To add an RPA (Remotely Piloted Aircraft) to your drone business, provided it qualifies as a non-significant change, you can follow the steps outlined below, ensuring compliance with CASA regulations. Here’s a general guide:

1. Review Your Operations Manual

  • Check your Operations Manual to see if it already accommodates the type of RPA you want to add. If the addition does not alter your operational scope, capabilities, or safety procedures significantly, this may not constitute a “significant change.”
  • Examples of non-significant changes could include adding an RPA of similar type, class, or functionality to those already covered under your existing certification.

2. Document the New RPA

  • Ensure that the new RPA is documented properly in your internal records, detailing the:
    • Model and specifications.
    • Intended use (e.g., aerial photography, surveying, etc.).
    • Maintenance schedule and procedures.
    • Pilots and remote crew who will operate it.

3. Update Key Documents to include new RPA

  • Aircraft Register: Add the new RPA to your business’s register of operational aircraft.
  • Flight Logs: Ensure flight logs are ready to track the new RPA’s usage.
  • Maintenance Records: Establish a maintenance log specific to the new RPA, covering necessary checks and servicing.
  • Insurance: Verify that your insurance policy covers the new RPA. You may need to update or extend your policy accordingly.

4. CASA Notification (if required)

  • Even if it’s a non-significant change, CASA may still require notification of the addition of a new RPA. Some operations allow for self-assessment of non-significant changes, while others may still ask for an informal update.
  • Confirm with CASA whether they need any paperwork or forms completed, such as an RPA addition form or simply an update through the myCASA portal.

5. Pilot Training for new RPA

  • If the new RPA operates differently from your current fleet, ensure your pilots are trained and certified to operate it safely, even if this doesn’t result in a significant operational change.
  • Maintain up-to-date training records for all pilots using the new RPA.

6. Internal Risk Assessment

  • Conduct an internal risk assessment to evaluate whether the addition of this RPA introduces any new risks that might not have been addressed in your current operational procedures.
  • If the risks are already covered in your operations manual, no further action is needed. If new risks are identified but minor, update your internal safety procedures accordingly.

7. Communicate Internally

  • Inform your staff and pilots about the addition of the new RPA. Ensure everyone is aware of any minor adjustments to the operational protocols, particularly regarding the use and maintenance of the new RPA.

8. Keep Updated on CASA Regulations and about RPA

  • While this may not be a significant change now, CASA regulations can evolve. Regularly check for updates to ensure your business remains compliant in the future.

By following these steps, you can successfully add a new RPA to your drone business without making a significant change, avoiding the more stringent approval process that would apply in those cases. However, it’s always a good idea to consult with CASA directly to confirm your obligations before proceeding.

 

If adding an RPA to your drone business is outside the scope of your current ReOC (Remote Operator Certificate) and constitutes a significant change, you must follow a more formal process to obtain CASA’s approval. Here is the step-by-step procedure:

1. Assess the Significant Change

  • A significant change is any alteration that affects the nature and scope of your certification. This could include:
    • Adding an RPA that differs significantly in size, weight, or operational capabilities.
    • Using the RPA for new types of operations (e.g., moving from visual line of sight (VLOS) operations to beyond visual line of sight (BVLOS) operations).
    • Introducing a new payload or sensor that requires different procedures or certifications.
    • Expanding into a new area of operations that isn’t covered under your current ReOC.

2. Review Operations Manual

  • Review your existing Operations Manual and procedures to identify the specific areas where the new RPA or operational changes fall outside the scope of your current ReOC.
  • You will likely need to update your Operations Manual to reflect the new procedures, safety measures, and risk assessments associated with the new RPA.
  • This update can be done through Uncrewed Approvals. 

3. Prepare an Application for CASA Approval

To proceed with a significant change, you need CASA’s written approval. Follow these steps:

  • Use the Approved Form: Submit your application for approval of the significant change on the CASA-approved form.

    • Visit the CASA website to find the appropriate form under your ReOC, typically found in the myCASA portal.

  • Documentation: Your application must include:

    • An updated Operations Manual and/or Safety Management System (SMS).
    • Updated risk assessments to reflect the new operations or RPA type.
    • Details about the new RPA, including specifications, operational limits, and intended use cases.
    • Training plans for pilots and crew if the new RPA requires different skill sets or certifications.
    • Maintenance and safety procedures specific to the new RPA.
    • Insurance documentation that covers the new RPA and operations.

  • Justification: Explain why the addition is necessary and how the new RPA aligns with your business goals. Be clear about how the change still adheres to safety standards.

  • Compliance Check: Ensure that the new RPA and proposed operations meet CASA’s safety requirements and that the change remains consistent with your overall operational framework.

4. Wait for CASA’s Assessment

CASA will assess your application and determine whether the significant change:

  • Is consistent with the nature and scope of your existing certification.
  • Will not adversely affect aviation safety.

CASA can:

  • Approve the significant change with or without conditions.
  • Request further information or adjustments before granting approval.

Timelines: CASA aims to process significant changes within a set timeframe, but the actual processing time may vary depending on the complexity of the change and the completeness of your application.

5. Comply with CASA’s Conditions (if applicable)

  • If CASA approves the significant change but imposes specific conditions, ensure you fully comply with those conditions. These might include:
    • Enhanced safety measures.
    • Restrictions on specific operations.
    • Additional training for your remote pilots or staff.

6. Implement the Significant Change

Once CASA approves your application:

  • Update your documentation: Ensure all internal documentation, such as flight logs, maintenance records, and insurance policies, reflect the inclusion of the new RPA.
  • Train staff: Make sure that all remote pilots, crew members, and key personnel are trained to handle the new RPA and the new operational procedures.
  • Monitor operations: Conduct an internal review to ensure smooth integration of the new RPA into your operations and monitor for any safety or operational concerns.

7. Ongoing Compliance and Monitoring

  • After the significant change is implemented, continue to monitor the impact of the change on your operations. Make sure all operations remain compliant with your updated ReOC and CASA regulations.
  • Regularly review safety procedures and ensure that your business operations align with the new scope of certification.

Summary

Adding an RPA that constitutes a significant change involves submitting a detailed application to CASA, updating your operations manual and procedures, conducting thorough risk assessments, and possibly adhering to conditions set by CASA. It is a formal process that ensures your business can safely and effectively manage the expanded operational scope.

For more detailed guidance and access to the required forms, you can always visit CASA’s ReOC management section on their website or consult directly with CASA for any specific requirements related to your business expansion.

Significant change

The definition of what is considered a significant change depends on the Part. You can find a list of significant changes in the relevant legislation. While these changes are not the same across the different legislation, there are some common significant changes across legislation. These can include:

  • changes to operational locations
  • changes to organisational structure
  • other changes that do not maintain or improve, or are not likely to maintain or improve, aviation safety.

Approval of a significant change is chargeable under the Civil Aviation (Fees) Regulations 1995. You will receive an estimate of costs from us to assess these changes.

Use the following forms to apply for a significant change: