Mark Houston, Senior Technical Specialist Unmanned Aircraft
We are currently processing Part 102 certificate number 48 with about another 15 waiting in the wings.
Since August last year when the Rules were implemented, there has been considerable development of the operations of various types of RPAS.
The biggest user is the real estate industry and they have a special set of requirements to complete a job including operating close to aerodromes, in controlled airspace, and operating over persons and property.
We have had some issues and complaints but considering the level of activity and the number of machines operating, the comparative numbers are very interesting.
These issues continue to arise and the use of the concept of risk based regulation is managing to provide a safe environment.
However, we are now seeing that there exists a collective thought amongst a group of uncontrolled aerodromes to require a part 102 RPAS operator to be authorised to conduct operations within 4km of these aerodromes.
Recent discussions with Ardmore Aerodrome and North Shore Aerodrome have allowed an initial dialogue to begin such that issues and areas to improve could be raised as valuable safety tools for all.
Given the consideration that these are busy GA fields operating a wide variety of types at irregular intervals, but with published operational procedures and local variations, the inclusion of RPAS operations by 102 certificated operators is being viewed as a discretionary action.
This suggests that there still exists a lack of understanding of the RPAS Rules Part 101 and 102 and it is up to CAA and the RPAS Industry groups such as UAVNZ, as well as the aerodrome operators, to raise the level of understanding.
The Part 101 Rule is the mainstay of the operating rules for all RPAS, and 102 allows a variance (not an exemption) to the 101 rules where the operator can show that they have suitable qualifications, experience, knowledge and use a risk management system that is required for certification.
It is agreed that the level of training is adequate for most situations and that the variance to operate within 4km of an airfield is offered based on suitable pilot qualification – Part 61, Part 149, or Part 141.
With the mentioned development and increase in utilisation, it is timely that these requirements be reviewed to ensure that the RPAS operators are adequately prepared for operations at the mentioned fields, and other busy spots throughout the country.
These are uncontrolled airfields with one offering a UniCom service of flight advisory information provided by a commercial business.
The airspace is therefore available for all eligible aircraft operations including RPAS/UAV/Drones.
There has been a misconception by some experienced RPAS operators that by holding a Part 102 certificate they can operate wherever they like.
This is also an issue and has been addressed by personal contact and with strong consideration such that every new applicant is left in no doubt that the right course of action is to complete their risk assessment for each job and include contact with the aerodrome operator, prior to commencing operations.
This is not them seeking an authorisation but is good aviation practice and allows for the aerodrome operator to engage with and help educate the RPAS pilot, whereby any differences to the published procedures can be discussed, any local activities not published are discussed, and so that the RPAS operator can provide their site plan and contact details for broadcast as an advisory to traffic using these aerodromes.
This and other considerations will be addressed in any future amendment to AC101-1 and AC102-1. All recent Expositions, and any future applications, have included this provision into their operating and risk management criteria.
It is generally agreed that RPAS are still considered as toys by the general public and in a lot of cases by GA pilots.
The biggest threat we have, and this includes all international authorities, is the threat of an incident involving an airliner and an RPAS.
The recent Heathrow incident showed just how quick people are to assume that is was an RPAS when it has been basically dismissed as the item that possibly struck the A320.
There is no room for hysteria and bias, especially confirmation bias, in aviation safety even though they exist as part of the Human Factor equation.
The education of all sectors needs to address the fact that RPAS are aircraft and are here and likely to stay.
The sophistication of some of the machines coming to market is remarkable with the fitting of INU, multiple GPS, multiple redundancy systems, ballistic recovery parachutes, collision avoidance technology, and remarkable performance with a wide variety of payloads.
Development of our understanding and acceptance of them into the aviation system will continue to allow them make a valuable contribution to the NZ economy.
As always, we are open to reasonable and honest dialogue and discussion. We are also there for help and advice to ensure that this exciting and vibrant environment of RPAS continues to be a safe and exciting part of the New Zealand aviation system.