This piece reflects the sentiments of interested parties from Australia who are involved in the RPAS integration effort. Other were asked to contribute, but declined as they were either content with the work products being produced or, had concerns about being seen as critical of the process. This may or may not become evident to the reader just “who” these folks might be or, are represented in the text of the story.
In the early days of the regulatory process, the community saw CASA as producing onerous guidelines for UAV/S. That was until the February 13th, 2007 edict (here in the U.S.), had set in that regulatory resolution was not imminent. Folks began to take another look at CASA who was seen as leading the way. The onerous bits didn’t just fall off, but at least the bitter pill afforded you a legal avenue for operation.
Fast-forward to the sUAS ARC, WG-73 and the UK CAP 722. I’ll leave it to the reader to deduce what, and where we are at in the regulatory sense. From my perspective, the UK CAA has taken a very pragmatic approach to the integration of UAS into their airspace. Does it represent perfection? No, but in my estimation the UK CAA represented their unmanned aviation industry in a more objective manner.
Through this article, I will interject with commentary when appropriate or in instances where parallels can be drawn or, I have personal experience.
The story [sic] as follows….
The Australian Civil Aviation Safety Authority (CASA) appears to be in a bit of a panic right now in trying to address the fact that 10 years after they introduced world-first regulations governing the use of unmanned aircraft in Australian airspace, very little has changed.
CASR Part 101 ‘Unmanned Aircraft & Rockets’, was first introduced in July 2002 and apart from very subtle (and very quiet) changes made to the regulations in 2011 to remove some of the duplication across the Civil Aviation Safety Regulations 1998 (and also inadvertently removing the Statutory Authority from early UAV Operator Certificates), Part 101 has not otherwise changed. What’s more, the guidance material supporting the regulations in the form of Advisory Circular 101 released at the same time is still in its original form.
By comparison, the UK CAP 722 guidance material for UAS is now in its 4th edition in 10 years.
In July 2011 CASA belatedly started project OS11/20 to review the regulations & guidance material relating to UAS.
The project is broken down into 2 phases beginning with the development of a new suite of Advisory Circulars:
AC 101-1 – General
AC 101-4 – Training & Licencing
AC 101-5 – Operations
AC 101-6 – Manufacturing & Initial Airworthiness
AC 101-7 – Maintenance & Continuing Airworthiness
AC 101-8 – Safety Management
Phase 2 will consist of a review and where necessary [further] amendment to CASR Part 101.
Almost a year on, the first of the new ACs were due to be released by CASA about now (May/June), but it seems maybe all is not well down-under and CASA’s expectations of continuing to lead the world in unmanned aviation might be about to come to an end.
The Australian Aerospace Industry Forum (AAIF) Sub-Committee on UAS Certification & Regulation, reviewed the first batch of CASA draft ACs in late February this year with a report tabled at a joint CASA/Industry meeting on the 13th of March. The comprehensive guidance-based report was finalized in April and as the concluding remarks from the AAIF report state:
“The ACs are a positive step forward in the direction of a comprehensive suite of advisory materials for the UAS sector. However, given the large number of issues identified in this review, the AAIF believes the ACs are some way off from being ready for release for broader consultation. This review has identified a number of critical issues. The guidance contained in the ACs reflects anticipated changes to be made to the regulations and as such, some of the ‘implied requirements’ within the ACs need to be further discussed with industry.”
The Australian Aerospace Industry Forum (AAIF) further advised that; “…significant improvements to the advisory material would be achieved if CASA engaged a professional writer.” suggesting the draft material is far from ready.
This wasn’t the only advice from the AAIF report, with convincing arguments for suggesting CASA have a rethink about such things as;
- The terminology & definitions used, particularly around the core terminology of UAV; UAS; RPA; and the word Autonomous, for instance
- Style & Layout, with better use of tables, process diagrams & illustrations
- Training & Licencing, including clarification on the scope of formal training & licencing and how that actually relates to defined roles
- Make explicit, the general rules of the air that are applicable to UAS
- The relevance of information specific to UAS and not just material copied over from the manned sector without any tailoring or forgetting to include critical elements of a UAS in the guidance material
- More prescriptive guidance on such matters as UAS Design, Manufacture & Initial Airworthiness, something CASA seemed to have difficulty in identifying themselves
- The importance of a Safety Case & Safety Risk Management in being able to make considerations & judgements
Interesting to see that these problems aren’t just plaguing the U.S. I’d have to say that this malady is affecting the rest of the world as well. Many of the initial concepts led to these questions, but from my vantage point they are issues that required either heavy lifting (hard work) or the empirical knowledge base to complete.
A few of us had raised questions about the lack of practical knowledge and application acumen that is lacking in the process. In my estimation it is folly to let the large vendors try to fill in the blanks with lessons learned in Iraq and Afghanistan. Initially there was some push back on military data, but I believe we are seeing a wearing down of the best of intentions.
If we look at these issues point by point, they are the hard questions representing the proverbial ‘can’ that has repeatedly been kicked down the road. Many of these same questions were ones that I brought up or emphasised during the sUAS ARC. Most of points were answered with a “trust us.” I continually reiterated that this approach was unrealistic because they don’t have the [civil] knowledge base to fully understand the technology (including the myriad of platform types) or the many possible applications.
Too be continued …