Have your say: proposed changes for large RPA – airworthiness and maintenance

The proposals would:

• add flexibility to how airworthiness certification can be used
• streamline the approval pathway for maintenance permissions.

What’s proposed

Airworthiness flexibility (Part 101)

We propose to amend regulations to:

• allow any type of certificate of airworthiness for large RPA, when the operation meets the related rules in the Part 101 MOS
• allow the Part 101 MOS to set circumstances where a certificate of airworthiness is not required for a large RPA operation, supported by risk and outcome-based provisions.

Under the MOS, a large RPA operating with a certificate of airworthiness must comply with its conditions and limitations.

Operating without a certificate would only be allowed where:

• the RPA does not carry occupants
• the operation has no adverse effect on safety, as proven by completing a risk assessment by an acceptable method
• CASA approves the operation through an existing operator approval arrangement, such as a ReOC.

Maintenance permissions (CAO 100.24)

We also propose minor amendments to the rules to:

• make approvals for maintenance permissions for large RPA more efficient
• keep existing competency standards for applicants
• modernise language, remove obsolete forms and references, and update submission methods (including related updates to CAO 100.23).

There is no change to the competency standards or approval process for maintenance permissions for crewed aircraft.

Why your views matter

Your feedback will help make sure the proposals are fit for purpose, clear, and workable. It will also help us balance flexibility as technologies evolve. These changes form part of the RPAS and AAM Strategic Regulatory Roadmap.

How to provide feedback

We invite you to provide feedback on the proposals via our consultation hub:

• Large RPA airworthiness certification closes on Friday 21 November
• Large RPA maintenance permissions closes on Tuesday 18 November.