South Africa’s constrained commercial drone industry
Good news bad news, the South African Civil Aviation Authority (SACAA) has announced that to the end of January 2017 there are 368 licenced RPL pilots in South Africa. That number up from 33 in 2016.
“The substantial increase in the number of registered RPAS [remotely piloted aircraft systems] and associated licences in the country is not a surprise at all,” SACAA executive, Simon Segwabe said.
“In fact, the increase has always been envisaged as the rapid advancement of this technology and its potential use in commercial and other activities make RPAS appealing to many prospective operators.”
A glass half empty
The number of pilots and aircraft registered is really just one-third of the story. Not only does the aircraft need to carry a ZT registration and the pilot have an RPL but to be legal truly, pilot and aircraft need to be part of a business holding a ROC (RPAS Operator Certificate)
This is not a cheap or straightforward process, it is required for the even very smallest of machines. The 734g DJI Mavic would need to be part of an ROC to be operated commercially.
As I type there just eleven legally licensed commercial operators in South Africa. So that would mean each company would need to employ 33 RPLs for those 368 pilots to all have legal work.
These are the licenced companies
UAV & Drone Solutions (Pty) Ltd
Public Display Technologies (Pty) Ltd
Timeslice Cinematography
LS Multi Copter Projects and Services (Pty) Ltd
Visual Air Productions (Pty) Ltd
Premier Aviation CC
FC Hamman Films CC
UAV Industries (Pty) Ltd
Anglo Operations (Pty) Ltd – CORPORATE operations only
Gillcor CC
Skyhook (Pty) Ltd
The ROC requirement for all but a few removes the cost benefit of drones. The cost of compliance is to high.
South Africa is falling behind countries in Africa, let alone in the rest of the world. Rwanda is far more progressive within the African diaspora.
Don’t look back in anger.
Why are we reinventing the wheel in South Africa with backwards looking regulation? Our aviation authority is letting down the drone industry.
Who should we follow? America may be about to suffer the same unintended consequences as the UK did after Brexit. In the USA, President Trump by halting new regulations has stopped work on Part 107 updates. In the UK the pre-Brexit Government was just about to sign off on light touch regulations for craft below 4kg AUW. That fell by the wayside when the new broom swept in.
So not those two for the minute, they have other fish to fry.
Things can only get better.
Last year Australia instigated very simple rules for sub 2kg craft, so that’s all the Phantom and eBees types out there. You need to tell the Civil Aviation Authority Australia (CASA) five days before you start operating that you are going to. They will then give you a 24 month permission, no test required.
Then follow these rules.
You must not operate your RPA in a way that creates a hazard to another aircraft, another person or property.
You must only fly during the day and keep your RPA within visual line-of sight.
This means being able to see the aircraft with your own eyes (rather than through first-person-view (FPV)) at all times.
You must not fly your RPA higher than 120 metres (400ft) AGL.
You must keep your RPA at least 30 metres away from other people.
You must keep your RPA at least 5.5km away from controlled aerodromes.
You must not fly your RPA over any area where, in the event of a loss of control or failure,
you create an unreasonable hazard to the safety of people and property on the ground.
You must not fly your RPA over or near an area affecting public safety or where emergency operations are underway (without prior approval).
This could include situations such as a car crash, police operations, a fire and associated firefighting efforts, and search and rescue.
You can only fly one RPA at a time.
But wait there’s more
If you own the land over which you are flying CASA created a new acronym for you. Small RPA private landowner. That’s nice but what does it mean? It means you can fly craft up to 25kg in weight, think farms, mines and game reserves. In my part of South Africa, I see light aircraft at low level on the weekends only and not every weekend.
Hundreds of farmers could be experimenting with drones on their farms here, many kilometres from cities and people. Mines could be measuring stockpiles, environmentalists protecting wildlife.
There was resistance to the changes in Australia from established drone operators, some felt the rug was pulled from under them but the new rules prevailed.
South Africa should stop boasting about being the best in the world, we are not leading Africa or the Southern hemisphere. We lead though, in bragging about semantics.
Use the safety stick
“The main concern for regulators such as the SACAA is the increasing number of unregistered and unapproved RPAS operations that are taking to the skies illegally and are being potentially operated by unlicensed individuals. It is estimated that for every registered and licensed remotely piloted aircraft taking to the skies, there are two or three more doing so illegally,” Segwabe says.
Two or three more RPA are flying outside of the regs for every licenced one Simon really!
What does that mean, 465 ZT registered drones, so that’s 1395 illegal operators in the worst case?
I would be willing to bet that number is more like 5000. I know we are not the size of America, but DJI sold 160,000 drones in December of 2016 over there. That’s just one manufacturer.
Let us just pause and reflect on that number and that as yet, there has not been a single confirmed sUAS, manned aircraft strike anywhere in the world.
There are far more drones out there in Southern Africa then the SACAA thinks.
Come on SACAA just roll out the Australian system and work with the future, not the past.
Let’s stop playing and get to work.
What is needed to licence your drone company in South Africa
Phase 1:
The applicant submits a “Letter of Intent” (CA101-02) to the SACAA (FOD) Flight Operations Department: Part 101.
Pre-application meeting scheduled and held
For commercial operations, the applicant will be referred to the Department of Transport to apply for a Domestic Air Service License (ASL) at the Air Service Licensing Council.
The applicant will need to submit the relevant ASL application form which can be downloaded off the Department of Transport website as well as the required documents. Regarding “aircraft” documents, one only needs to submit the Certificate of Registration and proof of insurance. Should the applicant not yet be insured, this can be a letter from an insurance company stating what insurance will be activated once the ROC has been issued and the aircraft is being operated. Part 101 requires the applicant to be “adequately insured for third party liability”. As per the Act, third party liability needs to be a minimum of R500 000 per aircraft.
The post holders required are: Accountable Manager/CEO
Person Responsible: Flight Operations (Ideally have some experience in flying operations and hold a RPL)
Person Responsible: Aircraft (Ideally have some experience in flying operations and maintenance experience)
Safety Manager (to have completed an aviation safety management course)
Quality Manager (experience/training in a quality system)
Security Manager – this post is optional for the application and can be combined with one of the above posts, eg: safety manager
*** Depending on the size and complexity of your operation, the above posts may be combined, however, it is recommended that safety and quality remain independent ***
In order to operate commercially, the applicant requires a Class III license, Category A4 (fixed wing), H1 (multi-rotor) and H2 (helicopter) and type of operations approved for G16 (other: RPAS) as well as any additional G-codes applicable to the intended operation.
Other processes which can take place at this time:
Registration of aircraft (needed for ASL application)
Application for Remote Pilots License (RPL) once the pilot meets all the requirements as per Part 101. Please contact Nicole Swart, swartn@caa.co.za for further information if required.
Phase 2:
Once the applicant has submitted his/her ASL application to the Air Service License Council, the Licensing council will publish the application in the Government Gazette for 21 days. After the 21 days have lapsed, the applicant will be invited to the council. It is recommended that the applicant commences this process as soon as possible.
Once the ASL application has been submitted, the applicant can commence the Formal Application by submitting form CA101-10: the POPS form, to the SACAA.
Once received and reviewed by the SACAA, the applicant will be invited to attend a formal application meeting with the relevant personnel at SACAA. Depending on the application, the formal meeting may, at the discretion of the inspector, be conducted via telephone and/or email correspondence.
The purpose of this meeting is to discuss the application process and resolve any omissions and/or discrepancies and to answer any questions from either party. This meeting shall encourage open communication and an effective working relationship between both parties.
The applicant will be notified in writing whether the formal application has been rejected or accepted. If the formal application is rejected, a full explanation will be provided to the applicant.
Phase 3:
Once the formal application has been accepted, the applicant will need to submit the required manual, the Operations manual to the CAA for approval with form CA101-03: “Application for a ROC”.
“Application for a ROC”.
The applicant may also submit form CA101-01: “Application for the RLA” with the required documents.
The CAA will complete a thorough review of the manuals
If a manual is incomplete or deficient, or if non-compliance with the regulation or safe operating procedures is detected, the manual will be returned for corrective action.
If the manuals are satisfactory, they will be “approved” or “accepted” as required by the regulations.
A fully completed Statement of Compliance must be included within the manuals submitted.
Phase 4:
After approval or acceptance has been given to all the required documentation, the applicant will enter the “Demonstration and Inspection phase”.
In this phase, the applicant will need to demonstrate its ability to comply with regulations, the company operations manual and safe operating practices.
The demonstration and inspection phase includes onsite evaluations of all policies, procedures, methods and instructions as described by the regulation and operations manual.
Depending on the intended operations, the inspector may specify what he/she would like to see demonstrated.
The demonstration is particularly important for those operators applying for “Approvals from the Director”, for example: to operate at night.
Phase 5:
After the document compliance and demonstration and inspection phase has been completed satisfactorily and the applicant has received the required ASL, the applicant will be issued with a RPAS Operating Certificate (ROC) as well as the Operational Specifications (Ops Spec).
The Ops Spec will contain authorizations, limitations and provisions applicable to the operation.
The certificate holder is responsible for continued compliance with the regulations, authorizations, limitations and provisions of its certificate and operational specifications.
The CAA is responsible for conducting periodic inspections of the operator’s operation to ensure continued compliance with the regulations and safe operating procedures.
Credits
If an applicant is in possession of a valid Class III license, Category A4 – Type G16, G4 or as applicable to the operation, he/she may begin the process from Phase 2.
What is issued at the end?
RPAS Operators Certificate Operations Specification (Ops Spec)
