Proposed Part 101 MOS – Chief RePL Instructor assessment fee - (SPC 2319US)

Closed 18 Jan 2024

Opened 6 Dec 2023

Feedback updated 30 Jan 2024

We asked

Summary of consultation on SPC 2319US - Proposed Part 101 MOS - Chief RePL Instructor assessment fee

The Civil Aviation (Fees) Regulations 1995 are the regulations for charging all of CASA's cost recovery activities. For this proposed fee item, 24.12  ties the service fee to the granting of an approval under a Manual of Standards (MOS), in this case under proposed paragraphs 2.29A (2)(c) and (4)(c) of the Part 101 MOS.

The regulatory fees are either a fixed amount or have been set at an hourly rate to reflect the cost of CASA's personnel or systems that are required to deliver the services or activities.

CASA engaged broadly with industry for feedback on the proposed $623 Chief RePL Instructor assessment fee. Notification of the consultation was published in the CASA Briefing newsletter, on social media, and the CASA website. A total of 83 industry stakeholders accessed the consultation CASA's Consultation Hub while the consultation was open, from 6 December 2023 to18 January 2024.

This consultation has now closed, and a summary of the feedback is provided below.

About this consultation

The aim of this consultation was to provide operators and industry an opportunity to raise any concerns regarding the proposed regulatory fee. This consultation has facilitated CASA to understand the potential impact that this proposed fee may have on an individual or their operation.

You said

CASA received 14 responses. Nine respondents consented to having their feedback published, while the remaining requested their submissions remain confidential. The responses represented a broad cross section of the remotely piloted community including RePL training organisations (4), Remotely Piloted Aircraft Operator's Certificate (ReOC) holders (3), RePL pilots/instructors (5) and Commercial Pilot Licence and RPA accreditation holders (2). Five respondents stated that they were representing their organisation, while nine were personal views on the proposed fee.

We did

CASA appreciates the contributions made by respondents and acknowledges that their feedback has been beneficial to the consultation process.

There were 83 industry stakeholders who accessed the consultation on CASA's consultation Hub. Of those stakeholders, 17% provided responses.

Of the 14 respondents, 6 supported the proposed fees, one respondent was neutral, and 5 respondents opposed the concept  of fees. Concerns raised included existing charges for ReOC holder renewals, the time needed to undertake the task to process a Chief RePL Instructor assessment, and whether there was a yearly charge to be imposed. These concerns will be addressed in further consultation documentation. Two other respondents disagreed with the fees but did not state their reasons.

The Australian Government’s overarching cost recovery policy is that, where appropriate, non-government recipients of specific government activities should be charged some or all the costs of those activities.

The proposed fees were developed in accordance with the Government Cost Recovery Policy and guidelines. The cost estimates were mapped with a subject matter expert and are the direct cost for a proficient officer to assess a Chief RePL Instructor. Included in this costing is an indirect overhead for system usage and corporate costs. To allow for better industry certainty, it was deemed appropriate to charge a fixed fee.

For existing RePL training organisations that wish to nominate a CRI from the proposed commencement date of the proposed introduction of the CRI position, CASA will be waiving fees for a twelve-month period from the commencement date.

Next steps

As the related CRI application and volume data becomes available, we will review and address assumptions on the fees—this is consistent with the Australian Government Charging Framework. Based on the feedback received from the Technical Working Group (TWG) and industry, the fees do not pose any significant concerns.


Published responses

View submitted responses where consent has been given to publish the response.


We're seeking your views on a proposed regulatory services fee for the assessment of an application for a new Chief Remote Pilot Licence Instructor (CRI).

After considering industry feedback, we have found the qualification requirements for Remote Pilot Licence (RePL) instructors outlined in Part 101 (Unmanned Aircraft and Rockets) Manual of Standards (MOS) 2019, are more detailed than necessary for the intended purpose. These requirements are set to take effect on 10 April 2024.

Before 10 April 2024, we are proposing the following changes to the Part 101 MOS:

  1. create a new CRI position, who must hold the prescribed requirements, and will be responsible for ensuring RePL instructors meet an appropriate standard
  2. replacing qualification requirements for RePL instructors with a condition that suitable internal training and checking is undertaken.

These changes aim to reduce the financial and administrative burden of all RePL instructors obtaining the required qualifications.

In line with the Australian Government Cost Recovery Policy, we are required to set fees for regulatory services. This consultation sets out the proposed assessment fee for the new CRI position.

The proposed new rule set/standards

The proposed amendment will require CASA to charge a regulatory services fee for the assessment of a new CRI application.

Regulatory service fees are either a fixed amount or a set hourly rate, that reflects the cost of CASA personnel or systems to deliver these services or activities.

The proposed fixed fee will cover the assessment of an individual’s application for the appointment to the CRI position of an approved RePL training organisation.

The proposed fee is $623.00 (no GST). This fee will be charged under the Civil Aviation (Fees) Regulations 1995.

The proposed fee was developed in accordance with the Government Cost Recovery Policy and guidelines. The estimated costs for a proficient officer to undertake the activity, were mapped with a subject matter expert and treated as a direct cost for the service. It was deemed appropriate to charge a fixed fee to give industry certainty of CASA fees.

It is proposed, CASA will waive fees for existing Remotely Operator’s Certificate (ReOC) holders applying for the assessment of a CRI application before 10 July 2024.

Previous consultations

In July 2021, the Part 101 Post Implementation Review (PIR) Technical Working Group supported the proposed:

  • introduction of a new CRI position
  • eased requirements for RePL instructors.

In late 2021, 93% of respondents also agreed with the introduction of a new CRI position following public consultation on the Proposed Amendments to Part 101 CASR and MOS - Unmanned aircraft and rockets - (PP 2107US).

Why your views matter

Your feedback will help us understand the impact the proposed fee.

This consultation is seeking your opinion on:

  • the proposed charge for the assessment of an individual’s application for a newly created CRI position of an approved RePL training organisation.

This consultation is not seeking your views on the proposed:

  • introduction of a new CRI position
  • eased requirements for RePL instructors.

Please submit your opinion using the survey link on this page.

If you are unable to provide feedback via the survey link, please email

Documents for review

All documents related to this consultation are attached in the ‘Related’ section at the bottom of the overview page. They are:

  • Summary of proposed change – 2319US, which provides background on the proposed fee
  • MS Word copy of online consultation for ease of distribution and feedback within your organisation.

What happens next

At the end of the response period, we will:

  • review all feedback received
  • make responses publicly available on the consultation hub (unless you request your submission remain confidential)
  • publish a Summary of Consultation which summarises the feedback received and outlines any intended changes and next steps.


  • Drone operators
  • Drone training organisation
  • Holder of RPAS remotely piloted aircraft operator’s certificate (ReOC)
  • Holder of RPAS and remote pilot licence (RePL)
  • Commercial drone operator


  • Drones/uncrewed aircraft systems
  • Licensing
  • New and emerging technology
  • Owner of drones and/or model aircraft