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Go to top of pageSpeech by Pip Spence
Advanced air mobility summit
Wednesday, September 1, 2021
On this page
As you've heard from Naa Opoku just now, there's a lot of work going on right now to ensure there is a coordinated, whole-of-government approach to managing and supporting the uncrewed sector.
Not surprisingly the Civil Aviation Safety Authority is playing a key role in the development of many of the initiatives.
Safety is of course a central element to the success of all sectors of aviation.
This is probably even more true in new and innovative areas such as Advanced Air Mobility.
And you need a clear picture of both what is expected in terms of safety outcomes and what the future regulatory environment will look like.
For this reason, we have a lot of work underway right now on a safety regulatory road map.
This roadmap will outline both the strategic regulatory direction and an understanding of the specific implications of likely regulatory requirements.
Over the next 20 minutes, I hope to give you an insight into the development of the roadmap, CASA's regulatory approach and share some of our work in the uncrewed sector.
I see CASA working closely with industry as key to the success of both our current and future initiatives.
We know that all safety knowledge and expertise doesn't reside within the walls of our organisation.
We have asked our Aviation Safety Advisory Panel to set up a technical working group to co-design the roadmap with us.
This group has 13 industry representatives and is co-chaired by Reece Clothier from AAUS and Luke Gumley from CASA.
There are nine principles that they are working to which cover issues such as regulatory cost, acceptable levels of safety, streamlining processes and supporting innovation.
To focus their work, we've asked the group to consider four core questions:
- Where should CASA regulate?
- Where can technology be leveraged to assist in regulation?
- Where are non-technology solutions best suited?
- How does Australia's regulatory framework compare with the rest of the world and what needs to change to support global harmonisation?
The Technical Working Group has now met a number of times and members are getting down into the nitty-gritty of the issues, which is very encouraging.
You can find their progress updates on our website and they are aiming to have a draft roadmap ready for public consultation by the end of 2021.
I would like to thank the members of the Group and indeed everyone else across the sector who has provided feedback and comments.
While the work on the roadmap proceeds at a good pace, the job of providing regulatory support to the uncrewed sector continues every day and indeed expands as the sector grows.
This means we're faced with the challenge of ensuring safety regulation is not holding back innovation and development.
I'd like to take you through a few real life examples of what we've been doing to support operations.
If I can, I'll get you to imagine you're responsible for the welfare of more than 300,000 head of cattle on dozens of properties spread across the nation.
It's a daunting job - you'll need lots of people and resources and the costs will be high.
How do you actually get around properties that can stretch 12,000 square miles?
In 2021, your solution could be drones.
But can drones really service vast areas of often remote cattle country where communications are difficult and high-tech uncommon?
For one large Australian agriculture business the answer was a resounding yes.
Remote drone monitoring of cattle properties for animal welfare and other requirements is happening, delivering results and, importantly for me, being done safely within the remotely piloted aircraft regulations.
To make this possible CASA has provided a number of approvals to operate beyond visual line of sight.
These were assessed using the structured SORA approach. SORA or “Specific Operation Risk Assessment” provides a defined process for the risk analysis of unmanned operations, as well as defining necessary mitigations and robustness.
The agriculture business running a drone fleet to keep an eye on their cattle considers that drones now play an important role in the future of agriculture and provide increased safety for staff and superior management tools.
The chief executive officer of the business has been quoted in the media as saying:
“Drones mean greater efficiency in costs along with higher levels of safety for staff. It's a win-win.”
Hearing words like this bring me a lot of satisfaction.
It means the approach CASA is taking is working and allowing businesses to innovate and prosper.
Despite what some people may say, those of us who work in the government sector do think and care about the real-world outcomes of policies, decisions and actions.
I know that in CASA I have a team of aviation experts who constantly strive to get the best possible safety and operational outcomes for the sectors we regulate.
Safety is of course the number one priority, but we also have a responsibility to ensure regulations and requirements do not stop businesses and individuals reaching their potential and being rewarded for their efforts.
This is particularly important in fast growing and innovating sectors where the burden of unnecessary red tape can stymie new ideas and discourage investment at critical points.
In the case of the cattle business, we needed to think well beyond what was, until fairly recently, the more traditional use of drones.
I do know that Australian Association for Unmanned Systems members have expressed concern about the time it takes for applications like this to be assessed and processed.
This is an entirely valid concern and I'll talk a little bit more later about some of the things we are doing to address it.
Despite these regulatory service-related concerns, we are in a good position today because CASA has been able to respond to the needs of the uncrewed sector in a timely and positive way.
This has been helped enormously by the foundation for uncrewed operations in the Civil Aviation Safety Regulations.
These are the modernised regulations that have been introduced over the last 20 years or so, with key elements progressively enacted.
One early area of the rules to be modernised and consolidated into one regulatory part was what we now know as Part 101.
This covers the use of unmanned balloons, unmanned rockets, pyrotechnic displays, model aircraft and remotely piloted aircraft.
Part 101 was developed back in the early 2000s and so did not envisage the drone technology of today.
Yet it afforded us a regulatory basis for assessing and then approving the use of emerging new drone operations in a way that gave Australia a competitive edge over other nations.
Of course, the rule set alone didn't guarantee drone technology would be given the green light to be used in new and interesting ways – it took a degree of foresight and risk taking by CASA's people as well.
A great example of this early free-thinking is the story of the go ahead for a drone home delivery service.
I'd like to play you a short presentation (CASA/Wing ICAO) which sets out how drone home delivery became a reality in two Australian cities.
"In April 2019 Australia was the first country in the world to approve a full drone home delivery service…"
"…they see we are doing things a little differently in this space."
There are a few things from that video that I'd like to highlight.
A salient point is that Wing chose to come to Australia because we had an aviation safety system that offered the flexibility to approve an entirely new way of operating and using drones in an urban environment.
Importantly, Wing had faith in the ability of CASA's staff to listen to what was being proposed and understand and embrace the safety and regulatory challenges.
This should not be underestimated, as it would in many respects have been easier and less risky for CASA to have declined to be a part of an experiment in a nascent aviation sector.
But, as Wing said in the video, they saw CASA as forward thinking and open to learning and innovating as the project developed.
The other key point made by Luke Gumley of CASA's remotely piloted aircraft branch is that we have understood the need to think differently as a regulator.
Historically, aviation safety regulation has been prescriptive and looking back this is not unexpected.
In the first decades of flying, the response within the aviation community to accidents was reactive and with most accidents linked to mechanical failures the solution was a to draw up rules and set standards.
Later concepts such as crew resource management and safety systems broadened our understanding of how to get optimal safety outcomes, yet by and large the approach of regulators was still prescriptive.
Today we understand the need to have outcome-based regulations and an approach that recognises that regulators don't have all the answers.
This approach allows the aviation industry to have the flexibility to use the most appropriate systems and procedures to achieve the safety outcomes the community expects that are set out in the rules.
You can choose to use a means of compliance provided by the regulator or you can find a different way to comply as long as the equivalent safety outcomes can be achieved.
This allows natural innovation and improvement to happen in the safety system.
For the uncrewed sector, which is the embodiment of innovation, freedom to work with the safety rules and not butt up against them as a hard barrier is essential.
Luke also mentioned that CASA will work with operators and prospective operators.
I'd like to strongly support that sentiment, as I appreciate that for people who are from outside the aviation environment the regulatory framework and its processes and procedures can be daunting at the very least.
CASA does have a role in helping you understand your safety obligations and the hoops that must be jumped through in seeking approvals or authorisations.
To date almost 2200 organisations have gained a Remotely Piloted Aircraft Operators Certificate.
These operators range from sole traders to large multi-national organisations and they have nearly 30,000 drones registered.
There are about 22,000 Remote Pilot Licences issued, with about 300 new licences issued on average each month. It won't take long before that overtakes the number of traditional pilots in Australia.
The fast growing and changing nature of the uncrewed sector means new safety and regulatory issues will emerge, demanding fresh thinking on behalf of the regulator, operators and individuals.
For CASA, a requirement to submit applications for approvals for some specific operations did not seem an onerous burden a few years ago when there were small numbers of operators conducting limited work.
But as the sector rapidly expanded so did the demands on CASA.
Naturally we dedicated more resources to the task.
We will continue this investment, however it is obvious smarter solutions are needed to efficiently deliver the appropriate safety outcomes without becoming a red tape hurdle.
A good example of seeking a smart solution to cutting red tape is the current trial of digital airspace authorisations near our major airports in Canberra, Adelaide and Perth.
It means getting access for drone operations within three nautical miles of each of those airports can be done digitally using one of the CASA-verified drone safety apps.
Requests for approval are automatically checked against CASA and Airservices data to decide whether the operation can be authorised. No fee is charged.
If the request is within the determined safe airspace around the three aerodromes the applicant is notified in real-time through the drone safety app.
Where this automated process is not available, a manual assessment by CASA staff is still required.
As well as providing a digital solution to cut through red tape we are standardising the approach to delivering these approvals, while ensuring the right safety outcomes for all airspace users and the general public.
Standardisation is important as it makes it easier for people applying for approvals to understand what is required and for CASA to make consistent and clear safety assessments and decisions.
It will also help us process things quickly.
To date, CASA has assessed complex applications on a case-by-case basis according to the SORA process I mentioned earlier.
We've now created standard scenarios for assessment which can be applied to a wide range of situations – particularly for beyond-visual-line-of-sight applications.
For each standard scenario there is guidance material, including information about how to assess an area, and the risk mitigations and procedures required to support the application.
In this way we are making the whole process simpler.
It is vital that open dialogue between CASA and the uncrewed and Advanced Air Mobility sector continues as we all understand there is no end point for these discussions, but rather they are steps along a path to a future we are still defining.
Despite the fact that we are designing a future in aviation without knowing the what the full picture looks like, there are some areas of focus for CASA and other regulators right now.
These include the design, certification and airworthiness of new aircraft, the design and implementation of future airspace arrangements, training and licensing standards for pilots/controllers and standards for ground infrastructure.
The approach to these issues world-wide is initially being led by the way regulators currently manage safety in the crewed sector, but this will necessarily change as the technology drives us towards increasing levels of autonomy.
I have seen the way regulators are tackling these issues described as a crawl-walk-run approach.
It makes sense that we don't want to run before we are ready, but I'm not sure about the 'crawl' aspect!
I guess what is really being said is that how we regulate safety in the world of advanced air mobility is still evolving and will mature over time.
The key for us all is how quickly advanced air mobility matures and making sure we do not lose sight of the need to maintain appropriate safety standards.
It is always important to remember that none of us 'do' safety for the sake of safety.
We 'do' safety because there is a public expectation that modes of transport made available to the community will have acceptable standards of safety – that the risks will be professionally and carefully managed.
Ignoring this basic truth brings perils for us all - whether we are regulators, businesses or innovators and experimenters.
Public confidence in new forms of transport will only come if safety is demonstrable and deliverable.
Never-the-less, the history of aviation tells us it is productive to dream and dream big.
Right now, we regularly see stories in the media about people and companies doing just that right across the uncrewed sector.
Public imagination is lit by stories about 'flying cars' and impending break throughs in urban mobility that promise to free us from traffic jams, car parking pain and crowded public transport.
The people building this new future – the people taking part in this important conference today – can be the 'Henry Fords' of this century.
More than 100 years ago the science behind safety was not understood and it took a human toll to drive the development of safety standards and later safety culture.
We are blessed today to still have the fire of innovation to push us towards an advanced mobility future, now with the knowledge of how to safely manage and mitigate the inevitable risks.