CASA UAV submission.
Just for P2:-
61. One of the important ways in which CASA is empowered to conduct the safety regulation of Australian civil air operations is by ‘developing effective enforcement strategies to secure compliance with aviation safety standards’61.
62. CASA’s approach to enforcement is set out in its Enforcement Manual, which has been amended to better reflect the principles of CASA’s Regulatory Philosophy.62 In exercising its enforcement powers, the Enforcement Manual provides:
The rest is pretty much bog standard. What the CASA submission does do (IMO) is highlight the ‘constraints’ and the narrow purview that marks the ‘approach’ to legislation. The plodding, pedantic, prescriptive methodology which attempts to cover the minutiae in detail and neglects the ‘core’ issue. This is noticeable in every regulation along with the continual need to cross reference and read other manuals. It is a cluttered, messy system, which leaves the ‘seeker’ of finite answer without a clear cut pathway to compliance. To me removing this clutter should be the focus of regulatory reform; take part 61 as a prime example. I digress.
One could be forgiven for feeling a little sympathy for the regulator in the matter of UAV control. It’s a witches cauldron of toil and trouble:-
64. When CASA is able to identify the RPA operator, CASA will take further appropriate steps
(such as a warning letter or initiating a formal investigation) where:
(a) the conduct involved an unacceptable risk to safety; and/or
(b) an apparent contravention of the applicable civil aviation legislation.
65. It is important to recognise, however, that in the vast majority of cases reported to CASA, it
is often extremely difficult to identify who was responsible for the alleged conduct, and
challenging to obtain sufficient evidence to support any enforcement action.
Spot on; you can see why ‘control’ is almost an impossibility. The registered operators are not a problem, serious hobbyists and sensible recreational users will take the rules seriously and act sensibly. As I’ve mentioned before, the model aircraft associations are first class and will ensure that ‘the rules’ are followed. All well and good; but is it a CASA task – outside of ‘air safety’ to control and manage the rest. If so, then how? I reckon its akin to trying to control what folk do with computers; just about everyone has at least one. I wonder how many ‘drones’ have been sold in the recent months leading up to Christmas. How, in the name of sanity, is CASA expected to contain and control the skies between now and Easter, when, hopefully, 70% of the new toys are wrecked or discarded? Not a job I’d want.
You could and perhaps should, actually treat the whole situation as one of ‘public safety’, rather than purely a matter of ‘air safety’. IMO that is where the real risk lays; nearly had my head taken off just a couple of days ago, walking between the car and home. The ‘ villain’ was a young chap, no more than seven with his gang two (2 and 4 y.o) and an I-pad. I watched for while. Clearly this gang of ‘hooligans’ was no direct threat to ‘air safety’ and the Morton Bay fig tree under attack could clearly hold it’s own; but accidents do happen, eyes get put out, windows get broken, cars take evasive action etc. However, this is not my main concern; the ‘kid’ spent 99% of his time looking at the I-pad, not the drone toy. Anyway, I ambled off when the tree delivered a mighty blow, reducing the four engine juggernaut to a three engine non event.
![[Image: C0R3uzFWIAE6QDz.jpg]](https://pbs.twimg.com/media/C0R3uzFWIAE6QDz.jpg)
I wonder if a short, kindly meant ‘safety’ message, delivered on the morning TV shows would not go a long way toward ensuring not only compliance with such laws as govern UAV operations, but the tenets of common sense.
![[Image: C0R3u-BWQAA9TzK.jpg]](https://pbs.twimg.com/media/C0R3u-BWQAA9TzK.jpg)
Sponsored by the preservation of fig tree society.
Toot toot
Just for P2:-
61. One of the important ways in which CASA is empowered to conduct the safety regulation of Australian civil air operations is by ‘developing effective enforcement strategies to secure compliance with aviation safety standards’61.
62. CASA’s approach to enforcement is set out in its Enforcement Manual, which has been amended to better reflect the principles of CASA’s Regulatory Philosophy.62 In exercising its enforcement powers, the Enforcement Manual provides:
The rest is pretty much bog standard. What the CASA submission does do (IMO) is highlight the ‘constraints’ and the narrow purview that marks the ‘approach’ to legislation. The plodding, pedantic, prescriptive methodology which attempts to cover the minutiae in detail and neglects the ‘core’ issue. This is noticeable in every regulation along with the continual need to cross reference and read other manuals. It is a cluttered, messy system, which leaves the ‘seeker’ of finite answer without a clear cut pathway to compliance. To me removing this clutter should be the focus of regulatory reform; take part 61 as a prime example. I digress.
One could be forgiven for feeling a little sympathy for the regulator in the matter of UAV control. It’s a witches cauldron of toil and trouble:-
64. When CASA is able to identify the RPA operator, CASA will take further appropriate steps
(such as a warning letter or initiating a formal investigation) where:
(a) the conduct involved an unacceptable risk to safety; and/or
(b) an apparent contravention of the applicable civil aviation legislation.
65. It is important to recognise, however, that in the vast majority of cases reported to CASA, it
is often extremely difficult to identify who was responsible for the alleged conduct, and
challenging to obtain sufficient evidence to support any enforcement action.
Spot on; you can see why ‘control’ is almost an impossibility. The registered operators are not a problem, serious hobbyists and sensible recreational users will take the rules seriously and act sensibly. As I’ve mentioned before, the model aircraft associations are first class and will ensure that ‘the rules’ are followed. All well and good; but is it a CASA task – outside of ‘air safety’ to control and manage the rest. If so, then how? I reckon its akin to trying to control what folk do with computers; just about everyone has at least one. I wonder how many ‘drones’ have been sold in the recent months leading up to Christmas. How, in the name of sanity, is CASA expected to contain and control the skies between now and Easter, when, hopefully, 70% of the new toys are wrecked or discarded? Not a job I’d want.
You could and perhaps should, actually treat the whole situation as one of ‘public safety’, rather than purely a matter of ‘air safety’. IMO that is where the real risk lays; nearly had my head taken off just a couple of days ago, walking between the car and home. The ‘ villain’ was a young chap, no more than seven with his gang two (2 and 4 y.o) and an I-pad. I watched for while. Clearly this gang of ‘hooligans’ was no direct threat to ‘air safety’ and the Morton Bay fig tree under attack could clearly hold it’s own; but accidents do happen, eyes get put out, windows get broken, cars take evasive action etc. However, this is not my main concern; the ‘kid’ spent 99% of his time looking at the I-pad, not the drone toy. Anyway, I ambled off when the tree delivered a mighty blow, reducing the four engine juggernaut to a three engine non event.
I wonder if a short, kindly meant ‘safety’ message, delivered on the morning TV shows would not go a long way toward ensuring not only compliance with such laws as govern UAV operations, but the tenets of common sense.
Sponsored by the preservation of fig tree society.
Toot toot