wants to do.

Do you think this proposal is an appropriate way for CASA to obtain the information it needs to assess applications for approvals?

Policy Proposal 2609US – Section 5.2

We are proposing to require OONP conducted in conjunction with other CASA approvals (i.e., outside of most standard RPA operating conditions) must be applied for and assessed together.

Do you think the proposal to require OONP approvals conducted in conjunction with other CASA approvals applied for and assessed by CASA, is an appropriate risk mitigator?

Policy Proposal 2609US – Section 5.3

We are proposing to restrict operations over or near a major gathering or organised event unless applied for and approved by CASA.

The approval is not intended to be event-specific; however, the operator must obtain a letter of agreement or invitation to operate from the event organiser and must notify CASA at least 7 days prior to operating over or near the event.

Do you think this proposal appropriately mitigates safety risks for operations over or near a major gathering or organised event?

Policy Proposal 2609US – Section 5.4

We are proposing that OONP approval holders have an emergency response plan (ERP) commensurate with the complexity and risk of the operation.

Do you think the proposal for OONP approval holders to have an ERP, commensurate with the complexity and risk of the operation, may improve safety outcomes?

Policy Proposal 2609US – Section 5.5

We are proposing changes to existing TMI 2024-01 Pathway 1 including:

• consideration of laceration protection
• the requirement for a safety case to support the application as well as requirements for specific documented practices and procedures
• the requirement to maintain a 'safe distance' from active participants
• that consent may be digitally recorded
• a separate RPA weight limit where operations are over or near active participants below 18 years of age.

Do you think the proposed changes to existing TMI 2024-01 Pathway 1 would appropriately mitigate safety risks?

Policy Proposal 2609US – Section 5.6

We are proposing changes to existing TMI 2024-01 Pathway 2 including:

• complying with an impact test standard to determine transferred kinetic energy
• simplifying when laceration protection is required
• considering sustained overflight of moving vehicles travelling at speeds higher than 60 km/h
• including third party organisations, acting on behalf of emergency service organisations for emergency services operations, to use the option for a higher kinetic energy limit of 34 joules
• clarifying requirements for consideration of wind speed and wind monitoring where a parachute recovery system is used
• clarifying options for applying to operate over or near a major gathering or organised event.

Do you think the proposed changes to existing TMI 2024-01 Pathway 2 would appropriately mitigate safety risks?

Policy Proposal 2609US – Section 5.7

We are proposing a new pathway for OONP approval where the drone is operated at a low altitude and overflight of people is not expected.

Under this new pathway, low altitude operations near people may be approved where all specified conditions are met.

Do you think the proposed new pathway for a low altitude operation not over people approval would appropriately mitigate safety risks?

Policy Proposal 2609US – Section 5.8

We are proposing a new pathway for an OONP approval where the drone uses a parachute recovery system (PRS) and the maximum impact energy under PRS descent is 34 joules or less.

Do you think the proposed new pathway for an OONP approval with a parachute recovery system would appropriately mitigate safety risks?

Policy Proposal 2609US – Section 5.9

We are proposing to remove the requirement to collect data for OONP where impractical or likely a duplication; such as collecting information on the drone operated, minimum distance operated from people, and the consequences of any collision.

Do you think the removal of these data collection requirements is appropriate?