03 Jan Australian BVLOS Approvals (Beyond Visual Line Of Sight) – Standard Scenarios
Australian BVLOS Approvals
The standard operating conditions for operating a remotely piloted aircraft (RPA) in Australia are very specific in that they state that the pilot must keep the RPA generally within their visual line of sight (VLOS) without any aids (other than corrective spectacles or sunglasses). The recent release of the manual of standards 101(MOS101) has introduced extended visual line of sight (EVLOS) but this will only support specific operations. Most large-scale RPA operators and operators who need to cover large areas or distances are seeking beyond visual line of sight (BVLOS) operations to make these operations both cost-effective and efficient. CASA has stated that the Specific Operations Risk Assessment (SORA) created by the Joint Authorities for Rulemaking on Unmanned Systems (JARUS) is the preferred method for assessing Australian BVLOS approvals.
SORA is a bowtie analysis of the hazards and risks of RPA operations in a number of defined ground and air environments. These are combined to provide a Specific Assurance and Integrity Level (SAIL) for the operation which in turn dictates up to 24 Operational Safety Objectives (OSO). The RPA operator then must show how they will meet each of the relevant OSOs to the satisfaction of the competent authority (CASA). If each RPA operation has to be evaluated from first principles, each time an operator applies to CASA, the SORA process becomes cumbersome and unwieldy. The SORA process does allow for the creation of standard scenarios; JARUS have created one. CASA has also developed a standard scenario based on the SORA process for use in remote areas of Australia which was announced at the 2019 AAUS conference.
SORA is a risk based approach to RPA operations based on a particular operating environment and SORA acknowledges that certain operating areas do not reflect the areas that SORA was designed around, the remote areas of Australia could be considered one of these. The Australian Bureau of Statistics (ABS) has provided a map of Australian population distribution (Fig 1.) which shows that large parts of Australia are inhabited at a density of 1 person per km2 or less. In these areas, the ground risk to people and property could already be assessed as low and it is feasible to avoid inhabited buildings at the planning stage. If there aren’t many people living in an area it is likely that there are few air operators operating in Class G airspace below 5000ft AMSL. CASA has designated large parts of these areas as remote for manned operation as shown in fig 2.
It appears that CASA has refined these concepts into designating a large part of Australia as a single area in which RPA BVLOS operations will be assessed against standard criteria as shown in figure 3. The large inland area bounded by the pink lines is what we think CASA are considering. It is our understanding that this can be applied up to 5000ft AMSL. It doesn’t change the responsibilities of the operator but provided the RPA energy is low and operating within the defined area the standard scenario may apply.
The advantage of this approach is that it provides clear guidance on what an RPA operator is required to provide as part of an application for CASA to approve an area for BVLOS operations. It doesn’t change the need for an IREX, remain 30M from non-consenting people, not overfly populous areas, etc. but it just makes it easier to know what is required.
Australian BVLOS Approvals
CASA is intending to put information on the assessment process for BVLOS operations in remote areas up on its website but this hasn’t happened yet. However, here are a few trends we are observing being requested of applicants for Australian BVLOS approvals:
Extensive stakeholder engagement,
C3 Link performance
Multi Crew Cooperation
Human factors evaluation
Emergency response plan
Third party provided services assurance
CASA will provide guidance on what you need to do for effective stakeholder engagement and to manage the air and ground risk but expects applicants to have an understanding of the JARUS SORA process. CASA will use OSO’s which are safety objectives that historically have been used to ensure safe RPA operations. It represents the collected experience of many experts and is, therefore, a solid starting point to determine the required safety objectives for a specific operation. CASA may define additional OSOs for a given SAIL and the associated level of robustness but to our knowledge has not required that to date. OSO’s robustness is defined as optional, low, medium and high which is a combination of integrity and assurance i.e. put simply what is the standard you are claiming and how are you demonstrating compliance with that standard. In the remote Australian airspace scenario nearly all the OSO’s robustness is low so with a reasonable RPA, some well trained people and good procedures most operators could achieve the required standard.
A standard scenario doesn’t mean the operation will be scrutinised any less than a full SORA only that the operational volume and risk considerations have already been reviewed and greater guidance offered over what is required. This has meant that assessment times and cost are rapidly reducing from being an operation that was only available to the large well funded company to something that can be approved in less than 2 months and significantly reducing CASA fees, current fees are approximately $2500. Should your organisation need any assistance in deciphering SORA or indeed help in preparing or obtaining these Australian BVLOS approvals please do not hesitate in gaining contact with Hover UAV to allow the maximum potential of your RPAS program to be unleashed. Our dedicated team of consultants have a wealth of knowledge in complex RPAS operations.