Author: isoadmin

Hover UAV is excited to share that we are holding 1-day training courses for the Specific Operations Risk assessment (SORA) method of risk assessment. The SORA is CASA’s preferred method for assessing the risk of complex projects, such as BVLOS. The SORA methodology was developed by JARUS (Joint Authorities on Rulemaking on Unmanned Systems), a group of experts gathering regulatory expertise from all around the world. The objective is to recommend a set of technical, safety and operational requirements for all aspects linked to the safe operation of specific RPAS operations where certification would be too expensive or inappropriate.

Learn how to develop a safety case to obtain BVLOS approvals using the SORA methodology. Our next SORA training course dates are as follows:

• 13 September

• 11 October

• 10 November

Contact us for more information or to book your course. We look forward to seeing you soon

BVLOS New Zealand (Beyond Visual Line of Sight) – Part 102

To enable drone operations outside of the Part 101 regulations in New Zealand, including operating Beyond Visual Line of Sight (BVLOS), drone operators are required to hold an Unmanned Aircraft Operator Certificate (UAOC) granted by the NZ CAA under Part 102.  

The Part 102 application process can take several months and involves identifying a ‘Prime Person’, conducting a safety case, preparing an exposition (operations manual), and managing the application with the CAA. There may also be a requirement for flight or equipment assessments to be conducted, and additional training and qualifications to be obtained.

Understanding the Part 102 application process for BVLOS operations, or other complex operations, will ensure the quality and completeness of your application and prevent further delays in obtaining your UAOC.

The Part 102 Application Process – BVLOS New Zealand

The first part of the 102 process is to prepare all the relevant information required for the drafting of your Part 102 exposition, compiling the application form, and identifying someone as the ‘Prime Person’. For BVLOS operations, a safety case will be a key part of gaining Part 102 approval.

Concept of Operations

The easiest way to prepare all the relevant information required for the submission and drafting of your Part 102 exposition and application forms is to develop a ConOps (Concept of Operations) that clearly outlines what you’re attempting to do, where you want to do it, what you’re attempting to do it with and how you plan on doing it safely.

 Prime Person

The ‘Prime Person’ holds responsibility for the exceptions issued by the CAA under Part 102. This person will need to gather identity and other documents including criminal conviction and traffic history reports to complete the fit and proper person application form. Additionally, they will be required to undertake an interview with the CAA to determine whether they have the knowledge and experience for the role. Undertaking a Part 102 training course through an approved training provider can assist, and should be organised during this phase to occur as close to the interview date as possible.

 Safety Case

While there are different methods that can be used to present the safety case to the CAA, the Specific Operations Risk Assessment (SORA) method is an internationally recognised process that qualitatively identifies the air and ground risk for your activity and assigns a Specific Assurance and Integrity Level (SAIL) rating which determines the organisational, equipment and safety structures that must be in place to ensure the operation will be conducted safely. As the degree of air and ground risk increases, the SAIL rating and related organisational, equipment and safety requirements also increase.

A full explanation of the SORA process can be seen here – Jackie Dujmovic | Nicola MacPhail presenting on SORA Process for BVLOS Drone Operations

The CAA has also provided an assessment evaluation tool to assist you in determining your proposed operations’ Specific Assurance and Integrity Level (SAIL).

Part 102 Exposition

In addition to the application forms, safety case, and fit and proper person questionnaire, the most important part of the application process is the submission of your Part 102 exposition. The Part 102 exposition is effectively your ‘how-to guide’. It defines the Part 101 rules you won’t be complying with and contains the procedures and policies, qualifications and training, unmanned aircraft, and safety management systems that you or your organisation will follow when conducting the specific drone operation.

It can be quite difficult to develop the appropriate policies and procedures to include in your exposition particularly if you don’t have experience with technical writing. This is why drone companies/operators will hire an exposition writer through a drone consultancy firm to write the exposition on their behalf. Good exposition writers will work with you to ensure that the exposition is written specifically to your organisational needs and requirements and, most importantly, that you understand it.

 Application Management

During this phase, the ‘Prime Person’ undertakes a fit and proper person assessment by the CAA. Additionally, the exposition and safety case is reviewed which typically involves two-way written and/or verbal feedback with the CAA to rectify any deficiencies or grey areas to ensure that safe operational procedures are developed. For more complex or novel drone applications a dedicated workshop may be required between the CAA and the applicant to work through the safety case and Exposition.

 Organisational requirements

Once your application is approved there will still be requirements that your organisation needs to conduct prior to commencing operations with your newly issued UAOC. This includes conducting any internal or external training to gain the necessary qualifications that are documented in your exposition. It’s also possible the unmanned aircraft will need to be inspected by a CAA-approved organisation to ensure that it is reliable and equipment failure is not likely to occur, particularly if your unmanned aircraft has been modified.

 Let’s go flying BVLOS in New Zealand

Once all this is done it’s time to get out there and safely fly your operation, putting all of your procedures into practice.

 We are here to help

Hover UAV is an RPAS Consultancy and Operations firm experienced in conducting SORA Safety cases and developing documented policies and procedures for BVLOS and complex drone operations on behalf of domestic and international clients. Most recently, Hover UAV assisted Pypervision in obtaining Part 102 certification for the conduct of BVLOS operations to enable fog dispersal operations.

Hover UAV has Part 102 packages for BVLOS and complex operations or if you don’t quite know what you need., we also conduct Discovery Workshops to assist you in developing your ConOps, and to determine your organisational and equipment requirements based on your intended operation.

If requiring information on BVLOS New Zealand please do not hesitate to contact the team today at 0800 992 753 for your free initial consultation.

As part of the recent burst of legislative activity, CASA have provided exemptions for remote pilots to obtain the necessary experience to upgrade their licences to:

a.     medium sized RPA and;

b.     a different category of small or medium RPA.

The release of CASA EX38/21 – Obtaining Experience for Grant of RePL for Medium RPA, and for RePL Upgrade to Different Category of Small or Medium RPA – Exemption Instrument 2021 allows a more practical pathway for remote pilot licence (RePL) holders to gain experience in operating other remotely piloted aircraft (RPA) in order to gain a licence upgrade for a different type of RPA or for a different category of RPA.

 Under Part 101 of the CASR, these upgrades could be achieved either through an approved training organisation or through a CASA flight test. Typically, for medium RPA, CASA flight testing is the most realistic option for certain RePL upgrades, but some of the can rules make it challenging for applicants to acquire enough operating experience with the relevant medium RPA to ensure that the flight test can be conducted safely.

Background

CASA must grant a RePL to an applicant if

·        the person has passed a relevant theory or knowledge examination (paragraph 101.295 (2) (a)), and

·        completed, a RePL training course (subparagraph 101.295 (2) (b) (i)) or a CASA flight test (subparagraph 101.295 (2) (b) (iii)), and

·        has at least 5 hours’ experience in operating an RPA under standard RPA operating conditions (paragraph 101.295 (2) (c)).

Standard RPA operating conditions (101.238) are designed to control the extent and scope of an RPA’s operation.

Owing to the limited numbers of approved training organisations that offer courses for medium RPA in particular, there are limited opportunities for a person to complete a training course as an alternative to completing a CASA flight test. Consequently, given the number of CASA offices across Australia, seeking a CASA flight test is often the most practical and preferred option. However, unless the applicant already has flying experience, a flight test may present some safety concerns, including to the CASA person conducting the flight test.

Under the licencing requirements, a person commits an offence if they operate an RPA and do not hold a relevant RePL. This requirement does not apply to the operation of an excluded RPA. That being said, a small RPA (with a gross weight of not more than 25 kg) is an excluded RPA if it is being operated in standard RPA operating conditions for the single purpose of gaining the required experience for a RePL. In this way, some opportunity to expand a remote pilot’s operating experience prior to attempting a flight test for a RePL for a small RPA is given.

However, this only applies for upgrades from a RePL for a very small RPA (gross weight of more than 250 g but not more than 2 kg) to a RePL for a small RPA, it does not apply to an upgrade from a RePL for a small RPA to a medium RPA (gross weight of more than 25 kg but not more than 150 kg). A medium RPA is not an excluded RPA –  preventing a person with a RePL for a small RPA from operating a medium RPA under standard RPA operating conditions to gain experience for a medium RPA flight test conducted by CASA.

The same problem crops up for remote pilots looking to upgrade to a different category of RPA. Although a small RPA is an excluded RPA if it is being operated in standard RPA operating conditions for the purpose of getting practical experience, this only applies to categories of RPA specified in the licence. The new category will obviously not be specified in the person’s RePL.

In addition, under the current regulations (101.270), a person commits an offence if they conduct operations using RPA without holding a certificate as an RPA operator (a ReOC holder) that authorises them to perform the operations. Again, the provision does not apply to excluded category RPA (small RPA, operated under standard conditions to gain experience) but the provision does apply to RePL upgrades to a medium RPA, or RePL upgrades to a different category of small or medium RPA.

The exemption instrument allows relevant operating experience for a type or category flight test to be obtained without committing an offence and without the need to be a ReOC holder.

The regulations do allow any RPA to be considered as an excluded RPA if it is being flown for the purpose receiving training from a ReOC holder authorised to conduct training in the relevant RPA. However, the ReOC holder’s Chief Remote Pilot must hold the applicable RePL rating for the relevant RPA (because of the competency requirements). Under the current rules, the only feasible way for this to occur is for the Chief Remote Pilot (CRP) to be assessed under a CASA flight test for the type or category of RPA, but the opportunity for the CRP to gain the flight experience required is still problematic.

The exemption instrument

A RePL holder for a small RPA who operates the same category of medium RPA is exempted from compliance with the experience part of the licencing requirement (requirements of sub regulation 101.252 (2)), but is subject to the condition that the RePL holder may operate the medium RPA only if all of the following requirements are met.

The operation must be:

a.     conducted under the standard RPA operating conditions;

b.     for the purpose of either (or both) of:

                           i.          meeting the experience requirement for the grant of a RePL for the same category of medium RPA (relevant RePL);

                          ii.          getting practical experience and gaining competency in the operation of the medium RPA for the grant of the relevant RePL;

c.      for the purposes of preparation to undertake a flight test conducted by CASA for the grant of the relevant RePL.

A RePL holder for a category of small or a medium RPA who operates a different category of small or medium RPA is also exempt from the experience part of the licencing requirement (requirements of sub regulation 101.252 (2)). The RePL holder may operate the different category of small or medium RPA but only if all of the following requirements are met.

The operation is:

a.     in a different category of small RPA or medium RPA that is of the same type of small RPA or medium RPA as is already included in the holder’s RePL;

b.     conducted under the standard RPA operating conditions

c.      for the purpose of either or both of the following:

                           i.          meeting the experience requirement for a RePL for a different category of small RPA or medium RPA (a RePL upgrade);

                          ii.          getting practical experience and gain competency in the operation of the small RPA or medium RPA for the RePL upgrade;

d.     for the purposes of preparation to undertake a flight test conducted by CASA a RePL upgrade.

The exemption also applies to ReOC holders for gaining experience for RePL upgrades to a medium RPA, or RePL upgrades to a different category of small or medium RPA.

The exemption instrument can be accessed from the Federal Register.

The checklist shows the documents required for a successful BVLOS application. Completing each of these documents and providing all relevant information may support a robust risk assessment. Please contact us to receive the PDF.