DASR UAS - Uncrewed Aircraft Systems

GM UAS.10 – Purpose statement and applicability (AUS)

Purpose: (Context) Defence UAS operations involve organisations with a range of organisational size and maturity; and varied UAS Configurations, Roles, and Environment (CRE). Consequently, Risk Management (RM) must scale according to the Aviation Safety hazards associated with specific organisations and CRE. Defence characterises air and ground Aviation Safety risks for UAS as distinct components of the overall risk landscape, which enables improved application of risk controls in the absence of Aircrew on board an Aircraft. (Hazard) Poorly scaled and implemented RM for Defence UAS operations could compromise Aviation Safety. (Defence) This regulation requires UAS Organisations to implement defined RM requirements, with distinct consideration of air and ground risk, so that Aviation Safety risks are eliminated So Far As is Reasonably Practicable (SFARP), and if not reasonably practicable to eliminate, minimised SFARP.

DASR UAS applicability

DASR UAS only applies to UAS operated by Defence:

as State Aircraft

up to, but not above 100km above mean sea level.

If a UAS is used for Defence purposes and regulated by a Civil Aviation Authority (CAA):

the requirements of DASR UAS.10(a) and DASR NDR apply

Services and Defence Groups may interpret AMC DASR NDR.05(a) references to ‘...or equivalent document’ to include the approval granted by the CAA for the UAS operation

UAS Organisations may not use the flexibility provision presented in GM DASR NDR.10(a) to operate the UAS outside the requirements and limitations (including operating areas) imposed by the CAA—unless the Sponsor:

applies to the relevant CAA for a dispensation to their regulations, or

temporarily operates the UAS under DASR UAS, (If exercising this option, the CAA regulations, requirements and limitations will cease to apply for that period), or

approves the use of Defence Airspace where the CAA has imposed a restriction on the use of Defence Airspace in a civil approval instrument (eg Defence controlled Restricted Areas).

DASR UAS.20, DASR UAS.30 and DASR UAS.40 do not apply.

DASR UAS non-applicability. DASR UAS regulations do not apply:

where a Service or Defence Group sponsors foreign military UAS operations in Australian sovereign Airspace—in these circumstances, DASR GR.27 applies

to Defence UAS operating indoors where the Uncrewed Aircraft (UA) is physically contained within the indoor operating area; however the Work Health and Safety Act 2011 remains applicable.

Applicability of other DASR. DASR UAS may be interpreted as a self-contained regulation. Therefore, other DASR only apply where prescribed within DASR UAS, or at DASA’s direction.

Other applicable authorities, regulations and policies. Authorities, regulations and policies, external to DASR UAS, may relate to the safety of UAS operations. While these other elements are not Aviation Safety requirements, UAS Organisations are responsible for identifying any additional requirements relevant to the acquisition and safe use of UAS. Examples include:

the Work Health and Safety Act 2011 and Work Health and Safety Regulations 2011

the CASA Office of Airspace Regulation (OAR) operating under the Airspace Act 2007
and Airspace Regulations 2019

the Defence Test and Evaluation Manual (DTEM)—as the Defence policy for T&E

the Defence Spectrum Office (DSO)—as the Defence authority for radio frequency spectrum allocation

the Defence Security Principles Framework (DSPF)—for hazards relating to cyber-security

the Directorate of Defence Radiation Safety and Assurance (DRSA) and the Defence Radiation Safety Manual (DRSM)—as the ADF authority for LASER safety

the Defence Training Area Management Manual (DTAMM)—applies to the management of Defence ranges and associated Airspace

the Explosives Safety Regulatory Framework (ESRF)—regulates hazards specific to explosive materials

carriage of Dangerous Goods or any other substance that could reasonably create a unique hazard

Autonomous Systems and Autonomous Weapons Systems Policy—guides Defence personnel in responsible development and use of autonomous systems technologies

Service-specific policy, where applicable.

Definitions. DASR UAS employs the following definitions in addition to the DASR Glossary and specific to characterisation of ground populations:

Table GM UAS.10–1: Definitions applicable only in DASR UAS

ICAO definitions. DASPMAN uses definitions from ICAO Doc 10019—Manual on RPAS where applicable in order to promote international harmonisation. Consequently, DASPMAN draws the definitions for UAS, UA, UAS Organisation, Remote Pilot, Remote Pilot Station, and segregated airspace from this reference, with minor adaptation to suit the military context where necessary. 

GM UAS.10(a) –  Service and Defence Group Authorisation (AUS)

Statutory accountabilities and responsibilities. Persons who authorise and operate UAS hold or execute statutory accountabilities or responsibilities to eliminate Aviation Safety risks So Far As is Reasonably Practicable (SFARP), and if it is not reasonably practicable to eliminate those risks, to minimise risks SFARP (this is referred to within the DASR UAS at times in the shortened form of ‘eliminate or otherwise minimise risks SFARP’). Compliance with DASR UAS will assist in executing this responsibility. However, Services and Defence Groups are responsible for implementing the most appropriate risk controls for meeting their statutory accountabilities or responsibilities to the persons potentially affected by the activity. Additionally, the relevant Service or Defence Group may need to implement further risk controls when authorising UAS operations by Remote Pilots who may be less familiar with the broader concepts of Flight operations safety management. While RPs are not explicitly included in this regulation, they have a statutory duty to take reasonable care that their acts or omissions do not adversely affect the health and safety of other persons.

Services and Defence Groups. Service Chiefs and Defence Group Heads are accountable for authorising all UAS operations within their respective environments (including Risk Management and retention). DASR UAS assumes that Service Chiefs and Group Heads will apply DASR UAS to their own environments through command and delegation instruments, with accountability ultimately residing with the Service Chief or Group Head. In this context, DASA expects that operating-level personnel will refer to Service or Defence Group policy provided by an informed Commander, Accountable Manager, or delegate with appropriate authorisations, to remain compliant with DASR UAS. Where there is no delegation from the Service Chief or Group Head, the Service Chief or Group Head is accountable for providing approvals to operate UAS.

The accountability for ensuring the safe operation of UAS rests with Service Chiefs or Groups Heads, irrespective of whether DASA issues a discrete authorisation.

Where DASA provides operating permissions through DASR UAS without the need for a discrete authorisation, Services or Defence Groups can use the DASA Approval To Operate UAS (ATOUAS) template to issue authorisations. 

GM UAS.10(b) – Operations compliant with DASR Certified, Specific or Open categories (AUS)

The category system provides operating freedoms to suit Service and Defence Group capability requirements and Risk Management (RM) requirements contextualised to those freedoms.

Certified category enables Services and Groups to operate a UAS over GP, MEP and Informed Personnel, and in all classes of Airspace for which the UAS is equipped.

Specific category Type A (DASR UAS.30(a)) enables Services or Groups to seek a discrete DASA approval for operations when the other categories do not provide the capability sought by a Service or Defence Group.

Specific category Type B (DASR UAS.30(b)) enables Services and Defence Groups to operate within predefined Standard Scenarios:

detailed in DASR UAS.35, with notification to DASA, only as an Approved UAS Organisation

detailed in DASR UAS.36, with notification to DASA, without a requirement to gain discrete DASA Approval.

Open category enables Services and Groups to operate UAS within the predefined limitations detailed in DASR UAS.40, without a notification to DASA, and without a requirement to gain discrete DASA approval.
 

GM UAS.10(b)1 – Occurrence Reporting (AUS)

GR.40 applies to Occurrence reporting for Approved Organisations. See also DASPMAN Volume 3, Chapter 10.9 for expanded guidance regarding Occurrence reporting for all UAS Organisations.

GM UAS.10(b)2ii – UAS Registration (AUS)

Registration assures transparency to Airspace management authorities where necessary, and provides traceability between a UAS and its operating unit. DASA may direct a Service or Defence Group to apply for Defence Registration when DASA identifies a benefit.

Where a Service or Defence Group elects to use more than one local register, they can meet compliance with the requirement through implementing a system of management that meets the intent for transparency and traceability.
 

GM UAS.10(c)1 – Determination of Experimentation-related Aviation Safety risks (AUS)

Experimentation. The Defence Test & Evaluation Manual (DTEM) defines what constitutes Experimentation and applies to Experimentation activities on UAS.

(Context) UAS Experimentation Flights are an essential input to capability, and in many cases, UAS Organisations can conduct Experimentation without exposing MEP, Informed Personnel or GP to hazards beyond routine operations. However, UAS Organisations may need to conduct Experimentation Flights with additional safety risks to MEP, Informed Personnel and GP. (Hazard) UAS Organisations could expose MEP, Informed Personnel or GP to unnecessary Experimentation-related hazards through a lack of appropriate organisation, personnel and process controls and a poor appreciation of the UA technical risk; and compromise Aviation Safety. (Defence) This regulation requires UAS Organisations to implement appropriate Risk Management to ensure that Aviation Safety risks to MEP, Informed Personnel, GP and Critical Infrastructure are eliminated So Far As is Reasonably Practicable (SFARP), and if not reasonably practicable to eliminate, minimised SFARP.

Where an Experimentation activity does not pose additional risks beyond the UAS Organisation’s normal operating risk profiles (ie does not impact extant risk management), they may conduct Experimentation under any of the DASR UAS.36 and UAS.35 Standard Scenarios.

Examples of when Experimentation may introduce additional risks to MEP, Informed Personnel, GP and Critical Infrastructure include:

dropping logistics items in proximity to personnel for the first time

operating a UAS from a ship’s flight deck for the first time, with personnel exposed to hazards (eg personnel on deck, or within launch and recovery hazard areas)

Flights of UAS where the UAS Organisation has not yet established reasonable confidence in the platform (eg first ever operation of a developmental UAS)

Flights of existing and proven UAS where modifications are made to Safety Critical systems and UAS Organisations cannot exclude personnel from ground risk areas.

Defence policy may apply, including:

The Defence Test & Evaluation Manual

Service or Group Experimentation policy

GM UAS.10(c)2 – Weaponised UAS (AUS)

Approval pathways. This regulation provides additional safety assurance for a weaponised UAS where the weapon hazards increase the platform’s inherent hazard to other Aircraft, persons on the ground and Critical Infrastructure. It provides a commander two options for weaponised UAS approvals. A commander may either pursue a DASA approval UASOP; or operate IAW a weaponised UAS Standard Scenario. The UASOP provides a greater degree of flexibility with a commensurately more rigorous assurance process. Whereas, the Standard Scenario enables Service or Defence Group self-approval without the need for a discrete DASA approval.

DASR UAS and Explosives Safety Regulatory Framework (ESRF)—applicability guidance

Under the DASR, any form of Explosive adapted, included, or attached to a Defence UAS for the purposes of applying a destructive effect to personnel and equipment, is ‘weaponised’. DASA applies DASR UAS to remotely or autonomously controlled airborne weapons only where it identifies a tangible Aviation Safety benefit. Therefore, DASA will assess each platform on a case-by-case basis and determine DASR UAS applicability for any UAS that adapts, includes, or attaches Explosives on any platform where the Explosives Safety Regulatory Framework (ESRF) or Land Range Safety applies. The ESRF regulates hazards specific to explosive materials, which do not include the hazards controlled by DASR UAS. DASR UAS provides regulatory controls for the hazards posed by a UAS to other Airspace users; and personnel and Critical Infrastructure on the ground. Hence, for weaponised UAS, the ESRF regulations and DASR UAS both apply.

The focus of Aviation Safety Risk Management for weaponised UAS is the destructive elements of the UAS that introduce hazards exceeding those of the platform itself. In the case of non-weaponised UAS, DASA only applies regulatory hazard controls that further reduce the overall risk of impact that endangers the Aviation Safety of other Airspace users, persons on the ground or water and Critical Infrastructure due to the kinetic energy imparted. The implementation of Aviation Safety hazard controls specific to the presence of Explosives may only need consideration where the weapon expands the hazard profile of the UAS (eg the weaponised component of a UAS increases the potential fatalities upon impact beyond the consequence inherent to the non-weaponised platform).

Smoke, flares, and methods of illumination (eg used for Search and Rescue purposes) are not weapons. However, these items are pyrotechnics and hence, are Explosives—the ESRF applies. The Service or Defence Group remains responsible for ensuring that anything dropped or discharged from a UAS is risk managed SFARP. This includes ensuring the adequate safe carriage of stores to prevent unintentional release and/or discharge of those stores and any unintended consequences.

GM UAS.10(c)2i – Certified or Specific Type A weaponised UAS approvals (AUS)

Applications for the weaponisation of a UAS should consider:

any undue hazard exposure to MEP, Informed Personnel and the GP

possible impacts to Airworthiness of the platform as a consequence of integration and subsequent weapon release and separation

hazards identified during system start-up, launch and recovery and Flight loads of the UAS-Weapon combination

accuracy, integrity, availability and continuity of service of the weapon system where there is an impact on Aviation Safety, including any latency of the command and control link

the likely safety risk associated with the application and intended mission of the UAS

safety requirements for the application of laser technology (eg any safety risks associated with laser technology applicable to the UAS requires additional assessment beyond weaponisation and Service or Defence Group authorisation to operate safely—normal Defence procedures for laser safety clearances apply as per the Defence Radiation Safety Manual).
 

GM UAS.10(c)3 – Carriage of persons (AUS)

DASA defines specific assurance requirements for the carriage of people on UAS on a case-by-case basis—albeit using crewed Aircraft DASR as a benchmark for most operations. However, DASA will consult with a Service or Defence Group to refine appropriate requirements where the carriage of personnel on a UAS is critical for mission risk (eg Search and Rescue or battlefield medical evacuation).

GM UAS.30(a) – UAS Operating Permit application (AUS)

This regulation identifies the accountable person for UAS operations.

This regulation assumes that the UAS Operating Permit (UASOP) applicant will be the UAS Organisation. DASA acknowledges UAS Organisations may have support in developing UASOP applications from a variety of organisations including CASG and other support agencies. UAS Organisations may delegate work to other organisations that supports the development of a UASOP application. However, the overall accountability for the UASOP application and its submission rests with the UAS Organisation. Once submitted, DASA will assess the application in order to assure the safety of UAS operations before issuing a UASOP.

DASA will issue a UASOP for the particular UAS and scope of UAS operations provided that risk controls proposed as part of the UASOP application eliminate or otherwise minimise risks SFARP. DASA will require the relevant UAS Organisation to demonstrate that:

it has documented the intended CRE for the UAS and provided it to DASA

if required, is an Approved UAS Organisation, or has otherwise applied to DASA to be an Approved UAS Organisation

if required, has submitted evidence to DASA of their Safety Management System

if required, has submitted evidence to DASA of their Initial and Continuing Airworthiness systems

it has submitted evidence to DASA of their Flying Management System, including:

an assessment of the risk of Deconfliction breakdown IAW the 7-step Risk Management process

an assessment of the risk of unintended descent IAW the 7-step Risk Management process

management of Remote Pilot (RP) qualifications, or other DASA approved system.

it has proposed any other requirements or limitations for inclusion in the UASOP in order to eliminate or otherwise minimise risks SFARP.

Risk controls will generally fall into one of three categories, as follows:

Technical risk controls. Technical risk controls relate to the application of rigour to the design, production and maintenance processes, such that a system’s likelihood of failure is known and controlled. This may include the application of standards, or inclusion of systems designed to support safe operation, such that the likelihood of failure is reduced.

Operational risk controls. Operational risk controls relate to the application of restrictions and limitations to the operation. This may include measures such as limiting operations to segregated airspace, over a safe area of designated ground or water, or restricting flight over the GP, to a limited set of weather conditions, or to specific roles.

Systemic risk controls. Systemic risk controls relate to the application of regulatory standards to organisations involved in the design, production, maintenance and operation of the system. Systemic mitigation is intended to reduce the occurrence of organisational and human errors which can contribute to the failure of a system.

A DASA issued UASOP will, as a minimum identify:

the UAS

the UAS Organisation

registration requirements for the UAS

compliance with an approved CRE document or Statement of Operating Intent and Usage (SOIU)

whether the UAS Organisation needs to be an Approved UAS Organisation

the implementation of a SMS contextualised for the UAS CRE, if necessary

the implementation of a tailored Initial Airworthiness and Continuing Airworthiness system contextualised for the UAS CRE, if necessary

compliance with an FMS

key risk controls that must be employed to minimise the risk of Deconfliction breakdown during UAS operations

key risk controls that must be employed to minimise the risk of unintended descent during UAS operations

the RP qualifications, or a DASA approved system, that can control the UA

Occurrences that must be reported

and direct any other restrictions and limitations as necessary.

GM UAS.30(a)2i – UAS CRE (AUS)

This regulation assures that UAS Organisations define a CRE sufficient to inform decisions about whether a UAS is, and remains, safe for operations approved under a UASOP. The defined CRE establishes context for risk management, sets a baseline to control UASOP operations, and helps identify changes that require update and reassessment of Risk Management approaches.

DASA recommends the CRE document is best suited for enduring operations under a Standard Scenario, or for simple UASOP applications. An SOIU is more appropriate for complex UASOP applications or when the relevant stakeholders consider DASA endorsement is necessary.

The difference between a DASA CRE Document and a UAS SOIU lies mainly in the number of stakeholders that need to be consulted, and the required approval level for each document:

CRE Documents do not usually require extensive stakeholder consultation and can be approved by the Service or Defence Group Head (or delegate). DASA endorsement of the CRE document is not required.

SOIUs require more significant stakeholder consultation, including with DASA. While still required to be approved by a Commander or Group Head (or delegate), the SOIU may warrant a higher-level delegate approval (compared with the expectation for crewed aircraft SOIUs in AMC ARO.50(a)). This aligns with the increased inherent hazards of the UAS operation, necessitating increased stakeholder consultation (due potentially to the shared nature of the risk, refer to WHS Act Section 46) to minimise the risk of the UAS operation.

GM UAS.30(a)2ii – UAS Organisation requirements (AUS)

This regulation assures that UAS Organisations have the necessary maturity, experience, and systems in place to carry out the proposed UAS operations. The mechanism employed by DASA to assure this is to reserve higher risk and complex UAS operations only to Approved UAS Organisations.

Some UASOPs may not require operations as an Approved UAS Organisation. However, note that some Specific category Type B Standard Scenarios are reserved for Approved UAS Organisations only (refer to DASR UAS.30(b)).

Applying for Approved UAS Organisation status is not likely to prove burdensome for applicants, given most UAS Organisations will progress through the Specific category Type B Standard Scenarios before requesting a UASOP from DASA. Of note, MAOs are Approved UAS Organisations where the OpSpec details permission to operate the relevant category of UAS.
 

GM UAS.30(a)2iii – SMS (AUS)

DASA may not require implementation of an SMS for all UASOPs. However, in the context that UASOPs facilitate operations beyond Specific category Type B and Open category, those situations are the exception. Note that even the Specific category Type B Standard Scenarios require a range of SMS implementation.

UASOP applicants should consider the sliding scale of requirements implemented for the following categories:

Open category, as the category with the lowest inherent hazards, does not explicitly require an SMS. However, it does provide some embedded elements of SMS.

The Specific category Type B Standard Scenarios for all UAS Organisations (DASR UAS.36) provide tailored SMS requirements due to increased inherent operating hazards beyond those in Open category.

The Specific category Type B Standard Scenarios for Approved UAS Organisations only (DASR UAS.35) and Certified category, require an SMS compliant with DASR SMS due to further increased inherent operating hazards.
 

GM UAS.30(a)2iv – Initial Airworthiness and Continuing Airworthiness (AUS)

This regulation assures that UAS Organisations apply a suitable Initial Airworthiness and Continuing Airworthiness system to support any systemic and technical risk controls proposed as part of an operation, to ensure the integrity of the risk controls through the operational life of the UAS.

Initial Airworthiness and Continuing Airworthiness requirements are not necessarily relevant to all UASOPs. Examples where DASA may not impose those requirements could include operations that only involve a limited number of flights, operations with only a fleeting exposure to people and Critical Infrastructure, and low weight and speed UA that are unlikely to cause injury upon impact.

DASA will only impose Initial Airworthiness and Continuing Airworthiness requirements on UAS where they make a tangible contribution to the safety of other airspace users, or people and Critical Infrastructure on the ground or water. This is generally the case where a larger UAS, typically one that exceeds the weight limitations of Open category, is expected to operate in close proximity to people and Critical Infrastructure on the ground, and other Airspace users. UAS Organisations should implement measures, where practicable, to reduce the likelihood and consequence of critical component failure (eg positioning equipment when relied upon for separation from crewed Aircraft ADS-B Out, independent Flight Termination Systems, etc.). This could also include increased rigour in engineering and maintenance support, and reporting of issues encountered.

Ultimately, DASA’s decision on Initial Airworthiness and Continuing Airworthiness requirements within a UASOP will be based on whether the UAS operation is relying on any key systemic or technical risk controls, and whether those risk controls require a suitable Initial Airworthiness and Continuing Airworthiness system to ensure their proper function.

The direct application of Airworthiness DASRs (i.e. DASR 21, M, 145, 66, and 147) to UAS outside of the Certified category is usually not practicable. Each of these regulations inherently assume the UAS will have a standards-based design, a Military Type Certificate, and subsequent Certificates of Airworthiness for each UA, which is generally not the case with UAS outside of the Certified category. Instead, where necessary, DASA will generally pursue an alternative approach by identifying the underlying ‘safety intent’ that the Airworthiness DASRs aim to achieve, and prescribing these principles as broad outcome-based requirements to be achieved. The UAS Organisation may therefore have latitude in how to meet these requirements.

A UAS Organisation is likely to have the most comprehensive understanding of their proposed CRE and available risk controls. Therefore, the onus is on the UAS Organisation to propose, if necessary, Initial Airworthiness and Continuing Airworthiness requirements to DASA for agreement and inclusion in the approved UASOP. Additional Initial Airworthiness and Continuing Airworthiness guidance is available in UAS.30(b).
 

GM UAS.30(a)2v – FMS (AUS)

This regulation assures that UAS Organisations implement a suitable Flying Management System (FMS) for their proposed UAS operations.

Applicants should consider the following range of FMS within DASR UAS, and the possible application to their own CRE, when determining UASOP application proposals:

Open category does not require a formal FMS to manage the constrained inherent operating hazards in this category. However, note that DASR UAS.10(a) and DASR UAS.10(b) do mandate basic management requirements.

Specific category Type B category provides permissions for increased inherent operating hazards. Therefore, UAS Organisations operating Specific category Type B UAS must implement a basic Flying Management System IAW DASR UAS.30(b)3.

Certified category, as the category that most closely resembles the hazards inherent with crewed Aircraft operations, requires full compliance with DASR ORO.10.

In reality, the requirement for an FMS will not prove burdensome to applicants, as most UAS Organisations would have already progressed through the Specific category Type B Standard Scenarios before requesting a UASOP from DASA.
 

GM UAS.30(a)2vi – Risk controls for Deconfliction breakdown (AUS)

Deconfliction breakdown refers to the point where the safety margins between the UA and other Airspace users begin to reduce and compromise Aviation Safety.

DASR UAS addresses the risks associated with integrating Specific and Open Categories into existing Airspace (both controlled and non-controlled) primarily due to:

equipage shortfalls

inability to comply with the Air Traffic Control instructions (eg meet standard rates of climb)

the inability to comply with rules of the air (eg the absence of capability to ‘see and avoid’ other aircraft).

Where UAS segregation from other Aircraft is not a practicable option for UAS Organisations, operations in a variety of Airspace may be conducted under a UASOP if the UAS Organisation demonstrates to DASA that they eliminate or otherwise minimise risks SFARP to other airspace users.

A UAS Organisation eliminates or otherwise minimises risks SFARP to Airspace users through risk controls specifically targeted to the risk of Deconfliction breakdown. Note that risk controls proposed may result in secondary considerations, for example Initial Airworthiness and Continuing Airworthiness requirements for technical risk controls such as ADS-B Out.

The Airspace integration management and due regard prescription in DASR UAS.30(b) may provide UAS Organisations with a useful basis for applications under Specific category Type A.
 

GM UAS.30(a)2vii – Risk controls for unintended descent (AUS)

This regulation assures that UAS Organisations implement suitable risk controls to eliminate or otherwise minimise risks SFARP of an unintended departure from a Flight path that leads to compromised safety of people and Critical Infrastructure on the ground. DASA refers to this as ‘unintended descent’, and is the point where control of the UA is lost and safety margins for people on the ground and Critical Infrastructure begin to diminish. Unintended descent also includes controlled flight into terrain.

Operations near or over people and Critical Infrastructure can be conducted under a UASOP if a UAS Organisation demonstrates to DASA that they eliminate or otherwise minimise risks SFARP to people and Critical Infrastructure.

UAS Organisations achieve risk minimisation through implementing risk controls specifically aimed at addressing the risk of unintended descent. Note that proposed risk controls may result in secondary considerations, for example Initial Airworthiness and Continuing Airworthiness requirements for technical risk controls such as independent flight termination systems.
 

GM UAS.30(a)2viii – RP qualification and DASA approved systems (AUS)

This regulation assures that:

UAS Organisations define suitable qualification requirements for their RPs and implement systems to ensure only qualified RPs control UA.

only DASA approved systems control a UA where no RP ability to intervene is proposed.

When proposing a new or updated UASOP to DASA, the UAS Organisation should define:

the required RP qualification and training requirements, given the expected UAS CRE

any requirement for the RP to maintain a specified medical standard in accordance with DASR.MED.10

any requirement for the RP to maintain Currency and Recency.

Applicants should consider the range of requirements for the following categories when determining a UASOP proposal:

Open category provides RP qualifications contextualised for the most limited UAS operations hazard profile in DASR UAS.

Specific category Type B category provides more prescriptive RP qualification requirements contextualised to increased inherent operating hazards.

Certified category provides the most stringent RP qualification requirements due to operating permissions equivalent to crewed Aircraft.

DASA approved system. The provision for a DASA approved system is to account for the spectrum of possibilities presented by Autonomous Aircraft, increasing levels of autonomous functionality in UAS, and associated with Artificial Intelligence technologies.

If proposing to DASA a system to control a UA, the UAS Organisation should:

define the level of control the system will have over the UA

identify the functions, failure conditions, and failure modes that are impacted by the removal (partial or complete) of the RP

analyses the relevant functions, failure conditions, and failure modes that are impacted by the removal (partial or complete) of the RP

justify to DASA why the Risk Management approach for the proposed system is appropriate.

GM UAS.30(b) – Purpose statement (AUS)

Purpose. (Context) Standard Scenarios facilitate a range of Defence UAS operations without the need for a bespoke DASA approval for every usage, by providing defined hazard controls. (Hazard) Inadequate risk controls for UAS Organisations may compromise Aviation Safety and lead to a breach of Defence’s WHS obligations. (Defence) This regulation requires a UAS Organisation to implement organisation risk controls to eliminate Aviation Safety risks SFARP, or if it is not reasonably practicable to eliminate those risks, to otherwise minimise Aviation Safety risks SFARP.

GM UAS.30(b)1i – UAS.35 Standard Scenario applicability (AUS)

DASA provides the DASR UAS.35 Standard Scenarios exclusively to DASA Approved UAS Organisations, to assure hazard controls associated with increased permissions in these Standard Scenarios. A DASA Approval assures that Approved UAS Organisations implement appropriate Initial Airworthiness (IA) and Continuing Airworthiness (CA), Flying Management Systems (FMS), and Safety Management Systems (SMS) to ensure Aviation Safety.

MAOs are Approved UAS Organisations where the OpSpec details permission to operate Certified, Specific Type A, and Specific Type B UAS.

Other organisations can apply to DASA for organisational approval provided they can demonstrate that they have implemented effective IA, CA, FMS, and SMS requirements.

GM UAS.30(b)1ii – UAS.36 Standard Scenarios (AUS)

The UAS.36 Standard Scenarios provide all UAS Organisations with predefined permissions and limitations without a requirement for a DASA approval.

GM UAS.30(b)2 – Initial Airworthiness and Continuing Airworthiness (AUS)

Initial Airworthiness, in the context of Standard Scenarios, is to assure that UAS Organisations implement suitable arrangements to identify and remedy deficiencies in the UAS design, where reasonably practicable. The design system safety and reliability requirements drawn from initial and continued airworthiness principles, can then be applied where they make a tangible contribution to safety in the context of operations under the Standard Scenarios.

Continuing Airworthiness, in the context of Standard Scenarios, is to assure that UAS Organisations implement suitable and ongoing arrangements to maintain the UAS in a condition for safe operation.

GM UAS.30(b)2i – Technical risk controls (AUS)

UAS Organisations should consider implementing all reasonably practicable technical risk controls, including:

appropriate automatic Flight actions upon Command and Control Lost Link agreed with the relevant authority or Air Traffic Control agency (eg autonomous recovery systems, or independent Flight termination (when it is safe to terminate independently))

limiting the Uncrewed Aircraft over the operational area and the Airspace designated for the activity (eg geo-fencing, programmable maximum and minimum altitude)

the capability for the Remote Pilot to monitor:

 Command and Control link performance through the control interface

externally provided services that affect flight critical systems and voice communication systems (eg mobile or satellite networks)

prior testing of functionality to enable manual termination of Flight by the RP

considerations for the safe recovery from human error (eg, functional tests, mechanical interlocks/safety pins, use of acknowledgment features, fuel or energy consumption monitoring functions).

Where the UAS Organisation identifies risk controls that are not reasonably practicable to implement, they remain responsible for the safety and reliability of the UAS and for ensuring appropriate Risk Management for unsafe design conditions.

GM UAS.30(b)2ii – UAS configuration management (AUS)

The UAS Organisation should consider establishing a system to manage the configuration of the UAS design, including authorised design changes and repairs cognisant of the UAS CRE, including through a technical log.

GM UAS.30(b)3 – FMS (AUS)

This requirement assures that UAS Organisations implement an adequate Flight operations framework of authority and requirements, appropriately contextualised to the UAS CRE. GM UAS.30(a)2v contains additional guidance that contextualises UAS.30(b) UAS Organisation requirements.

GM UAS.30(b)3i – CRE (AUS)

A CRE informs decisions about whether an Aircraft design remains safe for operations in the defined roles and environments. It establishes the context for Risk Management, and sets a baseline to control activities and assist Services and Groups in identifying changes that require update and reassessment of Risk Management.

Significant changes to the CRE should result in an update to the UAS CRE document or SOIU and re-submission of an updated DASR Form 150 referencing the updated document.

A CRE document should include the extent to which the UA is required to operate near or over people and Critical Infrastructure including the duration of exposure and expected population density, amplifying:

population distributions of Mission Essential Personnel, Informed Personnel and General Public exposed to UA hazards

Airspace environments in which the UA may operate, including the extent of shared Airspace usage

the extent to which the UA is required to operate in the proximity of Aerodromes and vessels

the extent to which the UA is required to operate near Critical Infrastructure.

GM UAS.30(b)3ii.b – SMS implementation (AUS)

UAS Organisations conducting operations IAW UAS.36 should consider implementing an SMS with:

defined policy and objectives, including:

a statement of management commitment to safety

safety accountabilities and responsibilities

coordination of emergency response planning

SMS documentation.

Aviation Safety Risk Management artefacts documenting:

hazard identification processes

safety risk assessment and mitigation.

safety assurance using artefacts to document:

safety performance monitoring and measurement, including monitoring and investigation of Occurrences, and implement changes to OIP where necessary

the management of change

continuous improvement of the SMS, including routine auditing to confirm compliance with DASR UAS.

safety promotion using artefacts to document:

training and education

safety communication (eg notices, bulletins, briefings, posters).

GM UAS.30(b)3iii – Key Staff (AUS)

Key Staff are personnel appointed by a UAS Organisation to ensure the appropriate assignment of accountabilities for Aviation Safety. Some low-complexity operations may not justify assigning individual personnel against all positions; in those cases, the UAS Organisation may combine accountabilities into one or more personnel.

UAS Organisation Key Staff requirements should generally include:

defined initial and continuing position eligibility requirements

defined authority delegations and limitations

roles for managing, as a minimum:

the Safety Management System

IA and CA, where relevant

Flying operations standardisation

Flying Supervision

Flying instruction, when the organisation conducts training.

The following describe Key Staff and their general functions:

Aviation Safety Officer. An Aviation Safety Officer is responsible for the management and maintenance of UAS Aviation Safety within the operating organisation. Such duties might include:

identifying, reporting and tracking of hazards; and implementation of hazards controls

the conduct of Aviation Safety training for members of the UAS Organisation

ensuring crew duty limits are enforced

incident investigation

correction of identified deficiencies.

IA and CA management. Personnel managing IA and CA are responsible for implementing and monitoring appropriate IA and CA risk controls commensurate to the inherent technical hazards of a given UAS. The extent of technical risk controls will vary significantly depending on the operational context. Therefore, the level of qualifications, training and experience required for managing IA and CA is set accordingly.

Standardisation Officers (STANDO). A STANDO is responsible to the Accountable Manager (eg operating unit CO) for monitoring and reporting on operational staff compliance with OIP, and providing guidance for standardisation of UAS Organisation operations.

Flight Authorisation Officers (FLTAUTHO). FLTAUTHOs are personnel of any appropriate rank or position appointed to provide Flight Authorisation of all UAS operations conducted by the UAS Organisation.

UAS instructors. A UAS instructor is an RP authorised by the UAS Organisation as competent to provide UAS flying instruction and assessments. The UAS instructor is responsible for providing instruction and assessment to unit personnel IAW the relevant Learning Management Package and OIP. UAS Instructors may also be OEM authorised personnel responsible for initial training on the relevant UAS.

GM UAS.30(b)3iv – Flying Supervision and Flight Authorisation (AUS)

For UAS operations with increased complexity, UAS Organisations should consider, based on the UAS CRE, whether to qualify FLTAUTHOs through either a Service-endorsed Flying Supervisors course or unit-level training. Unit-level training should usually cover:

Non-Technical Skills and fatigue management

the Defence Aviation Safety Program and Regulations

Aviation Safety Hazards

contemporary risk management

study of Occurrence Reporting, and accident and incident reports from other global operators, of relevant UAS types

FLTAUTHO roles and responsibilities

supervision of Crew.

Flight Authorisation should:

provide unambiguous instructions and guidance to allow the Aircraft Captain to make well-balanced decisions, while avoiding unnecessary interference with the Aircraft Captain’s legitimate decision-making responsibilities

ensure operations occur IAW:

the Standard Scenario requirements

the organisation’s approved OIP for:

CRE or SOIU

Airspace management and Deconfliction

planning requirements for safe distances from people on the ground and Critical Infrastructure

Continuing Airworthiness requirements and limitations when relevant

operation of the UAS

mission planning

crewing requirements (eg qualifications, experience, medical fitness)

Risk Management.

ensure FLTAUTH records:

include:

date, time and expected duration

UAS type and serial number

callsign (if used)

UAS Crew composition (eg Aircraft Captain, Remote Crew, Mission Crew)

planned mission details

any specific limitations that apply to Flights

identifiable acknowledgements by the FLTAUTHO and the Aircraft Captain

be retained as a permanent record and archived when the UAS Organisation no longer requires those records (eg IAW Commonwealth records management policy issued under the Archives Act 1983).

GM UAS.30(b)3v – UAS Crew qualification, training, experience and medical standards (AUS)

UAS Organisations should implement UAS Crew qualification systems

commensurate with:

the UAS operated by the UAS Organisation

the role and operating environment (eg Visual Line of Sight vs Beyond Visual Line of Sight operations, Visual Meteorological Conditions vs reduced visibility, day vs night operations, operations with Participating Aircraft).

including additional qualifications for UAS Crews where relevant to a Standard Scenario (eg for Test & Evaluation, BVLOS, night operations, competent spotters)

for instructor qualifications where relevant (including STD management), and requirements for routine competency assessments

UAS Crew Currency and Recency requirements should usually include:

a method of recording UAS Crew competency, experience and recency (eg logbooks and electronic Currency/Recency tracking)

methods to regain Currency and Recency

circumstances for appropriate extensions or waivers to Currency and Recency.

Remote Crew (and Mission Crew where relevant) medical fitness requirements should usually include:

a medical fitness system that defines:

minimum medical standards required to operate the UAS (eg aligned to Service requirements)

drug (including prescription and non-prescription medication) and alcohol use (eg limitations, notification requirements, mandatory no-fly requirements)

fatigue management (eg duty day, continuous rest between duty days, maximum accumulative Flight times per day)

self-assessment of medical fitness prior to, and during Flight operations

return to flying following Temporary Medically Unfit for Flying, where relevant.

training that enables the UAS Crew to understand the Aviation Safety risks associated with medical fitness in order to conduct an appropriate self-assessment.

GM UAS.30(b)3vi – Operating standards and limitations (AUS)

DASA provides the Approval to Operate UAS template (analogous to an operations manual) to capture operating standards and limitations for UAS Organisations. UAS Organisations using the template should retain the structure as far as practicable for the Aviation Safety benefit to standardisation across Defence UAS operations. However, UAS Organisations need only provide detail to the extent that it supports Aviation Safety.

Approved UA limitations should include:

performance limitations (eg operations ceiling, maximum commanded airspeed)

datalink limitations (eg range, antennae elevation limitations)

environmental limitations of the UA (eg Radio Frequency (RF) conditions, weather and dust limits)

technical risk controls limitations (eg autonomous recovery system, geo-fencing, altitude and range limiter and on-board cameras)

any other design feature that may contribute to Aviation Safety.

Pre-Flight checks (including independent verification of Safety Critical data) should confirm the configuration and serviceability of:

the UA airframe, control surfaces and propellers/rotor blades

the UA navigation system

technical risk controls (eg autonomous recovery systems, geo-fencing, altitude and range limiter and on-board camera)

payloads, including payload mounting and release mechanisms

other systems that contribute to Aviation Safety.

Flight planning procedures should include:

minimum safe lateral and vertical distances from GP, Informed Personnel, MEP and Critical Infrastructure (where potential exposure exists)

launch and recovery, and route/area planning to ensure avoidance of obstacles, people and Critical Infrastructure (eg required performance and minimum altitudes for launch, recovery and in-Flight)

minimum fuel or battery states for planned routes, and reserves

UAS hardware and software configuration, and minimum performance (eg standard configurations, weight and balance requirements, allowable module or payload combinations, minimum engine performance and power margins)

Lost Link procedures that ensure safe routing and altitudes, compliant with specific Standard Scenario requirements, and accepted by the relevant authority or Air Traffic Control agency

Role Equipment, dropping of items, use of lasers and any other hazard-sources that may project hazards beyond the UAS, where relevant

minimum UAS Crewing (eg minimum qualifications for specific missions, Mission Crew)

minimum quick reference documentation for the Remote Pilot Station(RPS)

RF spectrum approvals and ongoing usage, including any environmental limitations, where relevant

requirements for the use of externally provided services, where relevant (eg mobile telephone or satellite networks).

Contingency and in-Flight emergency procedures should be implemented and tested, and include:

Flight termination (including criteria and Flight termination sites)

management of Airspace or ground incursions (eg non-compliant Airspace users, or GP)

UA escape from the operational area/assigned Airspace (eg alerting GP, MEP, other airspace users and ATC)

malfunction of technical risk controls

loss of positive control

unintended UA ground impact

hung or inadvertently released stores

management of battery or fuel hazards

management of Dangerous Goods cargo.

UAS Organisations should implement procedures, limitations and requirements:

for Extended Visual Line of Sight, Beyond Visual Line of Sight, reduced visibility, night and Instrument Meteorological Conditions (IMC) operations, where the UAS Organisation conducts operations under these conditions

that enable the RP to operate the UAS within its weather limitations (eg obtaining weather forecasts and monitoring weather radars)

for managing the Remote Pilot Station (RPS) environment, where relevant (eg sterile cockpit)

for handover procedures that enable the RP and/or crew to perform a handover to another RP and/or crew, where relevant (eg checklists, crew coordination and monitoring during handover)

for avoidance of spectrum conflict and electromagnetic interference (eg coordinating with the Defence Spectrum Office and conducting a survey for high intensity emitters)

where relevant, multi-crew operations, including:

standard RPS duty allocations

standardised phraseology for critical phases of flight.

to manage human-machine-interface (HMI) deficiencies, where relevant

UAS Organisations should implement in-Flight monitoring of:

command, control and communication data-links performance to ensure safe conduct of Flight

cyber risks that may affect Aviation Safety

RF spectrum that eliminates or otherwise minimises SFARP, interference to a UAS.

UAS Organisations should define requirements for Flight recording and locating equipment (where practicable) to ensure retention of altitude, speed and track data until the UA is recovered without incident.

GM UAS.30(b)3vi.a – Due regard and Airspace integration (AUS)

Defence has an obligation under international law (Chicago Convention Article 3d refers), ‘when issuing regulations for their state aircraft…'to'…have due regard for the safety of navigation of civil aircraft’. For the purposes of the Standard Scenarios, Defence applies ‘due regard’ to include operations which do not comply fully with IFR, nor VFR and in which the Aircraft Captain assumes responsibility for Deconflicting with civilian air traffic.

Due regard operations for UAS involve implementing risk controls to ensure the safety of civilian Aircraft. UAS Organisations must not conduct due regard operations such that the primary control against the hazard of a collision is the ‘see and avoid’ capability of a third party. Similarly, reliance on operating in historically low density Airspace, either solely or in conjunction with relying on the see and avoid capability of a third party, does not satisfy the requirements for due regard operations.

The options provided in AMC UAS.30(b)3vi.a for territorial and non-territorial areas refer to the United Nations Convention on the Law of the Sea (UNCLOS) definition of territorial and non-territorial seas.

ANP 3300 defines RAN policy for Defence UAS operations in vicinity of Australian and foreign warships, including definition of approach and departure paths for air-capable ships.

Figure GM UAS.30(b)3vi.a‒1 depicts the straight-in approach and departure paths at non-controlled Aerodromes.
 

Figure GM UAS.30(b)3vi.a‒1: Approach and departure paths at a non-controlled Aerodrome

Where a UAS Organisation is using Lowest Safe Altitude (LSALT) by night as the ceiling for an operation, those operations are subject to the requirements of the RAAF AIS General Planning Australia for calculation of the appropriate LSALT.

Approval authorities for specific Airspace. A range of authorities control the various types of Airspace volumes, listed in En Route Supplement Australia (ERSA) and the Designated Airspace Handbook (DAH) and as listed below. UAS operations may only occur within the following Airspace where the relevant authority first provides permission for:

Flights within the no-fly zone of a controlled Aerodrome, which is (see also figure GM UAS.30(b)3vi.a−2):

within 3 nm, in any direction, from the runway threshold of any runway of a controlled aerodrome

within the areas shaded dark grey less than 7 km from the runway threshold, and above 300 ft AGL beyond 7 km from the runway threshold

for UAS <250 g Take-Off-Weight only, above 150 ft AGL within the light grey shaded area

cumulative for Aerodromes with multiple runways.

Figure GM UAS.30(b)3vi.a‒2: Controlled aerodrome no-fly zones

controlled Airspace above 400 ft AGL when operating outside a controlled Aerodrome no-fly zone

the Airspace surrounding vessels capable of launching and recovering Aircraft—contact Royal Australian Navy Headquarters Fleet Air Arm for advice regarding approvals for RAN and foreign warships

areas where a fire, police or other public safety or emergency operation is being conducted—refer to local authorities.

Airspace management OIP. UAS Organisations should consider implementing:

defined requirements:

to seek approval from Airspace controlling authorities or Airspace control agencies to enter Airspace as detailed in ERSA (eg Airservices Australia or Airspace controlling authorities)

for communications with Participating Aircraft

to notify other Airspace users of the intended UA activity

for safe margins from Airspace boundaries and Participating Aircraft based on:

credible failure modes of the UAS

maximum airspeed

turn radius at maximum airspeed

command and control latency

navigation system redundancy and accuracy (Global Navigation Satellite Systems, altimeters)

technical risk controls (eg geo-fencing)

risk recovery controls (eg parachutes, air brakes, autonomous recovery system, etc)

Lost Link and emergency routing

Flight termination systems and designated Flight termination sites

adjacent area activity that may affect UAS behaviour, such as Radio Frequency emitters

adjacent area activity such as high-density Airspace.

documentation to inform (eg via the DASA ATMP template) relevant external stakeholders of the Aviation Safety hazards, relevant limitations and Risk Management associated with planned UAS operations, including:

UAS description, including equipage and navigational capabilities (eg GPS and altimeter accuracy, size of UA, operating ceiling, relevant launch/recover and manoeuvring capabilities)

type or volume of Airspace for intended operations

segregation or separation methods (eg RA, MOAs, Manual of Air Traffic Standards-compliant methods approved by the responsible Air Traffic Control agency, Lost Link procedures)

limitations (eg RP operating limits, lack of see and avoid capability, non-certified equipage, communications transceiver range limits, any prohibition of Flight above other Aircraft)

a formal operations liaison POC (eg Operations Officer).

Documentation consultation and endorsement. UAS Organisations may seek advice through DASA (DD UAS OPS) for implementation of Airspace Risk Management where they identify that they lack the necessary expertise or assess that further oversight will benefit Aviation Safety (eg DASA endorsement of an Air Traffic Management Plan).

GM UAS.30(b)3vi.b – Ground risk planning (AUS)

Areas at risk. UAS Organisations should generally determine the green, orange and red areas at risk for a UA system based on:

‘Green area’ dimensions, including:

task profile to be flown (eg point to point, area surveillance)

navigation accuracy (eg GNSS accuracy, position holding error, map error)

UA flight logics.

‘Orange area’ dimensions, including:

maximum operational speed of the UA

turning radius (fixed wing) or stopping distance (multirotor)

command and control latency

RP reaction time

loss-of-link logic (eg pre-programmed path or direct return)

geo-fence logic (if active) upon breach of the geo-fence. (180 degree turn or stopping).

‘Red area’ dimensions, including:

maximum operational speed of the UA

maximum operational height above ground level

descent profile resulting from the most credible UA failure mode(s), and whether the descent is likely to be controlled or under flight termination conditions (eg ballistic descent, glide ratio, drift under parachute recovery systems, debris field)

command and control latency

RP reaction time.

Adjacent area purpose. The adjacent area accounts for the residual risk posed by the failure of the containment risk controls used in the green, orange and red risk areas. One of the key advantages of UAS is their relative low-cost, but the trade-off is that system reliability is generally lower or unknown. Therefore, the adjacent area limits the population density commensurate to Standard Scenario limitations as a means of minimising potential consequences from containment failures.

People at risk. UAS Organisations should consider the following guidance when determining population densities.

Quantitative values. UAS Organisations should use quantitative values provided by authoritative statistical data sources (eg the Australian Bureau of Statistics) to determine the expected population density within an operational area. However, the UAS Organisation should also consider that this data may not reflect the actual population density at risk during an operation due to:

time-stale data (date of last census)

time of day and day of week variations

seasonal variations (eg camping areas or holiday destinations that could be expected to have a greater population density during holiday periods)

major weather events / area evacuations

sheltering—in general, UA weighing less than 25 kg (limited to the speeds in the Standard Scenarios) cannot penetrate buildings except in cases where the UAS speed or building materials are unusual (eg ballistic terminal speed descent, tents, glass roofs).

When using quantitative values to determine the people at risk, UAS Organisations should:

for the green, orange and red areas at risk apply the highest population density (people per square kilometre) of any segment overflown in the operating area

for the adjacent area at risk, use population density (people per square kilometre), averaged over the whole adjacent area, based on:

available population data

the adjacent area only beyond the Red area.

Qualitative descriptors. Where a UAS Organisation cannot characterise population density through quantitative means, UAS Organisations may use the qualitative descriptors defined in GM UAS.10 to determine the likely population density in an area, where relevant—prior to the implementation of risk controls to reduce the ‘at risk’ population.

GP and Critical Infrastructure avoidance criteria. Determinations of safe margins should include consideration of:

maximum airspeed of the UA

maximum operational altitude above ground level

UA descent profile under controlled descent or flight termination (eg ballistic descent, glide ratio, drift under parachute recovery systems, debris field)

command and control latency

RP reaction time

UA positional accuracy

use of geo-fencing (if available)

Loss of Link routing

payloads, where the payload may introduce hazards.
 

GM UAS.35 – Standard Scenario Privilege (AUS)

The DASR UAS.35 Standard Scenarios provide Approved UAS Organisations with a Privilege to operate UAS with residual risk to third parties (primarily civilians) through the Risk Management controls detailed in each Standard Scenario. This Privilege invokes specific requirements to execute Defence responsibilities to third parties in addition to those detailed in the broader Defence Aviation Safety Program. DASA will review and monitor this Privilege and will revoke the Privilege where it identifies non-compliances.

GM UAS.35(a) – Standard Scenario Privilege (AUS)

Approved UAS Organisations may also use this Standard Scenario over Defence Controlled Ground or Water.

GM UAS.35(a)3i – UA dimension and speed limitations (AUS)

The UA dimension and airspeed constraints limit the theoretical size of the area on the ground (critical area) where a UA could impact a standing person and result in a fatality. This is achieved through maximum UA dimension and speed limitations in addition to systemic risk controls implemented by the UAS Organisation to protect people or reduce the consequence of an impact.

GM UAS.35(a)3iii.a – RA, MOA and CTR (AUS)

En Route Supplement Australia (ERSA) and Designated Airspace Handbook (DAH) provide the approval authorities for operations in CTR, Restricted Areas (RA) and Military Operating Areas (MOA).

A CTR may enable the exclusion of non-Participating Aircraft where there is an active ATC service provided that ATC apply appropriate separation standards to Participating Aircraft.

MOAs that extend into international Airspace are not enforceable under international law. Therefore, Defence cannot prevent foreign Aircraft from entering such MOA. However, through the Airspace Regulations 2007, CASA can impose conditions of entry into MOAs for Australian registered Aircraft and publish any conditions in the DAH. Therefore:

MOAs and a RAs place equivalent entry restrictions on Australian registered Aircraft:

foreign Aircraft:

under international law, are not restricted from entering MOA

although not legally restricted from entering a MOA, should not enter Australian MOA without contacting the relevant administering authority.

UAS.30(b) provides the applicable core requirements for managing Airspace. UAS Organisations comply with AMC2 UAS.30(b)3vi.a by constraining any Defence UAS operation (outside Australian territory) to within a MOA. However, UAS Organisations will still need to be cognisant of foreign aircraft entering the MOA and implement appropriate procedures to respond to these situations.

Temporary RA and MOA requests. Requests for temporary RA and MOA are staffed to CASA – Office of Airspace Regulation through either the National Airspace Management Organisation (eg for routine requests) or the Joint Airspace Control Cell (JACC) (eg for large exercises). CASA, IAW the Airspace Act 2007, may establish temporary RA and MOA for purposes including:

public safety, including the safety of Aircraft in Flight

national security.

Foreign areas equivalent to CTRs, RAs and MOAs. UAS Organisations may use foreign Airspace where that Airspace provides equivalency to CTR, RAs and MOAs, if approved by the applicable Airspace controlling authority. In such situations, UAS Organisations will still be required to comply with DASR UAS.

Non−Participating Aircraft. Note, if the UAS is contained inside a Restricted Operating Zone (ROZ)—even if that ROZ is within a CTR/RA that permits non-Participating Aircraft; but the ROZ excludes non-Participating Aircraft—then the UAS Organisation has met the intent of DASR UAS.35(a)3iii.a.

GM UAS.35(a)3iii.b – Due regard (AUS)

See UAS.30(b)3vi.a including AMC and GM for due regard requirements.

GM UAS.35(b)1 – UA dimension and speed limitations (AUS)

The UA dimension and airspeed constraints limit the theoretical size of the area on the ground (critical area) where a UA could impact a standing person and result in a fatality. This is achieved through UA dimension and speed limitations, in addition to systemic risk controls implemented by the UAS Organisation to protect people or reduce the consequence of an impact.

GM UAS.35(b)2 – IA and CA (AUS)

See DASR UAS.30(b)2 including AMC and GM for the requirements applicable to all Standard Scenarios. Approved UAS Organisations should ensure they implement IA and CA risk controls appropriately contextualised to the risks introduced through one-to-many operations.

GM UAS.35(b)3i – RA and MOA (AUS)

En Route Supplement Australia (ERSA) and Designated Airspace Handbook (DAH) provide the approval authorities for operations in Restricted Areas (RA) and Military Operating Areas (MOA).

MOAs that extend into international Airspace are not enforceable under international law. Therefore, Defence cannot prevent foreign Aircraft from entering such MOA. However, through the Airspace Regulations 2007, CASA can impose conditions of entry into MOAs for Australian registered Aircraft and publish any conditions in the DAH. Therefore:

MOAs and a RAs place equivalent entry restrictions on Australian registered Aircraft

foreign Aircraft:

under international law, are not restricted from entering MOA

although not legally restricted from entering a MOA, should not enter Australian MOA without contacting the relevant administering authority.

UAS.30(b) provides the applicable core requirements for managing Airspace. UAS Organisations comply with AMC2 UAS.30(b)3vi.a by constraining Defence UAS operations (outside Australian territory) to within

Temporary RA and MOA requests. Requests for temporary RA and MOA are staffed to CASA – Office of Airspace Regulation through either the National Airspace Management Organisation (eg for routine requests) or the Joint Airspace Control Cell (JACC) (eg for large exercises). CASA, IAW the Airspace Act 2007, may establish temporary RA and MOA for purposes including:

public safety, including the safety of Aircraft in Flight

national security.

Foreign areas equivalent to RAs and MOAs. UAS Organisations may use foreign Airspace where that Airspace provides equivalency to RAs and MOAs, if approved by the applicable Airspace controlling authority. In such situations, UAS Organisations will still be required to comply with DASR UAS.

Non‒Participating Aircraft. Note, if the UAS is contained inside a Restricted Operating Zone (ROZ)—even if that ROZ is within an RA that permits non-Participating Aircraft; but the ROZ excludes non-Participating Aircraft—then the UAS Organisation has met the intent of DASR UAS.35(b)3i.

GM UAS.35(b)3.ii – Due regard (AUS)

See UAS.30(b)3vi.a including AMC and GM for due regard requirements.

GM UAS.35(b)4 – Risks to GP (AUS)

See the DASP Glossary for the definition of Defence Controlled Ground or Water.

When operating UAS in an area where General Public (GP) are not prohibited from entry (eg over water and in a MOA), UAS Organisations should usually document procedures for, and ensure:

surveillance to detect GP entering the area of operations (eg vessels)

safe termination of operations if GP enter the area of operations.

GM UAS.35(c) – Standard Scenario for T&E and high speed UAS (AUS)

This Standard Scenario provides the most restrictive set of Standard Scenario risk controls given the requirement to eliminate or otherwise minimise risks SFARP to third parties through the absence of General Public and Critical Infrastructure from the operating area. An AUO should not view this Standard Scenario as a less restrictive approval pathway for UAS operations because it contains a reduced number of risk controls relative to the other Standard Scenarios. DASA may place further limitations on an AUO’s approval for operations under this Standard Scenario commensurate to the AUO organisation, personnel and process risk controls.

This Standard Scenario enables Approved UAS Organisations (AUO) to conduct UAS T&E and high speed UAS operations within the requirements of the Standard Scenario, with:

elevated Aviation Safety risks to persons and Critical Infrastructure

one RP for multiple UA’s

UAS of any dimension and speed.

AUOs should seek advice from DASA where there is any doubt regarding the appropriateness of the risk controls implemented to manage activities under this Standard Scenario.

High speed UAS

Where an AUO is operating high speed UAS, no single failure of the UAS should lead to operation outside of the red risk area (see AMC UAS.30(b)3vi.b for the applicable ground risk planning procedures, including red risk areas). One of the most effective means of protecting areas outside red risk areas is to use independent flight termination systems. A flight termination system should activate automatically when the UA position or actions are in doubt. The AUO should ensure fully independent flight termination systems:

are designed and manufactured to ensure reliability commensurate to the risk the UAS poses to other Airspace users, people on the ground and Critical Infrastructure

does not interface with other UAS systems that could interfere with operation in the event of malfunction (eg separate power source, antenna, control actuators etc.)

includes an independent means of providing awareness to the RP of the UA position and altitude for ensuring continued awareness in the case of primary RPS failure.

GM UAS.35(c)3i – RA and MOA (AUS)

En Route Supplement Australia (ERSA) and Designated Airspace Handbook (DAH) provide the approval authorities for operations in Restricted Areas (RA) and Military Operating Areas (MOA).

MOAs that extend into international Airspace are not enforceable under international law. Therefore, Defence cannot prevent foreign Aircraft from entering such MOA. However, through the Airspace Regulations 2007, CASA can impose conditions of entry into MOAs for Australian registered Aircraft and publish any conditions in the DAH. Therefore:

MOAs and a RAs place equivalent entry restrictions on Australian registered Aircraft

foreign Aircraft:

under international law, are not restricted from entering MOA

although not legally restricted from entering a MOA, should not enter Australian MOA without contacting the relevant administering authority.

UAS.30(b) provides the applicable core requirements for managing Airspace. UAS Organisations comply with AMC2 UAS.30(b)3vi.a by constraining Defence UAS operations (outside Australian territory) to within a MOA. However, UAS Organisations will still need to be cognisant of foreign aircraft entering the MOA and implement appropriate procedures to respond to these situations.

Temporary RA and MOA requests. Requests for temporary RA and MOA are staffed to CASA – Office of Airspace Regulation through either the National Airspace Management Organisation (eg for routine requests) or the Joint Airspace Control Cell (JACC) (eg for large exercises). CASA, IAW the Airspace Act 2007, may establish temporary RA and MOA for purposes including:

public safety, including the safety of Aircraft in Flight

national security.

Foreign areas equivalent to RAs and MOAs. UAS Organisations may use foreign Airspace where that Airspace provides equivalency to RAs and MOAs, if approved by the applicable Airspace controlling authority. In such situations, UAS Organisations will still be required to comply with DASR UAS.

Non-Participating Aircraft. Note, if the UAS is contained inside a Restricted Operating Zone (ROZ)—even if that ROZ is within an RA that permits non-Participating Aircraft; but the ROZ excludes non-Participating Aircraft—then the UAS Organisation has met the intent of DASR UAS.35(c)3i.

GM UAS.35(c)3ii – Due regard (AUS)

See DASR UAS.30(b)3vi.a including the associated AMC and GM for due regard requirements.

GM UAS.35(c)4 – Risks to General Public (AUS)

See the DASP Glossary for the definition of Defence Controlled Ground or Water.

General Public. When operating UAS in an area where GP are not prohibited from entry (eg over water and in a MOA), UAS Organisations should document procedures for, and ensure:

surveillance to detect GP entering the area of operations (eg vessels)

safe termination of operations if GP enter the area of operations.

Adjacent area. DASR UAS.30(b)3vi.b provides the planning procedures for characterising ground risk areas for the GP. The relevant test plan or equivalent document should detail formal Risk Management (RM) procedures commensurate to the UAS CRE and population densities within the relevant area at risk and adjacent area. For adjacent areas encompassing increased population densities (eg towns), RM should include consideration of systems such as fully independent flight termination systems to ensure flight termination should the UAS escape the planned operating area.

GM UAS.35(d) – Risk Controls for weaponised UAS operations (AUS)

The Explosives Safety Regulatory Framework details additional risk controls applicable to Explosives (eg fuzing systems).

GM UAS.35(d)1– Range Danger Area (AUS)

The Defence Training Area Management Manual (DTAMM) details Defence Range Danger Area policy.

GM UAS.35(d)2i – RA and MOA (AUS)

En Route Supplement Australia (ERSA) and Designated Airspace Handbook (DAH) provide the approval authorities for operations in Restricted Areas (RA) or Military Operating Areas (MOA).

MOAs that extend into international Airspace are not enforceable under international law. Therefore, Defence cannot prevent foreign Aircraft from entering such MOA. However, through the Airspace Regulations 2007, CASA can impose conditions of entry into MOAs for Australian registered Aircraft and publish any conditions in the DAH. Therefore:

MOAs and a RAs place equivalent entry restrictions on Australian registered Aircraft

foreign Aircraft:

under international law, are not restricted from entering MOA

although not legally restricted from entering a MOA, should not enter Australian MOA without contacting the relevant administering authority.

UAS.30(b) provides the applicable core requirements for managing Airspace. UAS Organisations comply with AMC2 UAS.30(b)3vi.a by constraining Defence UAS operations (outside Australian territory) to within a MOA. However, UAS Organisations will still need to be cognisant of foreign Aircraft entering the MOA and implement appropriate procedures to respond to these situations.

Temporary RA and MOA requests. Requests for temporary RA and MOA are staffed to CASA – Office of Airspace Regulation through either the National Airspace Management Organisation (eg for routine requests) or the Joint Airspace Control Cell (JACC) (eg for large exercises). CASA, IAW the Airspace Act 2007, may establish temporary RA and MOA for purposes including:

public safety, including the safety of Aircraft in Flight

national security.

Foreign areas equivalent to RAs and MOAs. Approved UAS Organisations may use foreign Airspace where that airspace provides equivalency to RAs and MOAs, if approved by the applicable Airspace controlling authority. In such situations, UAS Organisations will still be required to comply with DASR UAS.

Non-Participating Aircraft. Note, if the UAS is contained inside a Restricted Operating Zone (ROZ)—even if that ROZ is within an RA that permits non-Participating Aircraft; but the ROZ excludes non-Participating Aircraft—then the UAS Organisation has met the intent of DASR UAS.35(d)2i.

GM UAS.35(d)2ii – Due regard (AUS)

See DASR UAS.30(b)3vi.a including the associated AMC and GM for due regard requirements.

GM UAS.35(d)4 – Defence Controlled Ground or Water areas (AUS)

See the DASP Glossary for the definition of Defence Controlled Ground or Water.

The Defence Training Area Management Manual (DTAMM) details the approval processes and requirements for management of activities involving explosives. Service-specific policy may apply to the determination of appropriate areas.

General Public. When operating UAS in an area where GP are not prohibited from entry (eg over water and in a MOA), UAS Organisations should document procedures for, and ensure:

surveillance to detect GP entering the area of operations (eg vessels)

safe termination of operations if GP enter the area of operations.

Informed Personnel. Approved UAS Organisations should only permit Informed Personnel within the relevant ground area in addition to Mission Essential Personnel when their respective Commands are reasonably informed and retain risks at the appropriate Service or Group prescribed level.

GM UAS.35(d)5 – Safety risks to MEP (AUS)

The Defence Aviation Safety Program Manual (DASPMAN) Volume 3, Chapter 14 Safety Management Systems, provides guidance regarding ‘grossly disproportionate’ assessments relevant to MAO decisions regarding MEP risk exposure.

‘Protected location’ in AMC UAS.35(d)5 refers to any location that prevents harm to personnel from the weaponised UA. Note, 'harm to personnel from the weaponised UA' can include harm through blast, fragmentation, heat or ballistic effects.

GM UAS.36 – Standard Scenario Privilege (AUS)

The DASR UAS.36 Standard Scenarios provide UAS Organisations with a Privilege to operate UAS with residual risk to third parties through the Risk Management procedures detailed in the Standard Scenarios. This Privilege invokes specific requirements to execute Defence responsibilities to third parties in addition to those detailed in the broader Defence Aviation Safety Program. DASA will review and monitor this Privilege and will revoke the Privilege where it identifies non-compliances.

GM UAS.36(a) – Standard Scenario for limited operations over non-Defence Controlled Ground or Water (AUS)

This Standard Scenario enables limited UAS operations over non-Defence Controlled Ground or Water, with due regard for the Aviation Safety of other Aircraft and consideration of the risk to people on the ground, without the need for a discrete DASA approval. UAS Organisations may also use this Standard Scenario over Defence Controlled Ground or Water.

GM UAS.36(a)1 – UA dimension and speed limitations (AUS)

The UA dimension and airspeed constraints limit the theoretical size of the area on the ground (critical area) where a UA could impact a standing person and result in a fatality. This is achieved through maximum UA dimension and speed limitations, and assumes no additional risk controls to protect people or reduce the consequence of an impact.

Airspeed management. This Standard Scenario constrains UAS Organisations to operating UAS without the capability for higher speeds than the limitations imposed, unless they are an Approved UAS Organisation (AUO). AUOs may limit UA airspeed through ‘maximum commanded airspeed’ given the independent assurance provided to an AUO’s organisation and Flying Management System. In these cases, DASA expects the AUOs to Risk Manage UAS with greater speed capability than the imposed limitations.

GM UAS.36(a)2 – Due regard (AUS)

See DASR UAS.30(b)3vi.a including AMC and GM for due regard requirements.

GM UAS.36(a)3 – Ground area definitions (AUS)

See GM UAS.10 for the definition of Lightly Populated areas.

GM UAS.36(a)3iii – UA take-off-weight ≤250g (AUS)

The permission for a UA with a take-off-weight of ≤250 g recognises that the hazards to people on the ground are inherently minimised for a UAS with this take-off-weight and airspeed limit. This does not negate the obligation on the UAS Organisation to further eliminate or otherwise minimise risks SFARP.

GM UAS.36(b) – Standard Scenario for operations over Defence Controlled Ground or Water (AUS)

This Standard Scenario enables operations with larger UAS through limiting operations to Defence Controlled Ground or Water and exclusive use Airspace, without the need for a discrete DASA approval.

GM UAS.36(b)1 – UA dimension and speed limitations (AUS)

The UA dimension and airspeed constraints limit the theoretical size of the area on the ground (critical area) where a UA could impact a standing person and result in a fatality. This is achieved through UA dimension and speed limitations, and assumes no additional risk controls to protect people or reduce the consequence of an impact.

Airspeed management. This Standard Scenario constrains UAS Organisations to operating UAS without the capability for higher speeds than the limitations imposed, unless they are an Approved UAS Organisation (AUO). AUOs may limit UA airspeed through ‘maximum commanded airspeed’ given the independent assurance provided to an AUO’s organisation and FMS. In these cases, DASA expects the AUOs to Risk Manage UAS with greater speed capability than the imposed limitations.

GM UAS.36(b)2i – RA and MOA (AUS)

En Route Supplement Australia (ERSA) and Designated Airspace Handbook (DAH) provide the approval authorities for operations in Restricted Areas (RA) and Military Operating Areas (MOA).

MOAs that extend into international Airspace are not enforceable under international law. Therefore, Defence cannot prevent foreign Aircraft from entering such MOA. However, through the Airspace Regulations 2007, CASA can impose conditions of entry into MOAs for Australian registered Aircraft and publish any conditions in the DAH. Therefore:

MOAs and a RAs place equivalent entry restrictions on Australian registered Aircraft

foreign Aircraft:

under international law, are not restricted from entering MOA

although not legally restricted from entering a MOA, should not enter Australian MOA without contacting the relevant administering authority.

UAS.30(b) provides the applicable core requirements for managing Airspace. UAS Organisations comply with AMC2 UAS.30(b)3vi.a by constraining Defence UAS operations (outside Australian territory) to within a MOA. However, UAS Organisations will still need to be cognisant of foreign Aircraft entering the MOA and implement appropriate procedures to respond to these situations.

Temporary RA and MOA requests. Requests for temporary RA and MOA are staffed to CASA – Office of Airspace Regulation through either the National Airspace Management Organisation (eg for routine requests) or the Joint Airspace Control Cell (JACC) (eg for large exercises). CASA, IAW the Airspace Act 2007, may establish temporary RA and MOA for purposes including:

public safety, including the safety of Aircraft in Flight

national security.

Foreign areas equivalent to RAs and MOAs. UAS Organisations may use foreign Airspace where that Airspace provides equivalency to RAs and MOAs, if approved by the applicable Airspace controlling authority. In such situations, UAS Organisations will still be required to comply with DASR UAS.

Non-Participating Aircraft. Note, if the UAS is contained inside a Restricted Operating Zone (ROZ)—even if that ROZ is within an RA that permits non-Participating Aircraft; but the ROZ excludes non-Participating Aircraft—then the UAS Organisation has met the intent of DASR UAS.36(b)2.i.

GM UAS.36(b)2ii – Due regard (AUS)

See DASR UAS.30(b)3vi.a including AMC and GM for due regard requirements. Of note, the requirement to remain below 400 ft AGL eliminates some of the options available in AMC2 UAS.30(b)3vi.a.

GM UAS.36(b)3 – Risks to General Public (AUS)

See the DASP Glossary for the definition of Defence Controlled Ground or Water.

When operating UAS in an area where GP are not prohibited from entry (eg over water and in a MOA), UAS Organisations should document procedures for, and ensure:

surveillance to detect GP entering the area of operations (eg vessels)

safe termination of operations if GP enter the area of operations.

GM UAS.36(b)5 – T&E practitioners (AUS)

The DTEM defines the requirements and competencies of T&E practitioners.

GM UAS.40(a) – Purpose statement (AUS)

(Context) Open category facilitates a range of constrained Defence UAS operations where the UAS Organisation may have no previous aviation experience, without the need for a discrete DASA approval. (Hazard) Inadequately constrained regulatory risk controls for Open category UAS operations may compromise Aviation Safety. (Defence) This regulation requires a UAS Organisation to implement simple and robust risk controls to eliminate Aviation Safety risks SFARP, and if it is not reasonably practicable to eliminate those risks, to otherwise minimise safety risks SFARP.

GM UAS.40(a)1i – Accountability for all UAS operations (AUS)

A commander (with an appropriate delegation) or Defence Group equivalent is usually the accountable person for Open category UAS operations.

GM UAS.40(a)1ii – Aviation Safety Risk Management (AUS)

The Defence Aviation Safety Program Manual (DASPMAN) Volume 3, Chapter 14 Safety Management Systems provides guidance for development and usage of Aviation Safety Risk Management.

GM UAS.40(a)4 – Intervention by the RP (AUS)

Intervention refers to an action, command or input by the RP to direct the UA’s Flight actions. 

GM UAS.40(a)5 – UA speed (AUS)

UAS Organisations operating IAW UAS.40 should generally limit the UA speed to 25 m/s (50 kts) groundspeed to reduce potential injury consequences. Where a UAS Organisation conducts Flights that exceed 25 m/s, they should consider additional risk controls or operating under a Standard Scenario that provides the necessary permissions.

GM UAS.40(a)5ii – Operating below 400ft AGL (AUS)

The imposition of a 400ft AGL operating ceiling constrains Open category UAS to Airspace where fewer Aircraft routinely operate. This limitation assists to define operating context for the purpose of Risk Management.

GM UAS.40(a)5iii – Visual range (AUS)

UAS.40 limits flights to within visual range of the RP using two options. The options assure that the RP can always see and avoid other Aircraft.

Regardless of which visual option a UAS Organisation employs, they should ensure that RPs are aware of the various limitations on visual detection. RPs should exercise caution in relying on their perception of maximum visual range, and use the available visual cues at all times.

Pre-Flight considerations. UAS Organisations are responsible for ensuring RPs collect relevant Aeronautical Information (AI) (eg NOTAMs) to maximise the effectiveness of visual detection, and make broadcasts on relevant airband frequencies where appropriate. These actions aid in the identification of Flight activity for which the UA may pose a hazard. Relevant Flight activity could include low-level flying such as:

military low jet routes

agricultural aviation

tourist Aircraft

rescue helicopters

fire-bombing Aircraft

other UAS.

GM UAS.40(a)5iii.a(3) – Night visual conditions (AUS)

Night visual conditions equivalent to daytime are usually limited to areas such as brightly lit sports fields, Aerodromes and other high illumination areas.

GM UAS.40(a)5iii.b(3) – Ground environment definition (AUS)

See GM UAS.10 for ground environment definitions.

GM UAS.40(a)5vi – Relevant approval (AUS)

Figure GM UAS.40(a)5vi‒1 depicts the no-fly zone of Defence and civilian controlled Aerodromes, which are areas below 400 ft AGL:

within three (3) nm in any direction from the runway threshold of any runway of a non-controlled aerodrome

within the areas shaded dark grey less than seven (7) km from the runway threshold, and above 300 ft AGL beyond 7km from the runway threshold

for UAS <250 g take-off-weight only, above 150 ft AGL within the light grey shaded area.

For Aerodromes with multiple runways, the no-fly areas overlap and apply concurrently, measured from each runway.

For approval to operate in the no-fly zone of Defence and civilian controlled Aerodromes, the Air Traffic Control agency listed in En-Route Supplement Australia are the approvers.

Figure GM UAS.40(a)5vi-1: Controlled aerodrome no-fly zones

GM UAS.40(a)5vii – Relevant approval (AUS)

For operations in proximity to a civilian vessel, the captain, vessel master or delegate provides approval.

For UAS operations in proximity to Royal Australian Navy or foreign warships, restrictions may apply. UAS Organisations may contact the Royal Australian Navy Headquarters Fleet Air Arm for advice.

GM UAS.40(a)5viii – Relevant events (AUS)

A relevant event refers to any time a crewed Aircraft is within the relevant Airspace of an Aerodrome or HLS, including when an Aircraft is in the course of approaching, landing at, taking off from, or manoeuvring on the movement area of the Aerodrome.

If the UA is already airborne when a relevant event occurs, the RP is required to manoeuvre the UA away from the path of the crewed Aircraft and land the UA as soon as safely possible.

The no-fly area for a HLS is a circle of 0.75 nm (1.4 km) radius centred on the helipad, surface to 400 ft AGL.

Figure GM UAS.40(a)5viii‒1 shows the no-fly zone of a non-controlled Aerodrome, which are areas below 400 ft AGL:

within three (3) nm, in any direction, from the runway threshold of any runway of a non-controlled aerodrome

for UAS <250 g take-off-weight only, from 150 to 400 ft AGL within the light grey shaded area

from the surface to 400 ft AGL within the areas shaded dark grey.

Figure GM UAS.40(a)5viii - 1: Non-controlled aerodrome no-fly zones 

GM UAS.40(a)6 – Areas surrounding the operation (AUS)

UAS Organisations operating UAS under UAS.40 should ensure planning and operating procedures include consideration of surrounding areas and the consequences of escaped UA or other similar situations where the RP loses control of the UA. UA range and endurance should drive the extent of consideration given to other Aircraft, people or Critical Infrastructure in surrounding areas, and whether the UAS Organisation should implement additional risk controls to manage those risks.

For additional guidance, UAS Organisations could consider the AMC and GM to UAS.30(b)3vi.b provided for ground risk planning under the Standard Scenarios.

GM UAS.40(a)6i – GP sheltering (AUS)

This requirement assures the protection of GP from hazards related to the UA Flight. Where structures or natural features physically protect GP, the RP may operate the UA closer than 30 m.