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Mode Aviation
Reference No. AR201500060
Date reported 21 July 2015
Concern title The exclusion of Remotely Piloted Aircraft (RPA) which weigh less than 2 kg in the proposed CASA regulations
Concern summary

The concern related to the proposed new CASA regulations which will exclude all RPA’s which weigh less than 2 kg.

Industry / Operation affected Aviation: Other
Concern subject type Aviation: Other

Reporter's concern

The reporter expressed a safety concern related to the exclusion of Remotely Piloted Aircraft (RPA) which weigh less than 2 kg in the proposed CASA regulations:

  1. CASA has stated the sub-2 kg limit was calculated using weight and momentum and deemed to be a low risk. While this may be true in relation to falling on to people or property, it is not true in relation to collision with aircraft. The reporter, as a commercial pilot, has noted very severe incidents occurring as a result of an aircraft colliding with a bird weighing less than 2kg.
  2. There are reports, reportedly coming from CASA, that the sub-2 kg rule is being pushed through to reduce workload on CASA. The very significant delays in CASA RPA approvals are well known throughout industry. While this may not be true, it is becoming a very widespread belief in industry and is not helping the reputation of CASA.
  3. Some of the [manufacturer] range manuals state empty and payload weight that together add up to a maximum take-off weight (MTOW) greater than 2 kg. When asked, [manufacturer] now say the stated payload figure should be read as MTOW, even though that results in a camera payload of less than the Go-Pro cameras recommended for the aircraft. It is suspected that [manufacturer], and other manufactures, may be trying to ensure their product comes into the perceived new CASA sub-2 kg rule.

The reporter advised that with the improving technologies in batteries and cameras, this now includes the majority of commercial aerial photography. An example of this is the [manufacturer] range used by the majority of real estate aerial photography users. The new data from the manufacturer seems to now indicate that the RPA weighs less than 2 Kg.

This will be an unintended consequence to this exclusion as commercial photographers with no aviation experience will be operating, without completing any aviation training, in populated areas and in controlled airspace.

Regulator's response (Regulator 1)

CASA has reviewed the REPCON and in response to the expressed safety concern related to the exclusion of Remotely Piloted Aircraft (RPA) which are in the sub-2 kg category in the proposed CASA regulations I can advise:

  1. CASA commissioned and published research papers in 2013-14 in relation to the likelihood of human injury and aircraft damage resulting from impacts with sub-2 kg Remotely Piloted Aircraft (RPA). The results of this research and analysis were that in both cases, the risks from these operations are very low. This view is based on engineering modelling, not anecdotal opinion. A significant difference with airborne bird strikes is that there is only likely to be a single RPA involved, rather than the multiple strikes often experienced with flocks of birds.
  2. While there will be a flow-on effect for CASA operations in reducing the approvals for sub-2 kg operations CASA has determined that they pose a very low risk to other aircraft, people and property. While CASA's entry control workload may reduce as a result of the amended legislation, the resources freed-up will allow increased surveillance of the industry overall to ensure compliance with the standards by a greater number of industry participants.
  3. CASA does not dictate how an operator should meet the weight criteria. That is up to the operator to decide. Commercial operators in the sub-2 kg class will be required to acknowledge that they have read and understood the information in a new Advisory Circular (AC101-10). CASA also notes that model aircraft of similar weights have been flown safely for many years, including within controlled airspace, without any CASA requirements for aviation training or experience.
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Last update 18 September 2015