One of our activities was to discuss the current regulatory environment. In Australia, this is controlled by the Civil Aviation Safety Authority (CASA) and can be challenging to navigate. It was comforting to know that I am not the only one grappling with working my way through the system. Given the complexity of it, I thought that it might be useful to cover some of that here for any new players.
In all fairness, CASA is dealing with a rapidly changing technology and is doing its best to keep up. But with legislation that is more than ten years old, the current state of UAS is well beyond it. We are anticipating some changes in the near future, but until these are released, we must work within the bounds of the current rules.
Here’s what we know:
1. All remote pilots must abide by the following (unless exemptions are given – though these take time and money to request):
a. No flight within 3NM of an airport or helipad
b. No flight within controlled airspace
c. Maximum altitude of 400 ft above ground
d. Minimum distance of 30 m from people and property
e. Maintain unaided (i.e. no binoculars) visual line of site of the craft
f. Have a minimum of 5 km visibility (this is enough to stop people operating in bushfires, there is no need for a separate ruling here)
g. Daytime flight only
h. No flight if the clouds are lower than 1000 ft
Many people knowingly or otherwise violate these regulations and can certainly be fined by CASA for doing so.
2. If you are flying for any reason other than sport or recreation, the following also apply:
a. Individuals must complete RPAS training including a radio operator’s licence (AROC), English proficiency, theory and practical testing, and five hours logged flight. This covers flight for platforms with a maximum take of weight (MTOW) <7 kg. Estimated total cost $5,000 per person, five days training
b. Additional manufacturer’s training per person, potentially including ‘heavy lift’ for >7kg platforms. Estimated total cost $250 - $2,000 per person, half day to multiday training
c. Operator’s Certificate – This is required for the Organisation, but is given to named individuals as the Chief Controller and Maintenance Controller. Note that this is a challenge if staff turnover is high, as a new OC will need to be sought if these positions change. Compile and submit organisational documents and procedures to CASA, 3 hr practical exam and 2 hr oral exam. Follow up audits at 9 months and 3 years. Estimated total cost $10,000
Note that the costs given above do not include staff time, so the investment is significantly greater than this. There are some other interesting points to consider as well if heading down this route:
1. CASA certification process may take up to 1.5 years given the current waiting times
2. The OC is given for a specified platform only. So if you add to your ‘fleet’, you need to re-apply to CASA to have your new platforms listed and tested.
3. With more than one platform, the regulations state that you must employ a full time Chief Controller – i.e. this is the only job that they do. You can apply for an exemption to this though if only flying small (<150kg) platforms. This restriction would otherwise be prohibitive for small business for example.
Finally, aside from formal regulations, there are other items to include in your reality check when considering whether or not UAS applications are for you:
1. Must invest time and money into continual training and flight practice for your pilots
2. Preferably find an easily accessible location to fly and train without having to go miles away
3. Not everyone can be a pilot even if they have been trained – some people just aren’t cut out for it, therefore you may lose on some of your investment
4. Need to keep a redundancy in people, platforms, and sensors to ensure your business can keep running
5. Have to ensure all maintenance and flight logs are appropriately documented (prepare to be audited)
6. Purchase Ozrunways mobile app for aeronautical charts and radio frequencies
We estimate the overall start-up cost at around $200K-$250K to be operational, including staff time and training, certification, base platforms. The long term benefits hard to quantify, but in some cases this is the only technology that will provide the answers you need.
By comparison, around $2K per day + a mobilisation fee might get a commercial company to do the job for you… But most likely that would only be with a standard RGB camera. If you want to use thermal, hyperspectral, or LiDAR it would be another story. If you’re interested in hyperspectral sensors, have a look at my blog about the current options.
I wrote this not to deter new comers from entering the field, but to provide a realistic point of view so that it’s possible to make an educated decision about the real costs involved. It's not all sunshine and puppies! And I haven't really touched on the steep learning curve associated with flying and developing workflows for data analysis. It really needs to be someone's baby that they are fully dedicated to making work!
I wonder how this process is going to change over the coming years? Surely it's got to become cheaper and easier.
Thanks to all of the other workshop participants for the discussions that formed the basis of this blog.