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Guidance material for RPAS operations which encompass Research and Development or limited product demonstrations

Due to the rapid growth in the RPAS sector; CASA is receiving a number of enquiries from organisations wishing to conduct both short tern Research and Development (R&D) activities or short term demonstration activities of RPAS; for which they are not certificated or licensed.

In order to enable these activities CASA has produced a process by which operators of RPAS wishing to conduct such activities can apply directly to CASA to seek approval. The process enables CASA to appropriately satisfy itself that the activities can remain both safe and legal; whilst at the same time being no more onerous than those required to conduct similar air-work activities which fall within the regulations as written.

The process is described below at a high level, however CASA recommends that any organisation who is considering seeking approvals to conduct either R&D or demonstration activities contact CASA via rpas@casa.gov.au and request a phone call from an RPAS inspector to help provide further guidance. When emailing CASA please put “Request for R&D approvals” as the title.

How to apply

In order to operate within the R&D - Demo category applicants will require three separate instruments from CASA as follows:

  • Exemption against holding a Remote Operators certificate (ReOC) for the sole purpose of the specified activity
  • Exemption against holding a Remote Pilots Licence (RePL) ) for the sole purpose of the specified activity
  • An area approval; which outlines in detail the specified activity and any conditions which CASA has placed upon the activity.

Applications along with a safety case and any supporting documentation should be lodged to rpas@casa.gov.au with the following information provided:

  • A completed area approval application form which can be obtained from the CASA website.
  • A letter requesting exemption from the requirement to hold a ReOC for the specific purpose of conducting the R&D or demonstration activity. This must contain the full details of your registered business. All applicants will be required to hold an Australian Aviation Reference Number which can be applied for using form 1170 available on the CASA Website.
  • A letter for each pilot requesting exemption against the requirement to hold a RePL for the specific purpose of conducting the R&D or demonstration activity. This must contain the full details of each pilot. All pilots will be required to hold an Australian Aviation Reference Number which can be applied for using form 1162 available here:
  • A detailed concept of operation which outlines precisely the nature of the operation; including but not limited to:
    • RPA types
    • RPA weight and configuration
    • Operators previous experience and qualifications
    • Pilots previous experience and qualifications
    • If operating Beyond Visual Line of sight BVLoS details of the pilots qualifications to do so – such as a pass in an instrument rating examination (or similar if from another State)
    • If operating where an aviation radio is required evidence that the Pilot in Command holds an Australian issued radio licence
    • Proposed location of operations
    • Proposed date of operations
    • Proposed duration of operations
    • General description of the operation
    • Evidence of similar operations conducted elsewhere
    • Evidence that the chief remote pilot (person in-charge of the RPAS operation) understands Australian Air law as it relates to the operation of RPAS
  • A detailed project plan which outlines any gateway reviews which will be undertaken as the project progresses. These should be clearly articulated in terms of:
    • When does the gateway review take place
    • Who can undertake the review
    • What are the specific Go  No-go criteria for the review
    • What evidence will be used to inform the review
    • Who makes the final decision within the organisation
    • How will CASA be engaged in the review process
  • A detailed risk assessment and risk management strategy which clearly identifies:
    • The level of acceptable risk
    • A complete table of all identified risks including unmitigated likelihood and consequence
    • A table or other suitable document which clearly articulates how the risks will be managed and what the mitigated likelihood of al risks will be
    • The qualifications and experience of the person undertaking the risk management
    • Who can make the final decision as to if the operation meets an acceptable level of risk.

What happens once you have applied?

On receipt of your application CASA will undertake an initial review to determine the likely feasibility of your proposed operation. If the initial review indicates the operation as stated is not feasible CASA will advise you in writing. If the operation looks initially feasible then CASA will provide you with an estimate of costs and a proposed delivery date for the outcome of the full review. Please note this is not a guarantee that the operation will be approved; just that from an initial review the operation appears feasible. As at June 2017 the average fee for application is anticipated to be in the region of $1,200 and the service delivery time to be 60 days, from receipt of full payment.

Once the estimate fee is paid, your application will be assessment within reasonable timeframe. CASA may request further information to help guide the decision making process and may request demonstrations of the RPAS and crew. Please note the basic estimate will not normally have included fees for such events and therefore additional fees may be incurred.

Once satisfied with the information to make a decision CASA will inform you in writing of the decision. If the decision is to issue the instruments then the exemptions and area approval will be issued to you as one contiguous body of work

What happens once you gain your approvals?

The area approval issued will contain a number of conditions based upon the concept of operation; which are considered to be a legally binding agreement between the applicant and CASA. The applicant must ensure they fully understand the conditions as drafted and can comply with them.

Should the applicant wish to operate beyond the conditions as drafted then a revised application must be made.