[Peetwo]

CASA on drones - All care no responsibility.

Over on DDDD_MNFI's thread P7 said:

I don’t expect many of the CASA crew in the ‘drone’ department have noticed it, but the UK CAA have had a very clever UAV ‘operational’ awareness campaign running up the Christmas break, anticipating the increase in ‘traffic’. The information presented is easily understood and well distributed. The part I really like is the clever idea to run a photographic competition, pictures taken by UAV from 400 feet. What a proactive, sensible approach. Bravo UK CAA.

Meanwhile, in Australia, where, provided you don’t live too close to an airport, you can still drink the water; what do we get – pages of dribble about drone pizza delivery. What a load of old bollocks. In the first place, particularly around built up areas, as any chopper pilot will tell you, the wind shear and mechanical turbulence even in light wind conditions can be lethal.  It takes a great deal of skill to ‘operate’ at low level. Now this pizza delivery service want to start using ‘self guided’ drones to deliver their dreadful product - at the end of a 30 meter ‘rope’. It is a silly idea, but, IMO, even sillier are those who take a publicity stunt seriously and even respond in the press. Automatic, self guiding drones doing sling loads on GPS, in all weather conditions – Bwah hah hah.

UK CAA sane proactivity starkly contrasts the moronic, half baked CASA do nuthin approach.

Minister, the help you need is not available from CASA; get some before there is an incident.

Fantasy v reality:

40 Domino's Pizza Enterprises Ltd (PDF 611 KB) 

Note the alarming disconnection and false assumptions in the following Domino's submission quote - UDB :

...For commercial users, we have every expectation a regulatory system will allow for the unique nature of drone deliveries, specifically their low cost and low risk nature, owing to the short distances and low altitudes of standard flights. The existing regulations, particularly the requirement to conduct flights within line of sight, and associated requirements regarding the lodgement of flight plans, were understandable given the technology and safety environment in which they were established. However, Domino’s submits these rules will require careful examination, and relaxation, should commercial drone deliveries be viable in this country...

 
Now compare that to the AAAA submission - see HERE.  Without a doubt the AAAA are representing the most at risk sector of the industry from unregulated recreational or poorly regulated commercial UAV/RPA use:

..The members’ operations require them to work at low level - often a few metres above a crop or higher when sowing, fertilising or firebombing. Almost all operations will be conducted below 400’ - creating a direct conflict with drone use in the same airspace...

  
Therefore this is one submission the good Senators should particularly take note of for a 'real world' purview of the safety risks and possible recommendations for mitigating these risks:

..AAAA believes that the key risk that CASA has failed to address is separation between legitimate and legal low level airspace users and drones.

Airspace users affected include aircraft used for aerial application, survey, mustering, pest control, slinging, fire observation, emergency rescue and other aerial work activities.

In addition, all other aircraft approaching, landing, taking off and departing from private, agricultural or other airstrips are not protected by current laws.

In addressing this primary risk of a breakdown of separation - which AAAA has raised with CASA many times - it would not be unreasonable to expect CASA to have established a real time system of communication between drone users and existing low-level airspace users to allow them to make local arrangements for adequate self-separation.

No such communication system is in place and consequently this primary risk remains unmitigated.

AAAA believes that the current CASA approach of deregulating drones up to 2 kg generally and up to 25 kg when used on farm - without a commensurate system to facilitate notification and communication - is fundamentally flawed from an aviation safety perspective.

It is not the low kinetic energy of the drone that is at issue - it is the kinetic energy of the low level aircraft weighing several tonnes, travelling at approximately 250 km/h and with a vulnerable pilot at the controls protected by a thin sheet of Perspex and powered by an engine that would be highly likely to fail should a drone be ingested or hit a control surface. The consequence of such an event could be significant, especially for the pilot.

Again, AAAA has raised these issues with CASA and been consistently ignored, as demonstrated by the current regulations that ignore this very real risk.
A number of safety reports made to ATSB involving conflict between drones and other aircraft clearly demonstrate that this risk is not theoretical and not able to be managed given the current lack of a coherent notification/communication system.

There are many examples of GIS based apps that already perform this type of function in other areas. One example is the BeeConnected app - http://beeconnected.org.au/ - developed by Croplife and the Australian Honey Bee Council and of which AAAA is a strong supporter. This app allows spray contractors and apiarists to work together to manage a range of risks and is based on the principles of notification and communication.

The technology is obviously available and being successfully used in other sectors.

CASA - or the management of AirServices - has simply not considered the potential of such an approach to improve safety in this area. GIS technology combined with smart phones or other devices would lend itself to improving safety across a wide range of low level airspace issues.

This could include, for example, better and more timely notification of wind monitoring towers, wind farms, radio towers, powerline marking etc - information that is critical to low-level aviation but which is simply not made available through existing charts in a timely manner for operations that are highly seasonal, highly mobile and require constant variation and rescheduling due to weather and other operational considerations.

Clearly, such an approach would be a win-win scenario for drone operators, low-level operators, the regulator CASA and the airspace service provider AirServices - but unfortunately appears to be beyond the imagination or knowledge of those determining current drone regulations and responses to the clear primary risk of separation....

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Regulation of commercial drone operations - Commercial drone operations should be required to have systems of management that provide a commensurate level of safety as all other commercial aviation operators.

AAAA supports the following regime for all drones used in a commercial setting to ensure systems are in place to manage the relevant challenges including safety:

• All business owners must operate under the requirements of an AOC or similar and be licensed by the Dept in charge at the State/Territory level for chemical control of use purposes if involved with application of agricultural chemicals.
  
• All business owners must comply with the full requirements of an operations manual.All operations manuals must detail how the operation will manage the risk of airspace sharing, especially with aerial application and other low level users.
  
• All business owners must have operational control of their personnel.
  
• All drone operators must be competent and licensed by CASA and the Dept in charge at the State/Territory for chemical control of use if involved with application of agricultural chemicals.
  
• All drone businesses and operators must comply with similar competence requirements for all other commercial aviation businesses conducting similar operations.
  

Much, much MTF...P2