CASA flags changes to its pending Drone Manual of Standards
Published: 16 March 2019
Super summary: the Tweet
Following public consultation, CASA has made some amendments to its draft Part 101 Manual of Standards for drones, including requirements for drone training schools, obtaining a RePL, Extended Visual Line of Sight operations, and record keeping.
In September 2018, the Civil Aviation Safety Authority (CASA) released a proposed Part 101 (Unmanned aircraft and rockets) Manual of Standards 2018 (MOS), or more aptly titled “Monster of Standards”: 193-pages of eye-glazing material that in comparison makes counting sheep feel like an adrenaline sport. I retract that; in truth, the MOS is seriously important material providing critical guidance to drone pilots on key operational issues.
CASA opened a consultation survey from 24 September to 18 November 2018 which invited anyone to comment on the proposed MOS. Earlier this month, CASA released a report summarising the responses from the consultation survey and CASA’s response. The report is only 11 pages and available here.
Nonetheless, I am catering to those who are so time poor they consider blinking a waste of time. So here’s the Need-To-Know 17-point summary of a summary….
Aeronautical knowledge syllabus
 CASA will proceed with a limit on new remote pilot licence (RePL) holders to drones of 7kg maximum gross weight.
 Changes to the draft examination requirements include:
(a) open-book exam;
(b) increasing the time to complete the exam;
(c) allowing a second re-sit of the exam before having to repeat the course;
(d) increasing the pass mark;
Practical competency syllabus
 Greater focus on planning and practical considerations beyond simply controlling the drone in various phases of flight, including understanding degraded modes of automation.
Upgrading a RePL
 RePL holders with a 7kg limit on their licence will be able to get the condition removed by undergoing short practical training either with a drone training organisation or approved Remote Operator’s Certificate (ReOC) holder.
 Exam credits for applicants for an upgraded RePL reduced from 5 to 3 years for those who cannot show ongoing industry involvement. Credit period for those who can show ongoing professional involvement to remain at 5 years.
Requirements for drone training schools
 Mandated contact time between instructors and students for the aeronautical knowledge syllabus retained at 15 hours, with an additional 4 hours for each additional category of drone.
 Ratio of instructors to students for practical training replaced with requirement that the instructor may only instruct a maximum of 3 students actually flying, non-complex, drones at any one time. Instruction for aircraft designated as complex will be carried out with a maximum of two students at any one time.
 Certificate III course for teaching/instruction removed. An option for formal teacher qualifications has been added, in line with conventionally piloted instructor standards.
 To be an instructor, CASA will prescribe a minimum of 20 hours experience operating a drone in the category being taught. The 20 hours will need to be gained operating drones in the category in operations other than training.
 CASA proposes to commence the training aspects of the MOS 9-months from the date it goes live; other parts of the MOS will commence 6-months after the MOS goes live.
 CASA has not created a prescriptive standard for tethering; rather it has been left to operators to ensure that the tether is suitable.
Extended visual line of sight operations (EVLOS)
 CASA has removed the prescriptive requirement that a EVLOS pilot must have completed at least 5 hours of flight time in VLOS operations (in addition to the 5 hours experience required to get a RePL) with a drone of the same type as the drone that is to be used in the EVLOS operation. Rather, CASA plans to allow an operator-determined (still CASA-approved) type of experience.
 In relation to the maximum distance that a drone can be operated from the remote pilot, CASA has amended this to be 80% of the manufacturer’s published control link performance figure.
 CASA rejected use of first-person view (FPV) goggles for use in single person EVLOS operations where the drone flies behind obstacles, or as a substitute for observers; the current FPV exemption currently in place for recreational operations (e.g. drone racing) under certain conditions, will remain.
Record keeping and notification
 CASA has provided some alleviations to the draft proposal with respect to drones with avgross weight less than 2kg.
 Single-person operators will not have to complete the ‘Operational release’.
 CASA will allow the use of electronic records provided that they are shown to be immutable once completed.
I will be keeping my eye on the changes as they come into force.
The Drone Lawyer
16 March 2019