An Uncrewed Aircraft System Operating Permit (UASOP) enables the relevant Command/Group Head within Defence to authorise the operation of an Uncrewed Aircraft System (UAS) under the DASR UAS Specific Type A category.
The UASOP is a permit issued by DASA approving UAS operations that exceed the specified limitations and requirements of Open and Specific Type B category and cannot meet the requirements of certified category. The UASOP considers the full spectrum of risks associated with those operations and lists out the limitations and requirements to be met. DASA issues the permit to the relevant Command/Group Head on completion of a compliance assessment against relevant DASRs.
DASR UAS presents eligibility criteria for Defence UAS operating under the Specific Type A category. In order to support the full spectrum of Specific Type A UAS operations, the DASR UAS regulations include scalable hazard and administrative controls that DASA will require on a case-by-case basis, including:
the type of registration (whether on a local or Defence register)
whether a Statement of Operating Intent and Usage (SOIU) is required
initial and continuing airworthiness requirements
whether the operation must be conducted by a Military Air Operator (MAO)
the level of compliance required against the Standard Rules of the Air
Remote Pilot qualifications
UAS operating requirements and limitations.
DASA will issue a UASOP when satisfied that the applicant complies with DASR UAS requirements outlined in the Uncrewed Aircraft System Operator Compliance Statement (UOCS), DASR Form 152. For higher-risk UAS operations, the DASR UAS requirements are likely to be closer to that of crewed aircraft, whereas for lower-risk UAS operations (still within the Specific Type A category), requirements will be commensurately lower. The applicant may propose compliance requirements for DASA approval. However, DASA will ultimately determine the final set of requirements as outlined in paragraph 3.
DASA will issue the UASOP via DASR Form 153 – Uncrewed Aircraft System Operating Permit11. The UASOP will include:
the UAS type(s) that DASA authorised to operate and the registration requirements
the validity period of the UASOP
the approved operating areas and airspace
any requirements or limitations placed on the UAS
any management and support requirements, including any requirements to comply with DASR ARO.100, DASR ORO.10 and AMC UAS.30B (4)
detailed Initial and Continuing Airworthiness requirements, where necessary
An application for a UASOP is a multi-step process:
Firstly, the applicant notifies DASA of an upcoming UASOP application via a DASR Form 151.
Secondly, DASA develops a tailored list of DASR requirements that the applicant must comply with, documented in a DASR Form 152.
Thirdly, the applicant completes their bespoke DASR Form 152 with evidence and references.
Finally, DASA develops and approves a bespoke UASOP, via a DASR Form 153—and distributes this Form 153 to the applicant.
Submission of DASR Form 151 – Notification of Upcoming UASOP Submission is the initial step. This provides DASA sufficient information to determine if a UASOP is the most appropriate mechanism for the particular UAS operation and to begin the process of developing a bespoke set of DASR requirements for the applicant. Importantly, DASR Form 151 provides a means for the applicant to engage DASA and begin planning activities required to achieve the requirements of DASR UAS.
As per GM2 UAS.30.B, normal practice would be for the UASOP applicant to propose a suitable extent of compliance for DASA approval. The applicant may choose to propose tailoring to a DASR Form 152 – UAS Operator Compliance Statement (UOCS), for DASA to assess. Applicants should first await DASA confirmation from their submission of DASR Form 151 to ensure they address areas of concern prior to the development of a Form 152. The preferred approach is for DASA to tailor the DASR Form 152 (in consultation with the applicant).
Based on the information provided to DASA in the DASR Form 151, DASA may direct the following:
Defence Registration (DASR Part UAS.10.D) – DASA will determine whether Defence registration is required after considering internal policy decision criteria. These criteria may include22:
the ownership of the platform (such as whether the UAS will be owned by or operated on behalf of Defence)
the operational nature of the UAS (such as whether the UAS is considered expendable, what equipment is on-board, whether the UAS will be operated overseas)
the platform’s ongoing maintenance and continuing airworthiness program
Adding a UAS to the Defence Register invokes the requirement for an SOIU (IAW DASR ARO.50).
Complying with MAO requirements IAW DASR ARO.100 (DASR UAS.30.B.4. refers). As part of the DASR Form 152 development, DASA will direct the compliance requirements. Before operation of a UAS under Specific Type A, the MAO applicant must submit a Form 139a to update their Operations Specifications (OpSpec).
DASA will base initial approval or update of a UASOP on a program that may range from a desktop assessment of the submitted compliance demonstration evidence (detailed within the DASR Form 151 and contained within DASR Form 152), to iterative on-site assessments, oversight and other activities. DASA may conduct on-site visits prior to the approval of a UASOP as part of its education and assurance efforts.
Where an extant UASOP requires expansion or amendment (e.g. the removal of imposed limitations due to the applicant providing new compliance evidence), applicants must submit a DASR Form 154 – UOCS Request for Variation. DASA will assess the request, applying rigour proportionate to the change requested.
A UASOP will be withdrawn when either:
the applicant advises DASA that the operation of the UAS under the Specific Type A category is no longer applicable
DASA determines that the MAO Accountable Manager (AM), or Command/Group Head authorising the operation of a UAS can no longer ensure the operation in accordance with the conditions of the UASOP.
The MAO AM or Command/Group Head should address a minute to DG-DASA, including evidence to demonstrate that operators have been instructed to cease operations under the UASOP. DASA will provide a minute back to the relevant AM to confirm the UASOP has been withdrawn.
The MAO AM or Command/Group Head should advise whether the withdrawal of the UASOP impacts on any Defence registration requirements. The MAO AM or Command/Group must apply to DASA to remove a UAS from the Defence Register. Guidance on applying to remove a UAS from the Defence register is available at DASPMAN Volume 3 Chapter 6.1.1.
A Defence organisation bringing on a new UAS capability should engage DASA early in the acquisition life cycle to allow DASA to provide support and guidance to ensure acquisition and planning decisions are compatible with DASRs. While DASR UAS does not require UAS to operate within a fixed category from acquisition, the decisions made during acquisition may affect the operational flexibility afforded to the capability.
Prospective UAS operators are encouraged to engage DASA before making formal decisions on a new UAS capability to ensure giving consideration to likely future DASR requirements. DASA may educate the UAS organisation on the UASOP requirements and can appoint an internal contact.
The UASOP process, from initial contact to issue of the permit, can vary from six months to multiple years depending on the complexity of the operation. Early engagement with DASA generally correlates with a quicker UASOP turnaround.
Once approved, the UASOP details the responsibilities of a UASOP holder. The UASOP is only the permit providing Command/Group Head the ability to authorise operation of a Specific Type A UAS. Among other things, throughout the UASOP validity period, the UASOP holder is required to:
ensure key staff are appointed and competent
manage OIP changes, and where required, request a variation to the UASOP
ensure operation of the UAS is within the requirements and limitations as specified in the UASOP.
On approval of a UASOP, DASA may conduct ongoing compliance assurance activities to gain confidence that the UAS organisation is meeting the requirements of DASR UAS and the requirements and limitations included on the UASOP.
DASA UAS compliance assurance is nominally achieved through the following:
Oversight and on-site assurance. DASA may conduct on-site assurance activities for UAS organisations. Formal visits are usually part of oversight activities and may investigate compliance with DASRs, UASOP requirements and limitations, and internal OIP. DASA may also use oversight activities to validate the management of any prior findings and to conduct other oversight activities. DASA will tailor activities using a risk-based approach. UAS organisations may also request a DASA visit for educational purposes. DASA may provide incidental regulatory advice and education.
Initial approvals (including desktop assessments). DASA predominantly conducts desktop assessments of UAS organisations in considering UASOP approvals. The DASA UAS team conducting these assessments are usually from DAVNOPS, DIA and DCA, although DAVENG may provide specialist engineering assurance as required. DASA may also conduct desktop assessments in preparation for more complex on-site audits.