Project OS 04/03 - Post Implementation Review of CASR Part 101 - Unmanned Aircraft and Rocket Operations
Project closed 19 January 2012.
CASR Part 101 was drafted nearly 10 years ago in anticipation of civil operations of unmanned aircraft systems. Project 04/03 - "Post Implementation Review (PIR) of CASR 101" was initiated in 2004 and Project 05/01 - "Certification requirements related to the design, manufacturing and airworthiness of UAVs" was registered in April 2005. As both these projects had limited progress, the work to date now does not reflect the path being taken by ICAO, the FAA or EASA.
In the two year period since implementation of Part 101, considerable legislative change has rendered many references and procedures contained in Part 101 inconsistent with current requirements. Further, operating experience with Part 101 has highlighted a number of areas where the legislation is inconsistent either within the Part or with guidance material or duplicates legislation now contained in other CASR Parts.
There have been reports from field offices that the legislation is difficult to apply and enforce while comment from industry and regulatory staff indicates that sections of the legislation are complex and difficult to interpret.
Guidance material accompanying Part 101 consists of a suite of three advisory circulars and a draft operator certification manual. All documents need revision in light of experience and will need to reflect amendments made to Part 101 during the review process.
There is inadequate guidance material for airworthiness certification or controller and maintainer licensing. Further, while there is emphasis on risk management in existing guidance on the operation of UAVs, there is no formal guidance to prospective operators on the application of risk assessment, risk management or risk mitigation principles. These oversights must be addressed during the review.
The proposed review of Part 101 involving consultation with all stakeholders will seek to identify:
- elements of the legislation where interpretation has caused difficulties
- elements of the legislation which are difficult to implement or enforce
- inconsistencies between provisions of the legislation and with other legislation
- elements of the legislation which are overly complex
- requirements for new or amended guidance material.
This project was approved and announced 29 June 2004.
- Part 101 of CASR 1998
Project Leader/s: Mike Adams, Standards Branch
Project Sponsor/s: Executive Manager, Standards Division
View the project history.