Safer Skies: Registration and education
In the previous chapter, the committee considered the widespread concern
that unrestricted use of RPAS will lead to a serious aviation incident in
Australia. This chapter examines in greater detail the concerns of witnesses
and submitters, and evaluates registration and education as solutions proposed
by a variety of RPAS and aviation industry stakeholders.
Identifying all RPAS operators
A key concern raised by inquiry participants was that many RPAS cannot
be traced to their operators and that such operators are not required to report
to CASA on where and how their RPAS will be flown. Unsure of just how many RPAS
are in the sky, AusALPA highlighted a series of other unknowns:
We do not know the geographical distribution of operations,
nor do we know what the operator demographics are. We also do not know if the
operator population has the same distribution of cowboys and criminals as the
general population. We do not know with any scientific vigour the probability
of an aircraft-RPA collision either in general, by industry sector or by
aircraft type. Critically, we do not know with any certainty what the
consequences are likely to be of an aircraft-RPA collision.
Under the new regulations, formal registration requirements do not apply
to model aircraft or RPA unless being flown for commercial purposes.
RPAS flown for recreation, and weighing less than 150kg need not be registered.
However, evidence provided by the ATSB suggested that Australia is out
of step with other aviation nations who have taken a more comprehensive
regulatory response. The US, UK, Canada, France and New Zealand have all either
established or are moving towards a registration system and a requirement for RPAS
to display identification markings.
Current legislation in the US distinguishes between RPAS flying under
the Special Rule for Model Aircraft, and those flying for commercial purposes.
The Special Rule for Model Aircraft is similar to the excluded category of RPAS
under the CASR Part 101. RPAS below 250g that fly exclusively under the Special
Rule for Model Aircraft may be registered on a voluntary basis.
However, RPAS above 250g are subject to mandatory registration, costing the
operator USD $5.00. Once registered, an RPAS operator is provided with a unique
identification or tail number which must be displayed on the RPAS. Registration
is valid for three years and failure to comply results in severe civil
In 2018, it was announced that over one million RPAS had been registered.
In Canada, all recreational RPAS below 35kg must be clearly marked with
the owner's name, address and telephone number.
Furthermore, Transport Canada conducted a public consultation in
October 2017 about proposed registration rules for RPAS operators. The
proposed rules seek to introduce additional registration requirements in 'small
complex' areas such as aerodromes and urban spaces.
The UK Civil Aviation Authority is considering a similar regulatory
change to mandate the registration of RPAS over 250g,
whilst in South Africa, registration for RPAS of all sizes is mandated by law.
In Ireland, all RPAS weighing more than 1kg must be registered while RPAS
weighing less than 1kg are limited to operating at a height restriction of 50
feet, unless they are registered. Since December 2015, when RPAS registration
became mandatory, the Irish Aviation Authority (IAA) has registered over 8000 RPAS
and model aircraft.
Upon registration, RPAS users in Ireland have access to the IAA official
aeronautical data, mapping and RPAS registry.
Submitters also drew the committee's attention to a Joint Statement
issued in September 2016 by 16 aviation sector parties (including the
International Air Transport Association) in support of a European Union-wide
regulatory safety framework for RPAS.
The signatories made seven recommendations relating to public education,
training, research, and technical performance limitations by way of
geo-fencing. In relation to registration, the signatories called for the
registration of all RPAS to 'occur compulsorily at the time of purchase or
The signatories noted that:
If the owner/pilot can be traced, it will encourage compliance
with rules & regulations and could also serve as a motivation for training.
The IALPG argued that Australia's regulations are out of step with the
measures set out in the Joint Statement. It suggested that the regime in
Australia 'sends a message that the skies are free to 2kg and under RPAS
operators, and encourages rogue flights'.
As a starting point, the IALPG and other witnesses expressed support for
a mandatory registration scheme for RPAS users in Australia as well as the
provision of an identifying code or marking attached to individual RPAS.
These views were echoed in CASA's review of RPAS operations, whereby 86 per
cent of the 910 respondents indicated support for at least some form of
registration. According to CASA's analysis report, the majority voiced a
preference for RPA registration by weight, with 250g being the most commonly
This is consistent with registration requirements in the US and UK.
Identification in incidents or
A number of submitters argued that a compulsory registration system rightfully
places the onus of responsibility on the RPAS operator who could be easily
traced in the case of an incident.
The Executive Director of AAUS, Mr Greg Tyrrell, noted that registration could
act as a disincentive for non-compliant use of RPAS:
I think registration might help with deterring people from
doing the wrong thing, if they think they are going to get caught. It is like
if you are going to get caught with your car speeding, with your registration number.
I think that will help as a deterrent as long as people are aware of what the
rules are. So I think there is some merit in going down that track.
Submitters suggested that the RPAS operator should be required to
register themselves online and that registration markings should be physically attached
to the RPAS, by way of an engraved registration number or identifying code.
Helistar Aviation observed that the mandatory requirement should be similar to
the registration process for road vehicles.
Alternatively, Mr Chris Roberts, Managing Director of Parrot ANZ proposed
that registration be attached to the operator rather than the RPAS, much like a
A registration system could be created that encourages a
user-friendly process and is suitable for mass-market product. We believe
strongly that it should be online, free of charge and faster—basically instant.
If you buy a product, you need to register today and be approved today. It
should be the operator that is assigned a unique number. It should not be the
drone; it should be the operator, a bit like a driving licence. The applicable
rules and what the operator is signing up for and complying with should be
Other submitters argued that visual displays of registration alone are
insufficient for identification purposes, and should be accompanied by a
technological component such as an in-built chip.
Representatives from Parrot ANZ noted that this technology already exists
within their products, whereby users may opt-in to a registration regime
through the company app, thus consenting to provide global positioning system (GPS)
and mapping data for the purpose of technical analysis.
The committee was also made aware of the AeroScope technology built into new
products by DJI, one of the largest manufacturers of civilian RPAS. According
AeroScope uses the existing communications link between a
drone and its remote controller to broadcast identification information such as
a registration or serial number, as well as basic telemetry, including
location, altitude, speed and direction. Police, security agencies, aviation
authorities and other authorized parties can use an AeroScope receiver to
monitor, analyze and act on that information. AeroScope has been installed at two
international airports since April, and is continuing to test and evaluate its
performance in other operational environments.
AusALPA stated that a registration regime would be consistent with the identification
requirements that currently apply to the purchase of mobile phones and SIM
cards. It argued that it should be 'necessary to provide valid identification
to purchase a regulated RPAS in big primary and secondary markets'. In doing
so, CASA would be empowered 'to prevent collisions rather than investigate the
with the added benefit of improving data gathering of the types, numbers and
use of RPAS in Australia.
The opportunity for data collection was also reflected in CASA's review into
Registration provides a mechanism to gather data on total RPA
numbers, RPA types, locations, and the operational categories (commercial
versus recreational) RPAs are being used in. This data would be useful to
determine the resources required to adequately oversight the safety of RPA operations
in Australia and to more accurately determine the likely impacts of proposed
A deterrent for misconduct
Many inquiry participants upheld the view that registration should apply
to all RPAS operators, including commercial and recreational users.
Concern was expressed that by simply 'recommending' that commercial
operators stamp their aviation reference number on to their RPA, the current
regulations do not go far enough to deter RPAS misconduct.
Mr John Tessarolo of regional airline, Rex, told the committee:
CASA basically says that operators that are required to
notify CASA should either attach to or insert into their aircraft a fireproof
identification plate or write in the identification details in indelible ink.
That is about as far as the regulator has gone in actually saying, 'Let's
identify these drones.' So, it really comes down to the regulations keeping up
According to AusALPA, the tightening of regulations and implementation
of a mandatory registration regime could send a message to all RPAS operators
that 'they are operating in a highly regulated system'. CASA's review paper supported
this, stating that 'a person would be less likely to operate unlawfully when
their RPA is more readily identifiable by authorities in the instance were
[sic] the RPA operator operates unlawfully'.
AusALPA expressed hope that a review of the regulations would lead operators to
further explore and understand the legal and safety constraints on RPAS
Drone Safety Services suggested that multi-step processes could be added
to the registration system over time to enable the provision of insurance, or
to confirm the applicability of an existing policy.
By requiring the registration of all RPAS, Helistar Aviation noted that it
would then be possible to ensure that devices are insured for third party
liability whilst also enabling the tracking of operators after incidents.
In many jurisdictions overseas, insurance requirements for RPAS are
already in place. In the European Union, all RPAS weighing less than 500kg are
required to have public liability cover of approximately AUD $1.1 million.
Public liability insurance of at least $100 000 is also required in Canada
for all RPA weighing more than 250g.
Insurance cover is made possible through mandatory registration that allows RPAS
operators to be accountable in the event of an accident or incident.
In Australia, there is no requirement for RPAS operators to purchase
insurance. However, commercial RPAS operators are typically expected to have
public liability coverage as part of state and territory business obligations.
Whilst the committee heard that club membership with the Model Aeronautical Association
of Australia (MAAA) and associated clubs includes insurance cover of $20
million public liability,
the vast majority of recreational RPAS operators are unlikely to be insured to
cover damage or injury caused by devices under their control. The Insurance
Council of Australia stated that this leaves many amateur RPAS operators
financially vulnerable in the case of RPAS system failure or operator error
resulting in personal or property damage.
According to submitters, the benefits of public liability insurance
cover extend far beyond individual compensation. Coupled with a robust
registration regime, operators with insurance cover would become more visible,
accountable, and traceable in the case of an accident or incident. According to
Mr Ashley Fairfield, the possession of an operators certificate and the
associated insurance policy for his business, regularly acts as a deterrent for
unsafe flight. In contrast, amateur or recreational operators who have 'no skin
in the game' may be more inclined to illegally take on jobs or unsafe
operations as 'they will most likely lose nothing but the fee they got for the
The Little Ripper Group likened this behavioural change to the
'self-regulation' of the automotive industry, in which drivers must be
licenced, and cars insured. They suggested that this seemingly risk-averse
culture could be emulated in the RPA industry through implementing similar
insurance coverage requirements.
The IALPG pointed out that, without the introduction of a registration
requirement allowing RPAS to be easily identified, strict liability
compensation under the Damage by Aircraft Act 1999 would be 'nearly
impossible to enforce'. They remarked:
The legal regime which could act to provide the injured with
remedies against drone operators...has little ability to operate as intended if
the relevant aircraft operator is unable to be found.
Additional evidence from Australian Certified UAV Operators demonstrated
how the lack of registration and insurance has previously resulted in a
bystander footing the bill for an RPAS operator's mistake:
In August 2016 a DJI Inspire 1 RPAS collided into the front
of a new Mercedes GLS as it was being driven across the Sydney Harbour Bridge.
The impact left part of the RPAS embedded in the car bodywork and other debris
scattered across the road. Because of heavy traffic the vehicle was travelling
at a slow speed; had the traffic been moving faster the incident could have
affected several vehicles and resulted in greater damage in general. Because
the operator of the RPAS remains unknown, and despite police investigations,
the owner of the motor vehicle has been left with the repair bill.
Noting that the cost impost of insurance would be 'problematic' for many
recreational RPAS operators, Professor Des Butler suggested that an alternative
solution could involve the issuance of educational material that highlights the
significant legal liability associated with irresponsible RPAS operation.
Evidence against mandatory registration
Although the committee received a large amount of evidence supporting
mandatory registration, a number of submitters, particularly those involved in
drone racing, argued that registration is unnecessary. According to these
submitters, the creation of a mandatory registration requirement would be
ineffective in policing those who are already prone to breaching the rules.
Drone racing club member and member of the MAAA, Dr Chris Thompson, stated:
The same people now who break the rules or don't care about
them will keep on doing so, and those of us who fly safely will get registered
but we aren't the problem and won't cause any problems...
The people who are the problem won't get registered, and the
resources required to catch them vastly outweighs the actual risk they pose.
Another drone racer questioned how mandatory registration would be
applied to RPAS consisting of custom made parts. Mr John Cotterill suggested
that risk assessment and verification are made more difficult in the case of
operators who frequently change the parts on their RPAS to modify its function.
Mr Robert Carpenter of One Giant Leap Australia also alerted the committee to the
increasing number of second-hand RPAS sales that may further complicate
The ease with which individuals are able to access RPAS presents one of
the most significant challenges to the establishment of a registration system. CASA
suggested that operators who are able to purchase an RPAS straight off the
shelf are unlikely to take active steps to register their device, while those
that choose to register 'would most likely comply with the relevant safety
requirements in any case'.
To address these challenges, the committee heard that registration
should therefore be required before the time of use, to enable basic safety
awareness training before operation.
The IALPG also suggested that registration could take place through an in-built
technological mechanism to be activated upon sale.
Additionally, the registration of RPAS used for racing purposes could be
captured by a dedicated sports administration body such as MAAA or Recreational
Aviation Australia (RA‑Aus), as is the case with other specialised
aircraft such as balloons and sport rotorcraft.
Educating all RPAS operators
The lack of training and education of RPAS operators presented another
issue with the existing regulatory framework for RPAS. As highlighted in
evidence to the committee, there is currently no formal procedure by which RPAS
operators must learn the standard operating conditions or certify compliance
with the rules. The only exceptions to this are commercial operators of RPAS
over 2kg who are required to obtain a ReOC or RePL.
Yet, submitters suggested that there is a real prospect that RPAS will be
increasingly manned by inexperienced operators who are unable or unwilling to
understand the operating restrictions placed on their RPAS use.
Submitters noted that the mass introduction of RPAS on the consumer
market has rapidly expanded the availability of RPAS from specialist military
stakeholders to everyday retail consumers with limited training or aviation
At the same time, RPAS technology has become more advanced, offering
technological enhancements such as greater reliability, increased battery life,
and longer operating ranges, all at a decreasing cost. The Australian Airports
Association noted that these factors have contributed to a growing cohort of
inexperienced operators accessing and operating sophisticated technology:
Familiarity and enthusiasm with the technology encourages
amateur operators to upgrade to more and more sophisticated RPAS devices. As
the sophistication grows, so do the operating capabilities of these systems and
therefore the potential risk to aviation safety.
The IALPG commented further:
Australia's very wide and clear skies are a temptation for
all untrained, and amateur operators – the problem with the deregulation of
commercial operation is simply that it makes the problematic malicious,
uncaring, or untrained recreational operator, a legitimate operator, and
thus one who can make money through their exploits.
VIPA suggested that many RPAS users, particularly those without a RePL,
have little regard for public safety and the risks associated with operating an
unmanned aerial vehicle. It highlighted numerous reports of illegal flights
over populated areas and at night, both of which are contrary to the current
The Australian Certified UAV Operators took the view that many illegal
operations were borne 'out of naivety' as many such operators 'have not read
the regulations correctly or interpreted them correctly'.
Research from the UK Civil Aviation Authority revealed that only 36 per cent of
buyers receive guidance about safe flying when buying an RPAS.
In Australia, it is difficult to quantify the number of recreational RPAS
users, due to the lack of a registration system, let alone the number who take
the time to understand the rules for safe operation. When an RPAS is purchased,
the operator is provided with a yellow brochure titled 'Flying with Control?'
and is directed to the CASA website for further details.
However, submitters stated this piece of information was 'very simplistic' and
provided only the bare minimum amount of guidance to new RPAS users.
Contrarily, hobbyist users were keen to establish that their RPAS
operations are conducted under strict flying conditions and are generally
without incident. Mr John Cotterill, a recreational RPAS user, reported
that unauthorised or dangerous behaviour is frowned upon by the RPAS community,
which in many ways 'self‑regulates'.
Other recreational RPAS operators, particularly those with model
aircraft club membership, were regarded by submitters as 'a risk-averse and
mature set of operators' from which 'many lessons can be learned'.
Indeed, with the strict oversight of CASA's Sport Aviation team, Aeromodellers
New South Wales reported that all events and sites used by its members have the
'full support' of the regulator. Safe flying practices are promoted through a
comprehensive Manual of Procedures, and members undertake education programs
and direction from the MAAA.
Another educative initiative brought to the committee's attention was
the roll‑out of DJI's mandatory RPAS flight quiz. Since 14 February 2018,
RPAS pilots using DJI products are now required to correctly answer nine
questions about the rules for flying RPAS in Australia. The pre-flight quiz is
built into the mobile app used to fly DJI GO or DJI GO 4 products, and is also
posed to foreign flyers that have brought their DJI products to Australia to
fly. Australia is the third country to receive the DJI pre-flight quiz,
following similar launches in the US in October 2017 and the UK in December
Beyond the educational support associated with club membership, and
initiatives rolled out by individual manufacturers, the committee heard that
there is no overarching mandatory requirement to ensure new recreational RPAS
operators are aware of their safety obligations and are able to demonstrate an
appropriate standard of aviation awareness. In short, 'there are no checks and
balances' at a national level to ensure RPAS users fully understand the
restrictions on RPAS operation and are competent to fly.
The Australian Certified UAV Operators suggested that, in implementing
the regulations, CASA made 'sweeping assumptions' that all RPAS operators have
sufficient aptitude to find the relevant aviation legislation and regulations
applicable to them; understand the aviation language and terminology contained
within the regulations; and grasp their legal obligations when operating an RPA.
The IALPG agreed, noting that the standard operating conditions are
ineffective if RPAS users are not educated on how to comply:
The legislation purports to preserve safety purely by having
such SOCs [standard operating conditions], but in reality...there is no
requirement that people take up the kind of aeronautical education that would
skill them to even comply with the SOCs.
A representative from Drone Solutions drew on personal experience to
demonstrate the level of complexity inherent in aviation regulations that
amateur RPA operators are unlikely to grasp:
I had no previous aviation and no model aircraft background
when I started operating RPA. It is only after receiving a suitable level of
training that much of the "aviation language" started making any
sense. The [Civil Aviation Legislation Amendment (Part 101) Regulation 2016]
and [standard operating procedures] makes many assumptions about aviation knowledge
that are unrealistic.
How is anyone, without adequate training, going to fully understand concepts
Controlled Aerodromes – What are
these and how do you know how to locate them?
Non-Controlled Aerodromes - What
are these and how do you know how to locate them?
Restricted Areas – How do you find
out where they are and what hours they are operational?
RA1, RA2, RA3 – What are these and
how do you know how to locate them?
Representatives from the Unmanned Research Aircraft Facility at the
University of Adelaide acknowledged that even trained RPA operators may have
difficulty interpreting airspace requirements 'with the level of accuracy
required to meet the regulations, and maintain safe, regulated aircraft-RPAS
distance'. They submitted that the risks involved were 'greatly amplified in
pilots operating commercially under 2kg with no training, potentially fewer
available information resources, and no pre- and post-flight oversight'.
Witnesses therefore argued that at least a basic level of education and
training should be a priority for lawmakers.
The point was made that any RPAS registration system should have as a minimum,
the dual purpose of educating and registering RPAS operators. To this end, the
committee was told that, as part of a mandatory registration system, an RPAS operator
must be required to demonstrate an adequate understanding of the applicable
regulations in order to be issued with an identification number and access to
mapping and data information.
Mr Chris Roberts of Parrot ANZ commented that, regardless of
whether the pilot is located in or below the aircraft, 'the pilot is ultimately
always responsible for the operation' and should therefore be sufficiently
educated about his or her responsibilities.
Education, awareness and
Witnesses to the inquiry emphasised the point that RPAS have the
potential to cause a breach of national security, cause damage to life or
property and can invade the privacy of others. As such, there should be a
requisite equivalent and proportionate requirement on the part of the operator
to have some level of technical skill, as well as an appropriate understanding
of the rules and regulations concerning the operation of their device. To this
end, some submitters voiced their support for a certification or licensing test
for RPAS operators.
Model aircraft hobbyist Mr Edward Browning proposed a requirement
similar to the Basic Aeronautical Knowledge test for student pilots, which
would be followed by a practical demonstration of ability.
Similarly, VIPA suggested that all RPAS operators be 'required to complete a
basic air law examination'.
In their September 2016 Joint Statement, international aviation bodies
recommended mandatory training and certification as a top priority. The
signatories argued that an obligation to obtain a certificate or licence
creates awareness and mandates knowledge of the applicable regulations and
restrictions. They continued:
Moreover, a legally required certificate or license also
enhances the ability to enforce rules. Operating a drone is thereby reserved
for people who have acquired permission to do so.
This requirement should be mandatory except for the harmless
drones. This category of drones is understood to do no harm to people (e.g. be
limited to a maximum weight of 250g and a radius of action of no more than 50
meters from the pilot).
A number of submitters were in favour of a system whereby RPAS operators
are legally bound by a licence to abide with the regulations.
The notion of legal accountability was supported by Aeroeye. It stated
that education is more effective if operators 'have something to lose if they
choose to operate outside of the rules', such as a licence or registration.
Some submitters also argued a licencing test would raise the standard of
operation by challenging the misconception that RPAS are harmless toys for
children. Captain Phil Stevens noted in this regard:
Would you issue a pilot licence to an 8 or 10 years old
child? No. So why will you allow a similar child to fly a drone?
Maurice Blackburn Lawyers added that a standard education requirement
would send the right message to the public and add to the credibility of the
industry through 'weeding out' unsafe operators.
In CASA's RPAS operations review, approximately half of the 910
respondents agreed that both proficiency and/or training should be compulsory,
taking the weight of the RPAS into account.
CASA stated that, whilst many recreational and excluded category operators do
so lawfully and with a sound understanding of their safety obligations, 'there
is an increasing number of RPA operators...who have a poor understanding of the
RPA legislation, or have interpreted it incorrectly'.
However, the need for low-cost and time-effective training was also
emphasised by submitters.
AAUS noted that the challenge was to develop a standardised syllabus that is
able to deliver training at a national level and at a price that is affordable
for recreational RPAS operators.
These concerns were again reflected in CASA's review responses, with submitters
suggesting a free, user-friendly education syllabus, available through e‑learning
platforms that are regularly updated to meet industry and technology standards.
The example of marine radio operator certification was brought to the
committee's attention. Details about the training requirements for marine radio
operators are outlined in case study 4.1 below.
Case study 4.1 –
Training requirements for marine radio operation
Marine radio operators are
required to complete a number of training requirements before obtaining their
marine radio operators licence. Training requirements draw on an approved
syllabus, and assessment is undertaken by an independent invigilator. Operators
must demonstrate proficiency before being allowed to use their vessel for
The legislative framework for the
qualification of marine radio operators is authorised by the International
Telecommunication Union (ITU) Radio Regulations. Like ICAO, the ITU was
established by the United Nations and provides guidance on the wide range of
issues affecting information and communication technologies internationally. As
a member state, Australia has established training requirements for marine
radio operators. Five different certificates of proficiency and one certificate
of endorsement are issued to operators of marine radios as follows:
Long Range Operator Certificate of Proficiency (LROCP);
Short Range Operator Certificate of Proficiency (SROCP);
Global Maritime Distress and Safety System General Operators
Certificate of Proficiency (GOCP);
GMDSS First-Class Radio Electronic Certificate (1st-Class
GMDSS Second-Class Radio Electronic Certificate (2nd-Class
Marine Satellite Communications Endorsement (Satcom).
The type of qualification
required depends on the type of equipment carried on the marine vessel.
A number of certificates of
proficiency can be obtained by undertaking private study. However, colleges of
technical and further education, volunteer marine safety organisations, marine
training schools and commercial companies, may also provide courses in marine
The Australian Maritime Safety
Authority (AMSA) is responsible for the issue of GOCPs and 1st- and
2nd-Class RECs. AMSA has accredited a number of educational
institutions and registered training organisations to conduct examinations to
test candidates at the conclusion of the course. Approved providers are listed
on the AMSA website.
LROCPs, SROCPs and Satcoms are
issued by the Australian Maritime College (AMC) on behalf of the Australian
Media and Communications Authority. AMC approves invigilators to conduct
examinations on its behalf. A list of both independent invigilators, and those
associated with organisations, are listed on their website. Certificates are
issued on presentation of the results of approved examinations, and a small fee
A tiered education system
Many submitters, including Mr Greg Tyrrell of AAUS, noted that training
should be 'geared to risk' such that recreational operators are required to
have a base level of knowledge, and operators with further commercial intent
may be required to know more.
Similarly, Helistar Aviation proposed that a tiered system be introduced
whereby recreational and small RPAS operators are required to complete a
recreational pilot licence theory exam, while commercial operators could be
asked to complete instrument flight rule (IFR) training before conducting 'beyond
visual line of sight' operations (BVLOS).
According to submitters, a tiered system offers the prospect of limiting
and controlling the capability of an RPAS in accordance with the competency,
aviation awareness and education of its operator. As a starting point, 'off-the-shelf'
RPAS could be equipped with technical constraints on altitude and distance. All
buyers of RPAS would be required to pass a basic competency test and register
their device before use. For recreational operators who are interested in unlocking
additional capabilities and functions on their RPAS, a second tier requirement
would have to be met by way of further education and skill development. The
third tier would require operators to meet current licencing requirements
before commencing commercial operations.
In this vein, proponents of the MAAA's 'wings' program advocated for a tiered
accreditation system. As an example, the 'bronze wing' certification available
through MAAA's program is aimed at aero-modellers who fly models below 2kg; 'silver
wings' is aimed at those flying models over 2kg, and 'gold wings' is awarded to
pilots who are able to complete difficult manoeuvres such as a Cuban Eight,
inside loop and horizontal roll.
MAAA Secretary, Mr Kevin Dodd further explained:
Bronze and silver basically are the mandatory solo
proficiencies. In most of the clubs now, if not all, if you visit and do not
have your bronze or silver wings, they would probably stand an instructor with
you until such time as they were happy to see you fly.
Representatives from Aeromodellers New South Wales, who assisted in the
development of the wings system, added that the program 'helps to set a culture
within the clubs and our pilots of knowledge of the rules and safety'.
It also ensures consistency across state jurisdictions—a key benefit of any
federally driven regulation.
A tiered training program for all RPA operators, in combination with 'off-the-shelf'
technical restrictions, was generally supported in evidence to the committee.
Under such a system, all RPAS operators would be required to pass a minimum
level of testing before flying an RPAS, with the option to upgrade and fly
Representatives from Airservices Australia stated they 'would happily work with
manufacturers' to implement such a program,
whilst ATSB suggested that the idea could inform further policy.
In line with DJI's in-built quiz initiative, CASA encouraged all RPA
manufacturers to utilise technology to assist in enhancing user's understanding
and compliance with Australian RPA legislation.
Implications for other industries
Submitters suggested that mandated education requirements could shape
the way in which insurers develop policy.
Drone Solutions recounted difficulty in finding an aviation insurance broker
willing to provide public liability insurance in the absence of a RePL. It
Insurance professionals are experts at using risk profiles to
determine insurability and premium rates. If the insurance professionals are
concluding that it is too risky to insure someone in the sub 2kg excluded
category without providing a RePL, then they also seem to disagree with CASA's
This implied that any potential changes to CASA's regulations are likely
to have an impact on the insurance industry. The IALPG agreed that the
increased number of RPAS operating under the Part 101 amendments will cause the
insurance market to adjust policies and prices accordingly.
This view was seemingly illustrated in January 2018 when QBE launched a
dedicated RPAS insurance policy. Created in recognition of CASA's 'relaxed
regulations' for sub-2kg RPAS, the policy offers accidental damage cover,
ground risk cover, and third party liability cover for bodily injury or
property damage as a result of an RPAS incident.
The committee also noted that in December 2015, Vero Insurance revised
its public liability insurance policy to include fatality or major destruction
caused by a commercially operated RPAS below 10kg.
The committee received considerable evidence in relation to CASA's
public awareness and media activities. According to CASA, it has collectively
reached over 1.2 million people through RPAS safety videos; with 51 000
social media followers to date.
Cinema advertising to target recreational RPAS operators has also commenced,
with an estimated total audience reach of over 436 208.
In October 2017, CASA launched the 'Droneflyer' website which, it
argued, features 'a very simple, plain-English, accessible explanation of
CASA also released a Christmas safety video ahead of the 2017 holiday period to
remind RPAS operators to fly responsibly.
However, of particular significance to many witnesses was the CASA mobile phone
application, 'Can I fly there?'.
Can I fly there?
Can I fly there? is a mobile phone application that shows the
user where they are and are not permitted to fly their RPAS. It also identifies
prohibited zones such as airports, helicopter landing sites and other restricted
areas. Released in May 2017, the app was commissioned by CASA in response
to an increasing number of reports from pilots about near-misses with RPAS.
In August 2017, CASA's Chief Executive Officer (CEO), Mr Carmody, told
the committee that the app had been downloaded over 35 000 times and that the
web version had been accessed more than 60 000 times.
Updated figures released in May 2018 showed that the app had been downloaded an
additional 60 000 times. As well as the existing data map available, the
app also displays a 5.5km circular area around fire-affected emergency zones.
The Unmanned Research Aircraft Facility at the University of Adelaide
commented that the app's release is consistent with initiatives by the US FAA
and UK National Air Traffic Control Service. The US mobile app, 'B4UFLY',
provides information and alerts to RPA operators about when and where their RPAS
can be flown, whilst the app produced in the UK goes further to alert operators
of areas where privacy may also be a concern, such as near a school.
Submitters were generally supportive of the mobile app as a means of
educating the general public about the safe use of RPAS and to enforce 'no
drone' zones. However, the mobile app alone was viewed as just one step towards
bolstering public education about safe RPAS use.
In addition, RPAS stakeholders expressed broad support for training and
demonstrated proficiency requirements in order to make users aware of the
relevant regulations, risks and responsibilities associated with RPAS operation.
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