NZALPA’s Senior Technical Officer David Reynolds recently provided feedback for the remotely piloted aircraft system (RPAS) post-implementation review of parts 101* and 102** in the Civil Aviation Authority’s (CAA) survey.

The CAA said on its website: “Feedback will provide valuable insight into New Zealand’s RPAS sector, help the CAA determine whether these rules remain fit for purpose and will inform further policy analysis and next steps.”

After consultation with members and extensive research, Reynolds identified the current safety risks as:

• collision with manned aircraft and other RPAS
• distraction of manned aircraft pilots and air traffic controllers
• loss of control as a result of operator competence/awareness of RPAS capability
• loss of control as a result of failure/interference with C2 (command and control) links
• loss of control due to structural/system failure due to lack of airworthiness
• loss of control due to incapacitation due to medical impairment of the operator
• infringements into controlled/restricted airspace
• illicit carriage of and incidents involving the carriage of Dangerous Goods
• operator fatigue leading to lapses and incidents
• uncontrolled release of external loads
• disregard or lack of knowledge of RPAS rule parts and educational material by operators

Reynolds also provided details of the safety risks that will be posed by RPAS operations in the future as unquantifiable proliferation of the current risks. Other future risks were identified as:

• increasing pressure by the government and RPAS industry to disregard airworthiness standards and rules applicable to ‘conventionally manned’ aircraft to RPAS
• increasingly poor oversight due to a lack of CAA regulatory capacity and authority

NZALPA and Reynolds identified current process and risk mitigation practices, used by RPAS operators to ensure safe operations, as ineffective due to increasing reports of RPAS coming into close contact with manned aircraft and infringements for entering airspace in which they are not authorised to fly.

When asked about the existing knowledge of the RPAS operating rules and/or the effectiveness of promoting these rules to RPAS users, Reynolds said:

“In terms of actual operator knowledge this appears to vary widely. In the main, however, any knowledge is either not absorbed or ignored. There are currently no great incentives to neither acquire nor put into practice this knowledge

“In addition, as the numbers of operators/devices in use are unknown, nor their knowledge of operating rules tested, their effectiveness must be judged on their failure to apply/observe the rules in the form of incidents.”

In the survey, NZALPA noted that it would like to see the following points included in the rule framework for the RPAS sector:

• Each RPAS must have a responsible and fit person in command, trained, qualified and responsible for its operation at all times. They should ensure operations comply with the Rules of the Air and all air traffic control (ATC) instructions.
• Compulsory registration of owner/operators of RPAS greater than 250g. This is an important element in fostering adherence to the rules and encouraging the acquisition of necessary skills and qualifications. Devices registered to that individual.
• CAA/government to mount an extensive public awareness campaign about the safety risks, duties, liabilities and responsibilities associated with RPAS operations.
• CAA staffed, trained and equipped sufficiently to increase the effectiveness of enforcement.

Once the survey results have been compiled and assessed, a summary will be added to the CAA website, along with other updates. NZALPA will keep members informed of any updates in future editions of Uplink.

* Part 101 - Gyrogliders and Parasails, Unmanned Aircraft (including Balloons), Kites; and Rockets - Operating Rules; and

** Part 102 - Unmanned Aircraft Operator Certification.