Development of UAS in civil airspace and challenges for CASA
Association for Unmanned Vehicle Systems Australia
Melbourne – 25 February 2013 (keynote address)
I would like to thank you for the opportunity to speak to you today.
Growth of the UAS and CASA’s focus on safety
Aviation is a dynamic environment, internationally and domestically and there are always a number of challenges for CASA and the aviation industry at large. While these challenges are different, they both need to ensure that safety related considerations are at the forefront of our thinking.
One of the key challenges is the rapid growth in the Unmanned Aircraft Systems (UAS) sector. To better reflect the status of these aircraft as being controlled by a human remote Pilot, the terms ‘Remotely Piloted Aircraft’ (RPA) and ‘Remotely Piloted Aircraft System’ (RPAS) are being introduced into the lexicon.
In February 2012, there were 15 holders of Operators’ Certificates in Australia operating small remotely piloted aircraft for commercial purposes. Today, this number has doubled to 30 and the growing number of enquiries we receive on a daily basis suggests that this number will be more than double again within the next 12 months. This rate of growth reinforces to me that safety must remain as our number one priority. This is further strengthened in the National Aviation Policy White Paper which requires CASA to enhance oversight of the operation of UAS (or RPAS).
Events such as this conference are very important for CASA and industry to share experiences and so that we all hear the different perspectives. As you all know CASA is Australia’s civil aviation safety regulator. We have no authority to allow economic or commercial considerations to influence safety-related decisions we are obliged to make. It is only after all relevant safety-related factors have been considered with due precedence, that the economic or commercial considerations of that decision might be taken into account. Where a less onerous, but equally safe, alternative is allowed by the law, CASA will certainly entertain that option.
As I outlined during my recent interview on the 7.30 Report, approximately 90 per cent of the RPAs operating in Australia today are less than 7 Kgs and are relatively inexpensive and easily accessible to individuals through the open market. As you would appreciate, due to increasing number and their varied capabilities, it is impossible for CASA to effectively regulate all of them.
We have to address the current reality. There is no point in CASA writing regulations that can't be enforced. That's just bad law. Consequently, CASA is now looking at introducing a weight limit to make it less onerous, but still safe, for commercial operators to use small remotely piloted aircraft. You will hear more about these issues in the presentation tomorrow by Jim Coyne and Phil Presgrave.
CASA’s fresh regulatory framework
The current Civil Aviation Safety Regulations 1998 (CASR) Part 101 deals with unmanned aircraft, model aircraft and rockets. As a result of rapid growth and technological advancements in this industry, this regulation has become somewhat ineffective and needs amendment. Eventually, we will produce a new Part 102, which will introduce the new terminology (RPA, RPAS etc) and will bring the regulations into line with ICAO and will incorporate the emerging work of other leading regulatory bodies like FAA and EASA.
The principal objective of a fresh aviation regulatory framework is to achieve and maintain the highest possible uniform level of safety. In the case of RPA, this means ensuring the safety of any other airspace user as well as the safety of persons and property on the ground.
Identifying the commonalities and differences between manned and unmanned aircraft is the first step toward developing a regulatory framework that will provide, at a minimum, an equivalent level of safety for the integration of RPA into non-segregated airspace and at aerodromes.
Technical specifications to support airworthiness, the command and control data-link, detect and avoid technologies, and other functionalities are being addressed by various industry standards development organisations around the world. CASA is closely monitoring these developments and will remain focused on the higher-level performance-based standards.
Development of the complete regulatory framework for RPAS will be a lengthy effort. This is not a knee-jerk reaction, it is an evolutionary process, with regulations being added or amended gradually. In the first instance, non-binding guidance material will be provided in advance of the regulations for use by the industry. Close adherence to the guidance material will facilitate later adoption of the revised or new regulations and will ensure harmonisation across the industry and with the rest of the world.
Broader use of RPA and current limitations
The roles of RPA will continue to expand as technologies and performance characteristics become better understood. Long flight durations, covert operational capabilities, and reduced operational costs serve as natural benefits to many communities, such as
law-enforcement, agriculture and environmental analysis. As technologies develop, mature and become able to meet defined standards and regulations, RPA roles could expand to include operations involving the carriage of cargo and eventually possibly even passengers.
A civil market already exists for RPAS. However, this market will likely remain limited until the appropriate regulatory framework is in place. Any significant expansion will also depend upon the development and certification of technologies required to enable the safe and seamless integration of RPA into non-segregated airspace. I am speaking here of the technologies relating to detect and avoid.
The demand for small RPA flying visual line-of-sight for law enforcement, survey work, and aerial photography and video will continue to grow. Larger and more complex RPA, able to undertake more challenging tasks, will most likely begin to operate in controlled airspace where all traffic is known and where ATC is able to provide separation from other traffic. This could conceivably lead to routine unmanned commercial cargo flights.
Privacy and environmental concerns
The right to privacy is another controversial topic one hears when discussing RPA. Dealing with matters related to privacy is not part of CASA’s role; it is a matter for the Australian Privacy Commissioner.
However, CASA believes that the RPAS community can play a critical role in educating the broader public and engaging in meaningful dialogue with them to demonstrate the positive aspects of RPA technology and the benefits that can be provided to mankind.
Another evolving topic is environmental issues; again, while acknowledging that it is not part of CASA’s role, like manned aircraft, RPA operations will have an impact on the environment. It is critical that as RPA are designed, built and operated, their environmental footprint, noise and gaseous emissions, are compliant with the applicable standards.
Close interaction with ICAO and other international bodies
CASA is working closely with the International Civil Aviation Organization (ICAO) in the development of standards and recommended practices for remotely piloted aircraft systems on a global level. Australia is honoured to have one of our own, Jim Coyne, appointed as chair of the ICAO unmanned aircraft systems study group. ICAO has set up this study group to develop the regulatory framework to integrate it into non-segregated airspace alongside manned aircraft. As Chair, I expect Jim will be steering the group towards developing a package of standards and recommended practices, as well as the associated guidance material.
I have personally chaired the 12th Air Navigation Conference, held in Montréal late last year. This Conference was attended by over one thousand participants from 120 Contracting States. The purpose of the Conference was to define and achieve consensus on the next steps toward realising a collective vision of an interoperable, seamless and global air traffic management system for international civil aviation in the 21st century.
A number of recommendations came out of the conference relating to RPAS, most notably, that ICAO, as a matter of urgency; develop the necessary regulatory framework in its entirety to support the integration of RPA into non-segregated airspace and at aerodromes. The other notable recommendation is for all States to work closely with ICAO and each other to ensure harmonisation of provisions to accommodate RPAS operations.
As the regulator, we need to develop procedures and processes consistently taking into account the work of ICAO and the leading manufacturers of RPAS from the US, Europe and Asia. We need to continually identify training and experience requirements for our inspectors and related staff.
CASA’s proactive approach
CASA is under increasing pressure to allow greater use of RPA, both from industry and our government. However, we must always be cognisant that safety must remain our first priority.
To facilitate a consistent approach, I have directed our Operations Division to establish a specialist UAS team which will manage all aspects of UAS operations. This Division has already made offers to two individuals who will join Phil Presgrave in the UAS team. The creation of this team also comes with my commitment to ensure the staff employed remains current in terms of skills and training relevant to the UAS industry.
CASA will transition its regional UAS operations to this Division by Easter 2013, although some current applications which are well advanced may remain in the regional offices through to completion.
We are considering to make the process of obtaining an UAS Operators’ Certificate less onerous to the industry whilst not sacrificing safety. The entry control criteria will be assessed to more appropriately match the level of complexity and risk posed by the applicant’s proposed operation.
As you are probably aware, CASA works very closely with the aviation industry through the Standards Consultative Committee (SCC), which is made up with number of subordinate groups, to make recommendations to CASA on the development of regulations, standards and other associated advisory material.
Under the patronage of SCC, a RPAS Working Group was formed to review regulations and advisory material with an objective of providing more comprehensive guidance to industry on the regulatory requirements and approval processes for commercial operation of RPAS in Australia.
The guidance will consider the long term integration of RPA into normal aviation operations in all classes of airspace. I know that some of you are members of this working group, and are providing valuable advice to CASA.
A number of Advisory Circulars relating to operations, training and licensing aspects of RPAS are due to be released for public comment in the next month or so. I recommend that you review these documents and provide your comments to CASA.
The working group is also looking at developing a special set of regulatory provisions that will allow the use of RPA in emergency situations in a responsive manner whilst operating safely. It is my firm belief that RPA can provide a very valuable benefit for emergency services and CASA is being proactive to enable these operations to benefit our community.
In closing, I commend the Association for Unmanned Vehicle Systems Australia for bringing together the regulator, academia, RPA operators and manufacturers, and Defence to look at some of the challenges posed by the rapid growth of RPAS’ operations.