The subject of a ‘risk-based’ approach to classifications of UAS & UAS operations is still a very sensitive subject for all NAAs but CASA appear to be more accepting than many others on the merits of this approach.
How far the regulator should go in using ‘risk-based’ classifications to make judgements on the relative safety of UAS and UAS operations, needs to be considered very carefully in the context of equivalent levels of safety to manned aircraft & manned aircraft operations.
Manned recreational aircraft don’t routinely fly over populous areas because the aircraft manufacturer’s don’t, won’t or can’t “prove” the airworthiness and safety of the aircraft to a satisfactory level, and many (if not the majority of) UAS manufacturers today would find it hard even to “prove” the airworthiness of their aircraft at that level.
A sophisticated UAS used extensively in a war zone accumulating hundreds of thousands of flight hours, doesn’t “prove” anything until you consider the number of incidents & losses, and the core reasons behind those incidents & losses.
It’s not like they were being shot at or shot down every day. Many (about a 1/3rd?) of the incidents & losses can be directly attributed to material failures or failures in product or component quality. That’s about 5/6ths too many in a commercial perspective and way over the numbers required to allow more routine operations over populous areas.
The ‘Holy-Grail’ of routine UAS operations over populous areas might be very commercially persuasive but it shouldn’t dull our senses to the 100 odd years of aviation safety that has served us pretty well to now.
Sound aviation practices in aircraft design & manufacturing should still be the basis for a level of certification necessary to access high-risk airspace, regardless of how “harmless” it may seem at the time. Even more so when judgements are primarily subjective as they are in many cases still with UAS.
The last thing we need at this stage in the evolution of unmanned aviation is an increased propensity for aviation accidents or incidents, particularly over populous areas, as a result of commercial imperatives to survive, or impatience.
Risk-based classifications can certainly help reduce the cost and burden of commercial UAS operations in already identified low-risk areas of operation, but at the pointy end of the operational spectrum we need to maintain sound discipline & integrity.
We don’t need to rush the job for the sake of appeasing industry. If there is a commercial or financial imperative to get the regulatory and certification work done, then let industry start paying for it to get done properly & thoroughly.
If not, we’ll all end up paying for it in accidents and incidents and another decade of proving ourselves all over again.
We’d really like to think the informative work of the AAIF has not gone unheeded by CASA.
I guess only time will tell.
We have some of these exact forces at play here in the U.S. I have brought these issues to light in articles here at sUAS News as well as on the podcast series. The larger contractors will point to the numbers flown (non-peer reviewed telephone numbers) in Iraq and Afghanistan and reinforced by the other trappings afforded them by the “program of record”, to ask for and receive special dispensation to fly higher, further, at night and over populated areas. All of this moneyed influence spells trouble for the UAS/RPA community and could very well exacerbate the public backlash we are seeing now.
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