Transitioning from Excluded Category to ReOC Drone Operations

In-house drone programs are quickly emerging as an indispensable tool across various large organisations and across industries.

However, before any in-house drone program can become functional, valuable and compliant - they need to make sure they adhere to the strict aviation guidelines for all types of operations.  

In Australia, the Civil Aviation Safety Authority (CASA) oversees the regulation of drone operations and allows commercial operations to be performed under one of two rulesets,

1. Excluded RPA or more commonly known as Excluded Category (Ex-Cat)
2. Included RPA or more commonly known as RPA Operator's Certificate (ReOC)

Understanding the nuances between these two categories is crucial for businesses seeking to start, scale and sustain their internal drone program. Let's delve into the specifics:

Ex-Cat Operations: Ex-Cat operations typically involve drones that weigh less than 2 kilograms (including payload), and are operated in compliance with CASA's standard operating conditions. Pilots only need to perform a short online exam to become an “Accredited Operator”. Caveats exist in the Ex-Cat rules to allow the use of larger drones,  but are limited to operating over one's own land, as well as requiring additional pilot licensing. Individual Accredited Operators are ultimately responsible for all stages of the operation.

ReOC Operations: ReOC operations, on the other hand, can involve drones up to 150kg operated in compliance within CASA’s standard operating conditions or outside the standard operating conditions with additional approvals. All operations are overseen by a Chief Remote Pilot (CRP). Individual Remote Pilots are required to have completed the Remote Pilots Licence (RePL) and be inducted into the organisation’s processes and procedures. Responsibility for safety and compliance is shared between the individual remote pilots and the organisation’s CRP.

Why we all start out with Ex-Cat:

Many organisations initially opt for Ex-Cat operations due to the simplicity and accessibility it offers. Starting with Ex-Cat allows organisations to explore the capabilities of small drones to validate their use case. It also allows operators to gain experience flying to determine if operating drones is a viable pathway before further investment in training.

However, the ease of starting with Ex-Cat comes with inherent limitations and risks. Ex-Cat operations are restricted in terms of the size and weight of drones, limiting their suitability for certain commercial applications. The practical implications are limited flight time and payload capacity. Additionally, It is not possible to gain approvals to operate outside of standard operating conditions (i.e. within 3nm of controlled aerodromes, operation at night, operations above 400ft etc.) under the Ex-Cat rules.

Moreover, operating solely under Ex-Cat rules may expose businesses to legal liabilities and insurance issues in the event of accidents or incidents during commercial operations, as the individual Accredited Operator is ultimately liable for safety and compliance. Insurers may not cover Ex-Cat operations as they are seen as higher risk compared to ReOC operations due to their historically higher incident rate (often as a result of operator inexperience).

Transitioning to ReOC Operations:

As businesses scale their drone operations, transitioning to ReOC operations becomes an imperative. Obtaining a ReOC enables companies to unlock a multitude of benefits,

• Ability to use larger drones with a wider range of capabilities.
• Ability to obtain approvals outside of standard operating conditions.
• Enhanced legal liability protections
• Enforced operational standards that increase overall quality and safety

To transition to ReOC, companies must complete several steps:

• Appointing a CEO/MD who will have overall responsibility and accountability
• Appointing a Chief Remote Pilot who will be responsible for all flight operations
• Appointing a Maintenance Controller who will responsible for all maintenance activities (CRP and MC are often the same individual)
• Developing a comprehensive set of operational procedures include risk management systems and maintenance management.
• The Chief Remote Pilot must undertake an interview / assessment by a CASA delegate or inspector

While this can sound intimidating, thousands of organisations have now gone through the process. This includes organisations ranging from one person through to very large organisations with 100’s of Remote Pilots. FlyFreely has developed a variety of resources to help organisations through this process, including our standardised Operations Manual templates as well as our ReOC Pathways Service.

Once a company obtains a ReOC, it gains the flexibility to undertake a diverse range of commercial activities. This can ultimately extend to Extended Visual Line of Sight (EVLOS) and Beyond Visual Line of Sight (BVLOS) operations once the appropriate approvals have been obtained.

Both of these operation types are quickly becoming a standard practice when operating across long distances or extensive linear assets (e.g. power transmission/distribution networks, oil and gas pipelines, large commercial estates, environmental protection zones, agricultural land, and more). 

Conclusion:

Transitioning from Ex-Cat to ReOC operations represents a strategic decision for businesses looking to elevate their drone program capabilities. By embracing ReOC operations, companies can mitigate risks, enhance operational efficiency, and position themselves to quickly take advantage of future technology changes.

Reach out to the FlyFreely team to learn more about our ReOC Pathways Service to help you transition to your own ReOC today.

If you are beginning to build your operations, transitioning to your ReOC certification or scaling your fleet and would like some help feel free to Reach out to our team for more information.