3689599268?profile=originalThe Australian Certified UAV Operators Inc. (ACUO) have issued a petition to their members against the notice of proposed rule-making by Australia’s Civil Aviation Safety Authority.


This is the summary of that NPRM (my emphasis):


NPRM 1309OS - Remotely Piloted Aircraft Systems


This amendment to CASR Part 101 relates to Remotely Piloted Aircraft (RPA) used for commercial operations, but excludes model aircraft used for recreational purposes. It establishes a revised risk based framework for regulating RPA operations.  A key part of this amendment acknowledges the existence of a "low risk" class of RPA operations, which are determined as small RPA with a gross weight of 2 kilograms and below while they are being operated under the standard RPA operating conditions as defined and discussed in this NPRM.

For these RPA operations, CASA proposes that the requirements for a Remote Pilot (RP) Certificate or an Unmanned Aircraft System Operator’s Certificate (UOC) will not apply.

RPA with a gross weight above 2 kilograms in all operating conditions, and all RPA operating outside of the standard RPA operating conditions, will require an operational approval.

This amendment also proposes a number of changes to:

  • update the current terminology used within CASR Part 101 to bring it in line with the latest terminology used by ICAO as found in Annex 2 to the Convention on International Civil Aviation - Rules of the Air.

  • clarify the current requirements for RP training and RP certification

  • remove redundant requirements and to simplify the process for approval.

The AUCO concern seems to be amateur RPAS conflicting with aircraft and gives examples of recent Australian incidents.  They are particularly worried about people with no experience in aviation or model aircraft going down to Harvey’s and buying a Parrot or similar then popping it up near an airport - a well justified fear.  There is no doubt that the emergence of cheap, ready to fly aircraft with capabilities far beyond ‘model aircraft’ of the past is a growing worry.

A quick search on YouTube will show the current capabilities of small UAVs, how about an 80km solar-assisted flight with video downlink all the way?  Or an electric model aircraft flying at 16,000 feet?

All very worrying but what is hard to see is how the NPRM would increase the risk of this happening as the AUCO suggests.  The incidents referred to by the ACUO are illegal now and will continue to be illegal.  The people doing this are either ignorant of or don’t care about the regulations so whatever the regulations contain is unlikely to change their behaviour.  The recent CASA brochure, to be distributed to retailers, will help with the ignorant ones but the deliberate rule-breakers won’t be deterred by NPRM 1309OS.

The NPRM won’t legalise flying near aircraft.  It doesn’t weaken the standard RPA operating conditions that non-commercial craft must follow.  

It lessens the rules for small commercial craft but also removes the ability for those craft to do things that licences commercial craft can do - FPV, controlled airspace, publish NOTAMs etc.  An official CASA licenced operator can fly FPV down the middle of 16R at Sydney airport with the right approvals.  There’s no way a commercial UAV operating under the new exemption can legally do that.

What it does propose to allow is commercial sub-2KG RPAS.  CASA see sub 2KG craft flown within current RPA regulations on a commercial basis as being a low risk policy not requiring the costly burden of regulation.

Instead the AUCO proposes greater regulation, enforcement and penalties however this is an area that would be very difficult to police.  You may as well add children’s helium balloons while you’re at it.

It appears that the AUCO has missed the point as the NPRM proposes, amongst other things, to exclude commercial UAVs under 2KG flying from CASA oversight.  So commercial sub-2kg UAVs would be under the same rules as non-commercial.  Unlikely to reduce incursions by amateur craft.

Chances are that the proposed change would affect the  ACUO members financially..  many commercial jobs can easily be done by a craft weighing less than 2 kilograms - think real estate photography, infrastructure inspection and so on.

"This would only apply in the standard operating conditions, which includes operations in visual line of sight, less than 400 feet above ground level, non-populous areas, more than 30 metres from people and outside controlled airspace," said Director of Aviation Safety John McCormick.

I hope that CASA don’t cave in just to preserve the turf of the ACUO.



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  • just thinking aloud - the whole thing could be a self funding department of CASA.

    But there are many ways it could work. If you tied it in as a pre requisite for obtaining pl insurance then that would lock in serious businesses. And if it were tied in with some kind of umbrella insurance that could be obtained (i have seen similar results obtained in Kitesurfing australia wide which suffered from similar public risk issues)

    The license wouldnt keep all the non competent flyers out but would statistically probably knock out a large percentage of non disciplined operators. Perhaps 80% of the result for 20% of the effort / cost.

    my general point is that a sensible moderale / light amount of regulation would probably do the most good - i dont agree with hard / expensive regs - but also dont see totally anarchy as a good result either.

    Agree about the dangers of all starting out flyers. maybe strongly encouraging learners to start on something safer like an AR parrot with prop enclosed body / any super light multi to gain stick muscle memory / orientation skills would help.

  • You haven't really answered my question of what you'd get from the "license"?  Who will do those checks, and how much $$$ will they expect for their time? If it's just a case of "paying to play", then what surety does that give you that they're in any way competent?


    My point about your mates is that they are, theoretically, just as dangerous as commercial operators would be under the new regs - they're operating under the same conditions and rules for separation etc.

  • Hi Mike - you bring up some excellent points!

    The money could be invested in a national / bulk insurance scheme for small (sub 2kg?)commercial operators - as well as an association similar to or even ACUOS themselves. No fee / license no insurance.There are a myriad of options

    $500 - $100 is a tiny investment - pick a number - it could be $250 or even $150 and totally justifiable if you are a good flyer/ camera operator / navigator looking to generate revenues out of one of these.

    Mates are just "having fun" and exploring the hobby - i am sure we all have 5 of these! 

    Of course they dont have an OC and FC and the relevant 15 g / months of time to apply for these

    I am still in favor of total dereg for non commercial flyers at sub 2kg

    Imagine a line with the right side being complete and total regulation and the left being toal freedom / anarchy / free market mechanisms

    My personal view is that we are currently too far on the right of the spectrum where it is just too hard to get in and  "anti business". 

    If we look at the left side of the spectrum as being total dereg - then i reckon somewhere close to the left is a good place to be. But again total deregulation is asking for the industry to get tarred with a black brush as it starts to rain drones!    

    Anything is better than what we have now ! 

  • What would my $500-$1000 get me?  A quick chat from CASA saying "now you go be a good boy"? Would it go straight into the coffers of an organisation that is graciously volunteering to take over that burden from CASA?


    So, all your buddies - do they have an Operator Certificate, or are they making all their mistakes while they're "model aircraft" flying, and wouldn't come under any changes anyway?  People will screw up now before they get their OC, or if the new regs come in ... still before they start operating commercially.

  • and one more simple tweak would make a lot of sense.

    Make closed prop designs compulsory (a bit like the prop guards that DJI have o r the cybertech air frame design).

    This would greatly reduce any risk involved with prop strikes on humans when it does go wrong. 

  • While I love the idea of dereg on the sub 2kg set ups.

    I have been flying rc for 7 years (lots of 3d hi performance aerobatic planes) and have the skills to pull this off (i have been flying a FW450 for 14 months now - mostly incident free)

    however most of my aquaintances who have gotten in to this-  thinking it would be easy- have come back with the same result (usually accompanied by a facebook pic of a mangled UAV)

    "it was really great - but then something when wrong and i crashed it" 

    i have seen everything from incorrect soldering (mines not to good) , incorrect pid set ups  / incorrect mixes that map gains to camera tilt controls that cause the UAV to freak out . Accidentally Switching to full manual after relying on GPS assisted flight - in other words MOSTLY user generated errors.

    Without years of practise and good habits, without always thinking about plan B to get out of sticky situations new flyers will always run in to problems

    Hence I firmly believe total dereg is a bit dangerous.

    A license / yearly fee of around $500-$1000 for commercial operation would make sure that the super cowboy / yeeha factor is reduced and create just enough "take this seriously" factor to reduce the amount of phantoms diving in to crowds at events. At the same time this would be a very small barrier to entry to businesses looking to leverage and provide an awesome service that these SUB 2kg UAVS can provide.

  • Thomas - CASA has a summary here: http://www.casa.gov.au/wcmswr/_assets/main/lib100071/flying_with_co...


    Darrell, no hobbyists are actually required to fly anything in any designated area.  You can take a 20kg petrol powered, four engine plane down to your local oval and go nuts, as long as you're flyiing for "sport and recreation" and abiding by the same rules they're proposing for <2kg commercial operations.


    People fly small stuff in parks now - probably not much in the way of fixed wing over 2kg, nor, realistically, multis over 2kgs either.


  • If you AGREE with the Sub 2kg changes proposed by CASA, fill in the response form here: http://www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_102028

  • MR60

    @Darell, because contrarily to classical rc, multirotors have their purpose in being used for activities that are outside of an rc field: like bridge inspection, thermal analysis, precision agriculture, etc, etc.

  • How long do you think it will be before someone operating a <2Kg multirotor causes a serious injury? At that point someone with common sense will ask why people aren't required to fly multirotors in designated areas just like all the other RC hobbyists do. I just don't understand why multirotors should be treated any differently. 

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