NOTICES TO OPERATORS
These Notices to Operators are intended as a courtesy to Australian certified UAV Operators in order to impart information of safety or operational significance, or to impart information to help certified UAV Operators stay abreast of regulatory and industry developments.
If you have information of this nature that you believe is important to all UAV Operators, please email the details to the: [email protected]
NOTOP 06 - 19-10-14 COMMERCIAL OPERATION OF UAVs INDOORS
ACUO wish to advise the following information has been received from CASA in relation to the commercial operation of UAVs indoors.
[e.g. Conference Centres, Exhibition Halls etc]
CASR Part101.005 (3) states: Subparts 101.C to 101.I do not apply to the operation of: [in part]
(b) a model aircraft indoors;
(c) an unmanned balloon indoors
However, the regulation is silent on the use of a UAV indoors.
CASA suggest that as the CASR101 regulations also state that;
- CASR101.055 (1) – “A person must not operate an unmanned aircraft in a way that creates a hazard to another aircraft, person or property”, and;
- CASR101.245 (1) – in part: “…..A person must not operate a UAV within 30m of a person who is not directly associated with the operation of the UAV”
- [And giving due consideration for CASR101.280 (1) (2) & (3) – UAVs not to be operated over populous areas]
CASA would require the UAV Operator and the controller(s) to have CASA certification, and the event would most likely require some form of CASA approval or exemption.
If you require further information about the operation of UAVs indoors please contact the CASA UAS office direct: [email protected]
NOTOP 05 – 18-07-14 G20 SUMMIT MEETINGS
ACUO has received notice from CASA about the upcoming G20 summit meetings in Australia later this year. Certified UAV Operators are reminded that Cairns & Brisbane are hosting G20 summit meetings:
- The G20 Finance Minister’s Meeting in Cairns takes place 18-20th September.
- The G20 Heads of State Meeting in Brisbane takes place 15-16th November.
Of particular note is that for the period 11-18th November, the entire Brisbane airspace [from surface to 18,000ft] will effectively be shut-down for 90nm around Brisbane airport.
Only scheduled passenger aircraft and those aircraft which are registered with the Qld Police Operations Centre will be permitted to operate in Brisbane airspace during this time.
Note also that the Qld Government has enacted sweeping powers for police and enlisted services to curb any unauthorized activities or activities deemed to be a threat. This includes the use of Model Aircraft and just about all remote controlled equipment, including UAVs. [Reference: Qld State Govt – G20 (Safety and Security) Bill 2013]
If at all possible, it is best advised to avoid Cairns & Brisbane during these G20 summit meetings. If you must operate in Brisbane or Cairns during the summit meetings, please contact the Qld Police Operations Control Centre for advice.
Further information can be found in AIP-SUP H62/14, at the Airservices Australia website for AIP’s, Supplements and other operational information.
NOTOP 04 – 18-07-14 CASA SURVEILLANCE MANUAL
ACUO would like to remind certified UAV Operators of CASA’s defined procedures for conducting ‘Health Checks’ and Audits on certified UAV Operators to ensure they are maintaining safe operations.
[CASA surveillance is conducted on all aviation activities and the unmanned aviation sector is no different. The information provided here is purely as a reminder of what CASA is trying to do to maintain common standards amongst those who are certified for unmanned aircraft operations.]
The CASA Surveillance Manual was last updated in February this year . Annex 16 of the CASA Surveillance Manual details the framework of CASA’s surveillance system as it applies to certified UAV Operators. As you will see, there are a wide range of variables that CASA can look at and not all operators will be audited the same way. [although we should all be audited or health-checked in accordance with the same defined processes & procedures in the CASA Surveillance Manual.]
We are aware that CASA is conducting surveillance activities on both certified & uncertified operators and is also conducting annual audits of UOC holders as part of routine surveillance procedures. The feedback from those certified UAV Operators already audited is that the CASA inspectors have been helpful & the audits productive. If you are operating in accordance with your CASA approved Operations Manuals you should have nothing to fear.
If you are a UAV Operator coming up on 1 year of operations and renewal of your UOC, or haven’t had a ‘Health Check’ or Audit yet, you might want to avail yourself of the information in Annex 16 of the CASA Surveillance Manual and ensure your records and paperwork are up to date.
Note too that if you are audited, you should receive a written copy of the audit findings afterwards.
NOTOP 03 - 11-07-14 DANGEROUS GOODS
ACUO is advised there have been a spate of incidences lately of airline passengers either exceeding the limit for Lithium batteries on aircraft, or not declaring Lithium batteries in airline luggage.
ACUO wish to remind UAV Operators of the aviation regulations relating to Dangerous Goods, which includes Lithium batteries. There are limits to the type, size & number of batteries you can carry on an aircraft, or transport on an aircraft in Australia.
If you are carrying Lithium batteries on aircraft, make sure you protect your batteries appropriately for airline carriage and that you don’t inadvertently exceed the limits for lithium battery carriage on aircraft.
The CASA website has some good information & links on dangerous goods in aviation.
The CASA website also has a page on how to calculate maximum battery allowance.
If there are any doubts about the safety or legality of carrying or transporting Lithium batteries via air, please contact your airline for more advice, or send your batteries ahead by surface freight instead.
NOTOP 02 - 11-07-14 AREA APPROVALS
The Area Approval process seems to have many certified UAV Operators getting a little hot under the collar with the aviation regulators, due to the delays and costs in processing these approvals.
We fully understand the anxiety & frustration from this and the imposition it has on people’s businesses, but there are safety implications to consider and the last thing we want right now is UAV Operators breaching the regulations and giving the regulators a reason to restrict us even more.
ACUO is on the case and talking with Airservices Australia and CASA on how we can resolve the issue. Bear in mind that all manned aircraft in Controlled airspace are required to carry a transponder and be able to squawk a discrete transponder code. Currently, UAVs operating below 400ft AGL do not. If we want it to stay that way let’s all act responsibly until we can find a more workable solution.
In the meantime, the best advice is to get your Area Approval applications in to the CASA office at the earliest possible convenience. By the time CASA look at your application and get an estimate back to you can take a week and the estimate is valid for a full 30 days.
If the job for the Area Approval goes ahead, all you have to do is pay the amount via direct EFT and notify the CASA office with a remittance advice. The application should go for processing the same or next day. If the job falls through then you cancel the Area Approval application immediately.
What you need to be cognisant of with your application is not just the increased public risk from your proposed operations but the generally higher aviation risks, and what might happen should you encounter a problem or fault in your UAV system. In Controlled airspace there is usually a higher RF environment and the communications link is often the weak-point in UAV systems. There are also myriad ways to deal with emergencies in different UAVs. You might have some idea of what your UAV will do in an emergency, but Airservices has no certainty, and that’s exactly what they do need if they are going to be directing manned aircraft to avoid you.
It is also not uncommon to find manned aircraft below 500ft AGL in Controlled airspace and there are safe separation standards that need to be applied between aircraft, both manned and unmanned. The reality is that most if not all other aviation activities have priority over UAV operations and often those manned aircraft operating below 500ft AGL are there for a more serious reason than yours or mine.
Obviously, you will improve the application processing time if you use the standard Area Approval application and the matrix provided, to give as much safety information as you can to CASA & ASA for them to make a reasonable determination. If CASA & ASA can clearly see in your application that you have conducted a thorough risk assessment and can clearly see how certain risks will be mitigated, your chances of success are going to be greatly improved.
Above all, please, be patient and don’t be tempted to give the regulator an excuse to move the other way. We are doing our best to resolve the situation but it isn’t going to happen overnight.
NOTOP 01 - 16-06-14 NPRM 1309OS
ACUO response to the CASA NPRM1309OS was lodged today with CASA. This took a huge amount of effort by the Management Committee members to read & understand the changes being proposed by CASA before we could start formulating responses.
The NPRM covered not just the 4 Key Proposals made by CASA but also more than 50 individual changes throughout the CASR101 regulations as well as 3 new Advisory Circulars, all to be checked to determine what (if any) impact those changes might have on Operators and industry.
ACUO believes a key proposal in the NPRM (Proposal No 4) may have significant safety and risk implications for all aviation interests in Australia. ACUO submission provides an alternative solution and makes 2 key recommendations to improve the safety & integrity of the RPAS industry in Australia.
For the record:
There was no opposition to the recommendations made by this association from any of the 28 members of ACUO, nor was any opposition lodged with ACUO from anyone outside the association.
In addition to the ACUO membership, there were 25 non-ACUO certified UAV operators and 5 individual UAV Controllers who fully supported ACUO initiatives & recommendations via petition.
As of June 16th, ACUO has the backing of 53 certified UAV operators in Australia, just short of 50% of the 109 UOC holders to date.
ACUO wish to thank all the UAV Operators & Controllers, members or not, who supported our submission via petition. Your support shows that ACUO policies are relevant not just to our members but the wider commercial industry-base as well, giving us the confidence that we are representing the commercial sector of unmanned aviation adequately and appropriately.
Whilst we wait now to see what comes back from CASA in a Notice of Final Rule Making (NFRM) later this year, ACUO continues to represent certified UAV Operators though the CASA Standards Consultative Committee.