RPAS laws in Australia
The regulation of RPAS in Australia is administered via the Civil
Aviation Act 1988 (the Act) and the Civil Aviation Safety Regulations 1998
(CASR) established under the Act. Part 101 of the CASR, introduced in 2001,
specifically regulates unmanned aircraft.
In 2016, Part 101 of the CASR was amended in an effort to reflect the
drastically changed operating environment for RPAS since Part 101 first took
effect in 2001. This chapter explains the 2016 amendments and considers the
evidence about the impact of these changes to RPAS use in Australia.
The chapter also considers the international and domestic legislative
framework in place to regulate the operation of RPAS; the penalty regime for RPAS
misuse; and the concerns raised by witnesses and submitters.
The Chicago Convention and the International Civil Aviation Organization
The Convention on International Civil Aviation, also known as the
Chicago Convention, was signed in 1944. The convention establishes rules of
airspace, aircraft registration and safety, whilst also detailing the rights of
signatories regarding air travel. It applies to civil aircraft and excludes aircraft
used in military, customs or police services.
Article 8 of the convention provides that 'pilotless aircraft', including RPAS,
are prohibited from flying over the territory of a contracting State, without
special authorisation. Article 8 notes:
Each contracting State undertakes to insure that the flight
of such aircraft without a pilot in regions open to civil aircraft shall be so
controlled as to obviate danger to civil aircraft.
The Chicago Convention also established the International Civil Aviation
Organization (ICAO), a specialised United Nations agency responsible for
coordinating and regulating international air travel. The goal of ICAO in
relation to RPAS is to provide an international regulatory regime through
Standards and Recommended Practices (SARPs), with supporting Procedures for Air
Navigation Services (PANS) and guidance material, to 'underpin [the] routine
operation of UAS throughout the world in a safe, harmonized and seamless manner
comparable to that of manned operations'.
According to ICAO:
The principal objective of the aviation regulatory framework
is to achieve and maintain the highest possible uniform level of safety. In the
case of UAS, this means ensuring the safety of any other airspace user as well
as the safety of persons and property on the ground.
Addressing a growing global concern
In light of the proliferation of RPAS worldwide, a growing number of
ICAO member states expressed concern to the international body about reported
incidents of RPAS flying near airports and creating hazards for commercial aircraft.
To support the development of appropriate regulations, ICAO formed a UAS
Advisory Group in March 2016 to share best practice and develop guidance
material for the 191 ICAO member states.
In October 2016, the member states requested that ICAO consider developing
a management tool for UAS operating at low altitudes and to explore
registration and identification solutions.
ICAO acknowledged the concerns and released a publication ahead of Christmas in
December 2016 to provide recreational RPAS users with tips on safe RPAS use.
The publication noted that RPAS can 'pose a serious threat to manned flights
and people and property on the ground'.
Whilst ICAO has been involved in further discussions about harmonising
UAS regulations, and continues to hold symposiums across the globe to
facilitate this work, the responsibility for regulation at the national level
falls to the individual states, as per Article 8 of the Chicago Convention.
According to Article 8, standards relating to the maximum weight or
authorised flying altitude for various categories of RPAS are a responsibility
for national civil aviation authorities, with ICAO serving only an advisory
role. To this end, in December 2016, ICAO launched a UAS toolkit to guide
member states in developing their own UAS regulations.
The toolkit highlights the multitude of challenges facing member states
in developing appropriate UAS regulation, including managing the expectations
of the UAS industry; providing training materials to educate operators;
advancing harmonization with international counterparts; engaging legal
authorities to strengthen enforcement capacity; and managing large volumes of
new operators or new types of operations.
Australia's legal framework
In Australia, the Civil Aviation Act 1988 (the Act) establishes
the regulatory framework for maintaining, enhancing and promoting the safety of
civil aviation, with a particular emphasis on preventing aviation accidents and
The Act provides for the establishment of regulations and gives effect
to the provisions of the Chicago Convention relating to safety. Subsection 9(1)
of the Act outlines the role and responsibilities of CASA. It states that CASA:
...has the function of conducting the safety regulation of...civil
air operations in Australian territory by means that include...developing and
promulgating appropriate, clear and concise aviation safety standards; and
issuing certificates, licences, registrations and permits.
In terms of the overall civil aviation framework, CASA is the regulator;
DIRDC is responsible for policy; the ATSB is responsible for the investigation
of aviation incidents and accidents; and Airservices Australia is responsible
for service provision, including air navigation, and aviation rescue and
Part 101 of the Civil Aviation
Safety Regulations 1998
As noted in Chapter 1, Australia was the first country to allow
commercial UAV activities, with CASA the first body in the world to regulate
the operation of RPAS. Part 101 of the Civil Aviation Safety Regulations 1998
(CASR) was first introduced in December 2001 to provide a regulatory framework
for RPAS, with the aim of enabling the technology to progress without
compromising the safety of other airspace users, people and property. It is the
primary instrument governing the civil operation of all types of 'unmanned'
aircraft in Australian airspace including model aircraft, remote controlled
aeroplanes and helicopters, blimps, rockets, kites and RPAS.
When first introduced in 2001, the regulations contained in Part 101 of
the CASR were considered ground-breaking. According to many within the
industry, the success and advancement of Australia's UAV industry is largely due
to the flexible approach outlined in the regulations.
However, CASA developed the regulations at a time when there were only a few
operators in the country, with the majority of them commercial.
Since the introduction of the CASR in 2001, the number of RPAS users has
grown rapidly. In 2007, there were less than 25 certified RPAS operations in Australia.
By the end of March 2016, the number had grown to 500.
Similarly, the number of ReOCs issued by CASA rose from 70 in February 2014 to
1106 in July 2017.
By February 2018, CASA reported approximately 1283 ReOC holders and 7380 RePL
holders in Australia, with an estimated 50 000 additional unregistered RPAS
being operated for sport and recreational purposes.
A review of the regulations, to encompass the increased number of hobbyist and
amateur operators, was therefore considered necessary to keep pace with the
evolution of RPAS use.
Civil Aviation Legislation
Amendment (Part 101) Regulation 2016
On 29 September 2016, following a review of the regulations, amendments by
way of the Civil Aviation Legislation Amendment (Part 101) Regulation 2016 came
into force. CASA noted the following in relation to the changes:
Globally, aviation safety regulators are facing the same
kinds of challenges: to maintain high levels of safety without unnecessarily
impeding progress or unduly constraining commercial opportunities to use a
technology capable of a multitude of beneficial humanitarian, economic and
recreational applications. Responding to these challenges, CASA introduced
important amendments to the regulations that took effect in September 2016.
Prior to the 2016 amendments, all RPAS, regardless of weight or
operation, were regulated under the CASR as a single category.
Operators of UAV were required to obtain a RePL or ReOC in order to conduct
operations. However, under the new regulations, operators of RPAS below 2kg are
no longer required to obtain these qualifications. Along with the introduction
of weight categories, the new regulations also make the distinction between
commercial operators, and those using RPAS 'for the purpose of sport and
CASA explained that the intention of the amended Part 101 was to seek a
balance between managing risk and encouraging innovation.
It noted that the changes enhanced the existing safety framework by introducing
new provisions to strengthen and clarify the requirements and limitations
governing the safe operation of RPAS. At the same time, the changes aimed to reduce
the 'cost and legal requirements for lower-risk RPA operations',
and effectively 'cut red tape'.
The committee noted that the amendments made a number of significant
changes to the CASR, including:
new weight classifications for RPA;
reduced regulatory requirements for 'excluded' category RPA;
the establishment of standard operating conditions for RPA; and
the establishment of a series of new offences relating to the
environment in which RPA can be operated.
New weight classifications
The amended regulations recognise five types of RPA based on size and
weight as provided in Table 2.1 below.
Table 2.1: New weight classification for Remotely
g or less
than 100 g but less than 2 kg
least 2 kg but less than 25 kg
least 25 kg but not more than 150 kg
than 150 kg
New 'excluded' category
The amendments introduced the concept of 'excluded' RPAs for lower risk
categories of use. The meaning of 'excluded' category RPA is laid out in
Regulation 101.237 of the CASR, but generally includes both commercial and
recreational operators of RPAS below 2kg.
Operators of 'excluded' RPAS have reduced regulatory requirements and
are permitted to use their RPAS without a ReOC or RePL, and can therefore
operate without formal training or safety education.
Excluded category RPAS are not subject to formal registration requirements,
unless being flown for commercial purposes, in which case an aviation reference
number is required.
In addition, the 2016 amendments introduced the following provisions:
persons conducting operations for 'hire and reward' using very
small RPAs (100g to 2kg) are not required to have a ReOC or a RePL. They do,
however, have to notify CASA at least five days before flying, and must operate
in accordance with the standard operating conditions. Notification is valid for
private landowners are permitted to carry out some
commercial-like operations on their land under the 'standard RPA operating conditions'
without requiring a ReOC or RePL on two conditions: the RPA in use is below
25kg, and none of the parties involved should receive remuneration; and
for RPA weighing between 25kg and 150kg, the operator needs to hold
a RePL in the category of aircraft being flown.
Standard operating conditions
The standard operating conditions applicable to RPA are set out in
Regulation 101.238 of the CASR. Under the standard operating conditions, RPA
operators must abide by the following rules:
the RPA is operated within the visual line of sight of the person
the RPA is operated at or below 400 feet (120 metres) above
ground level (AGL) by day;
the RPA is not operated within 30 metres of a person who is not directly
associated with its operations;
the RPA is not operated:
in a prohibited area or in specified restricted areas
over a populous area
within 3 nautical miles (5.5 kilometres) of the movement area of
a controlled aerodrome;
the RPA is not operated over an area where a fire, police or
other public safety or emergency operation is being conducted, without the
approval of the person in charge of the operation; and
the person operating the RPA is only operating that RPA.
These requirements were expressly noted in a Notice of Final Rule Making
(NFRM) on August 2017,
and later in a direction issued under Regulation 11.245 of the CASR on
17 October 2017.
According to CASA, standard operation conditions apply when using
excluded RPAs, both for recreational or commercial purposes. Those using RPAs
in breach of those conditions must notify CASA and may have to apply for a
licence or exemption.
CASA 96/17 Direction
Following the introduction of the 2016 amendments, CASA told the
committee that there was a need to remove some ambiguity about the rules around
the use of recreational RPAS, including the prohibition of flights above 400
feet and within 3 nautical miles of an aerodrome.
Whilst the standard operating conditions instructed RPAS operators not to operate
within 3 nautical miles of a controlled aerodrome, the new rules established
that RPAS operations should also not occur near a non-controlled aerodrome,
should the operator become aware that a manned aircraft is being operated to or
from the site.
Other changes included the imposition of a weight limit on RPAS
operating in the movement area of aerodromes,
and clarification around the operation of RPAS over emergency operations.
Penalties and offences
A breach of the regulatory requirements set out in Part 101 of the CASR
constitutes a strict liability offence in most cases for which:
a penalty of a fine of up to 50 penalty units or $10 500 (imposed
by a court on conviction) may be applied; or
the issuance of an aviation infringement notice by CASA requiring
the payment of an administrative penalty of up to 5 penalty units or $1050 (in
default of which the matter would be referred for prosecution) can be applied.
The reckless operation of an unmanned aircraft which endangers the life
of another person, or endangers another person or another person's property, is
recognised as a serious offence under the Act. Upon conviction, a person may be
sentenced to a period of up to 5 years in prison for endangering another
person's life, and up to two years for otherwise endangering another person or
another person's property.
Aviation Infringement Notices
CASA informed the committee that a penalty specified in a regulation is
the maximum amount a court may impose on a person convicted or found guilty of
an offence against that regulation. CASA may issue an aviation infringement
notice (AIN) for offences under the CASR. The amount of the penalty imposed by
an AIN is specified in regulation 296A of the Civil Aviation Regulations 1988 (CAR)
if the maximum penalty a court could impose for the offence is 5
or 10 penalty units, the prescribed penalty for an AIN issued for that offence
is 1 penalty unit;
if the maximum penalty a court could impose for the offence is
15, 20 or 25 penalty units, the prescribed penalty for an AIN issued for that
offence is 3 penalty units;
if the maximum penalty a court could impose for the office is
more than 25 penalty units, the prescribed penalty for an AIN issued for that
offence is 5 penalty units.
Converted into dollar amounts, the range of penalties a court may impose
for offences against the provisions in CASR Part 101 is any amount from $2100
to $10 500 (depending on the penalty specified in the regulation).
The range of penalties that CASA may impose through AINs issued under those
regulations are also fixed amounts between $210 and $1050, depending on the
penalty specified in the regulation.
Information provided by CASA in September 2017 revealed that since 2015,
nine AINs related to RPAS had been issued. The first prosecution was made in
January 2015 when an RPAS operator in Townsville received an $850 fine for operating
the RPAS within the Townsville Control Zone. The RPAS was flown within 3
nautical miles of Townsville Airport, above 400 feet, at night, over populous
areas, and within 30 metres of people not directly associated with the
operation of the RPAS. Whilst the offender had breached the regulation multiple
times, a single fine was issued.
A more recent prosecution was made on 10 July 2017 when an RPAS
operator was fined $900 for 'hazardous flying at and near guests' at a wedding
in Kangaroo Valley. CASA told the committee that another person was fined $900
on the same day after their RPAS came too close to a group of children at an Easter
egg hunt in Canberra.
Noting the range of offences and fines applied over some years, the
committee questioned whether the penalty regime for RPAS-related offences had
been applied consistently. However, CASA noted that '[i]n the exercise of its
discretion, and consistent with the approach reflected in CASA’s Enforcement
Manual, CASA may issue a single AIN for more than one offence of the same
kind committed by the same person', as was the case with the incident in
The committee was further advised that varying fines were the result of the
changing value of a penalty unit, as defined in the Crimes Act 1914.
Concerns raised in evidence regarding the regulations
Inquiry participants' primary concern with the regulations related to
the classification of the recreational or hobby user as an 'excluded category' RPAS
operator, particularly given the growing number of hobbyists reported in recent
years. The argument was put to the committee that the amendments leave
recreational users effectively untouched as they are not required to undergo
any training or safety induction prior to operating an RPAS.
Concerns were also raised about the extent of due diligence taken prior
to the introduction of the amendments, the complex nature of the regulations,
and the effectiveness of the current penalty regime. These concerns are
detailed in the following section.
Concerns raised about 'excluded'
Many witnesses raised concerns that under the amended regulations,
excluded category operators are not required to undergo any formal training or
licensing commensurate to the risks that they pose. Yet, according to evidence
before the committee, there are now more than 5000 'excluded category'
operators in Australia, many of whom do not have an aviation background.
Inquiry participants argued that differentiating between recreational
and commercial RPAS operations did not justify relaxed requirements for new
users. The Australian Association for Unmanned Systems (AAUS) argued that under
a risk-based regulatory approach, 'regulations applicable to hobbyists and
recreational drones should be the same as those presented by commercial RPAS
operators'. In parallel, AAUS noted, effort is required to 'address issues
surrounding education and enforcement of the regulations'.
AusALPA suggested that there is a diminishing argument for the
regulatory divide between commercial and recreational RPAS operations,
particularly as passenger-carrying RPAS are a likely next step. It submitted
While we recognise that several years ago, the division
between private/recreational and commercial use was a reasonable proxy for
[consideration of RPA mass, frequency of use and location of use], the
explosion of availability of affordable RPAs has undermined that connection...
AusALPA further stated that the new rules would '[broaden] the base of barely
constrained users while undermining the market for the highly invested and
highly constrained commercial users'.
For many submitters, the development of the 'excluded' category appeared
to be 'a de-reg[ulation] of the entire UAV (drone) industry', allowing
untrained operators to fly their RPAS without first understanding the potential
The International Aerospace Law and Policy Group (IALPG) commented that it is 'alarming'
to roll back the very protections that had allowed safe operation before the
changes to CASR Part 101,
while Austec Aerial Solutions went further to describe the legislation as a
'complete failure' that would lead to injuries, and reckless and illegal RPAS
Concerns about due diligence conducted
prior to the amendments
Submitters also raised concerns about the extent to which CASA undertook
its due diligence before introducing the amendments. In particular, witnesses
pointed to the extremely short consultation period prior to the introduction of
CASA engaged in consultation with industry and the public about the
proposed amendments for approximately one month between 14 May 2014 and
16 June 2014 through a Notice of Proposed Rulemaking (NPRM 1309OS). CASA
received 90 responses, including two which had established petitions with a
total of 430 signatures.
In response to feedback on the amendments, CASA then prepared a new draft of
the regulations and submitted it to the UAS Standards Sub-committee (UASSC),
and CASA's RPAS Operations Office, for review.
The IALPG pointed out that the 2016 regulations came into force more
than two years after the initial consultation period, and did not reflect the
'leaps and bounds' that had been made in understanding the risks associated
'with all sizes of drone' since that time.
This concern was echoed by Maurice Blackburn Lawyers who were critical of CASA's
lack of research on the likelihood of injury occurrence from RPAS, compared to
Mr Joseph Urli of Australian Certified UAV Operators argued that the
decision made by CASA to relax the regulations went directly against the
recommendations of the wider aviation industry. He stated:
CASA's notice of proposed rulemaking was not a fair and open
process. More than one person between CASA and industry had preconceived ideas
about deregulating the industry and both the public consultation process and [the
UAS Standards Sub-committee's] support was manipulated to achieve the desired
outcome. The large majority of the actual industry certified commercial
operators, numbering just over 100 operators at the time of the [notice of
proposed rule-making], were against the deregulation for good reason.
The committee was also informed that, during risk assessments of the key
changes proposed in the amendments, CASA's own risk matrix, which incorporates
both likelihood and consequence values for a collision, was misinterpreted to
produce a low risk rating. It was noted in evidence that the conclusions made
by the two CASA-commissioned studies undertaken by Monash University diverge
significantly from the conclusions made in similar studies overseas.
In addition to these concerns, the committee heard criticism that CASA did
not fully grasp or consider how the relaxation of rules may impact on the
number of 'undesirable' RPAS operations undertaken by excluded category users.
According to submitters, CASA effectively 'opened the flood gates',
and abrogated responsibility in a way that was out of step with its usual
To this end, questions were raised about the proliferation of recreational RPAS
operating in Australia, with some witnesses questioning how CASA could relax
the regulations without having a clear picture of the total number of
recreational RPAS users in the country. Airservices Australia acknowledged
these concerns, noting that the number of RPAS in Australia presents 'an
emerging and insufficiently understood transport safety risk'.
Concerns about the complexity of
An additional concern of many submitters was that the regulations are in
and of themselves too complex. Mr Chris Bird stated:
CASA has tried to apply a full size aviation solution to
something that is now in the hands of the common person. To fly a full size
aircraft you need a lot of training and getting access to a plane is not easy
without having a license [sic]. The common person hasn’t had this training and
the expectation is that they just know about these things. Right now the
regulations are just too complex for the common person to understand.
Representatives from law firm Piper Alderman supported this view, stating:
...the language used in the CASA Regulations is likely to be
difficult for a lay person to navigate and interpret; for example, Reg 101.280
provides various strict liability offences in respect of the operation of RPAs
in "populous areas" but the definition of "populous area"
provided in Reg 101.025 is legalistic and not easily translated for real
As noted above, it is hardly accurate to describe the CASA
Regulations as "simple".
The committee heard that it is not only the regulations that are perceived
as convoluted, but also the advice provided directly by CASA. Mr John
Reidy-Crofts suggested that CASA's advice is overly technical and hard for the
public to understand. He referred to correspondence he received from CASA which
used terminology such as 'VFR', 'deconfliction' and 'uncontrolled air space'.
According to Mr Reidy-Crofts:
Until I read the CASA Advisory Circular, and made further
enquiries by gaining web site access to how airspace is managed in Australia, I
was not aware of what these terms meant.
...I hold serious concern that under the current CASA Licensing
and Operational rules for RPAS, a child or person of unsound mind, can operate
a small (excluded) RPA without any pre-requite [sic] training or license
requirements. I have also concerns over adults who may be of sound mind but
have no understanding of VFR or other terms as mentioned above.
Concerns regarding the recording of
According to the ATSB, an aviation occurrence is reported and recorded when
it is deemed to be:
an accident involving death or serious injury, aircraft
destruction or serious damage, or property destruction or serious damage;
a serious incident involving circumstances indicating that an
accident nearly occurred; or
an incident associated with the operation of an aircraft which
affects or could affect the safety of operation.
However, submitters highlighted a number of issues with the current
system of recording aviation occurrences, particularly with regard to RPAS
incidents. Such information is an important means of measuring the
effectiveness of the regulations.
Aviation occurrence reporting requirements are provided under the Transport
Safety Investigation Act 2003 and the Transport Safety Investigation
Regulations 2013. Airservices Australia is responsible for collecting
occurrence data, and recording it in their Corporate Integrated Reporting and
Risk Information System (CIRRIS). According to an Airservices Australia
representative, the database captured by CIRRIS is not publically available,
but reports can be sent to the ATSB when required under the Transport Safety
Investigation Act 2003.
Airservices Australia told the committee that, while there is currently
a 'very high reliance on pilot reports', it is working on enhancements to the
safety performance, monitoring and reporting systems 'to improve the management
of RPAS operational safety', such as through accurate occurrence reporting.
In addition to the CIRRIS database, the ATSB also records RPAS-related
incidents on the National Aviation Occurrence Database. The occurrence notifications
recorded in this database must meet a number of criteria, including that the
incident is deemed a 'transport safety matter'. Notifications not meeting the
criteria are classified as 'events' and excluded from the database.
As Australia's national transport safety investigator, the ATSB is
currently resourced to investigate around 140 aviation accidents and incidents
per year from approximately 5500 reported.
ATSB told the committee that it historically 'has not had sufficient resources
to investigate all accidents and serious incidents'. However, it does record
data 'for safety research, analysis and education'.
Information made available by CASA showed that, in the past five years, the
ATSB has published 10 investigations into RPA incidents, including two research
investigations in 2017. This is from a total of 151 reported RPA near
encounters with manned aircraft in 2017.
Along with these resourcing pressures, witnesses raised concerns that
there are also gaps in the current methodology for gathering aviation occurrence
data. According to Regional Express (Rex), the criterion for reportable
activity is too narrow, causing many instances of illegal or dangerous RPAS
activity to be deemed to be 'non-reportable events'.
Another issue raised was the heavy onus on members of the public to
provide information to CASA before a complaint can be verified, or an
infringement notice issued to the offending operator. According to CASA's
We are unable to pursue enforcement action unless we have
Please provide photographic/video evidence showing the
possible safety breach. If this footage does not clearly display the individual
operating the drone/RPA, further evidence may be required.
Austec Aerial Solutions likened this requirement to 'reporting a
burglary to Police and the Police ask[ing] you to provide all evidence so they
can charge the offenders'.
Mr Vince Sofia added that 'it should not fall into the hands of licensed
drone operators to become a "watchdog" for CASA, nor do we want too
A lack of regulatory resources, as well as the fact that recreational RPAS and
their operators are not registered, was blamed for the poor reporting system in
By CASA's own admission, a vast majority of cases remain unresolved as
'it is often extremely difficult to identify who was responsible for the
alleged conduct, and challenging to obtain sufficient evidence to support any
Concerns about the penalty regime
The evidence provided to the committee with regard to the penalty regime
raised two key issues. The first is that the penalty regime in its entirety is
an insufficient enforcement mechanism, as it does little to discourage unsafe RPAS
operations. Under the existing regime, a fine of up to 50 penalty units for a
breach of CASA's rules equates to approximately $10 500.
AusALPA noted that this amount is 'inadequate or at best unclear' in the case
of a serious incident involving manned aircraft.
NSW Farmers highlighted that RPAS misuse can also pose a hazard to other
operations, particularly agricultural activities. The lack of civil remedies
available to farmers that have caught RPAS trespassing on their property was of
NSW Farmers advocated for a base penalty of at least $50 000, contingent
upon 'the potential for harm and the amount of due diligence not undertaken by
the UAS operator'.
The Aerial Application Association of Australia was of the view that
penalties should be raised in order to account for the potential loss of income
for aircraft that are forced to stand down when an RPAS flies into restricted
Elevo agreed that the current level of penalties should be increased, and should
include a temporary or permanent prohibition measure for companies or
individuals found guilty of illegal operations.
Under the current system, CASA publishes formal enforcement decisions
online. It does not publish information on suspensions, cancellations or fines.
However, a number of submitters including the Australian Miniature Aerosports
Society took the view that the publication of all such breaches would serve as
a stronger disincentive to RPAS misuse.
The Aerial Application Association of Australia suggested that the publication
of RPAS prosecutions would act as a major deterrent for reckless RPAS users,
whilst AAUS agreed that it would 'establish a precedent' and deter operators
that may have ill-intent or are simply unaware of the rules.
The second major issue regarding the penalty regime is that of
inadequate resources allocated to the regulator. The committee received
evidence indicating that, without sufficient staff training and resources, CASA
is unable to effectively enforce the regulations in a way that responds to the
growing cohort of amateur RPAS operators. This includes being unable to
investigate the multitude of incidents breaching the standard operating
conditions, and issue aviation infringement notices to offenders.
The issue of cost-effective solutions for RPAS management is discussed further
in Chapter 7.
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