Re: CASA Consultation On Part 101 Manual of Standards

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16 September 2020

Dear Members,

Re: CASA Consultation on Part 101 Manual of Standards

First, thank you for your membership, we strive to serve your RPAS interests with a
united voice.

We write to bring your attention to CASA’s latest consultation on proposed changes to


Part 101 (Unmanned Aircraft and Rockets) Manual of Standards 2019 (the MOS),
titled, Proposed policy amendments to Part 101 MOS registration, accreditation and
transitional provisions - (CD 2014US). The link to the CASA page is available here.

Notably, the deadline for comment is 23 September 2020. While ACUO will provide a
response on behalf of the Members, we encourage you to provide your own
comments; alternatively, you may write to us and we will incorporate your views into
ACUO’s response.

We appreciate that time is scarce and that you have many competing interests. As a
result, if you would like to contribute but simply do not have the available time to read
all of the CASA materials on this consultation, please see below summary of the
proposed changes.

At a high-level, there are 7 proposed changes:

1. Any student who commenced a Remote Pilot Licence (RePL) course between 3
April 2020 and 10 October 2020, will have until 31 January 2021, to complete all
aspects of the course under the syllabi as is in force before 10 October 2020.
Any course commenced on or from 10 October 2020 must be completed against
the new relevant syllabi.

2. RePL training instructors are to be given an additional 18 months, to 10 April


2022, to obtain new instructor qualifications.

3. Chapter 11 of the MOS currently titled ‘Notification of Change to Operate


Excluded RPA’ is to be repealed. The aim is to replace the requirement for
excluded category notifications with registration.
Letter to Members

4. New Chapter 12: ‘Identification of RPA and Model Aircraft’. This provides that
registration holders are to legibly display, in a manner that is easily seen or
accessible, the manufacturer’s serial number, or the mark allocated by CASA
when the drone was registered.

5. New Chapter 13: ‘Operation of Foreign Registered RPA and Model Aircraft’.
Provides that an RPA or a model aircraft that has been registered under a law of
a foreign country but not registered in Australia, will be required to obtain
permission from CASA, instead of a registration certificate.

6. New Chapter 14: ‘Permisible [sic] Modifications to Registered RPA and Model
Aircraft’: This provides for the acceptable modification of registered drones and
criteria when any modified drone must be re-registered.

7. New Chapter 15: ‘Conduct of Online Training Course and Examinations for
Accreditation’. Provides for how the online pilot accreditation scheme will work,
including that an applicant must personally successfully complete the entirety of
the online training course.

The questions asked by CASA in this consultation are as follows:

Question 1: Do you agree that the Part 101 MOS amendments reflect the change in
policy as set out in the summary of proposed change and will work as intended?

Question 2: Do you agree that the Part 101 MOS amendments will not result in
unintended consequences?

Question 3: Do you have any additional comments about the proposed policy?

Please be in touch without hesitation if you have any questions.

Regards,

Tom Pils on behalf of


the Management Committee

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