PROF PHILIPPE-JOSEPH SALAZAR
LE AG LE E AG LE:
The Gazette – on full gas Is it a Model, a UAV or RPAS? – And what’s a ‘conversion’ and ‘currency’? If you were wondering what the CAA has been up to during the lockdown - it’s not idly watching Generations and Muvhango. During the Covid-19 confinement our regulator did not confine itself to reading SA Flyer over a cup of coffee either.
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HEIR rulemaking department has forged ahead with proposals to change regulations (CARS) and technical standards (CATS). These were duly gazetted and were officially published by the Government Printing Works on 3 April 2020 in what is called, for those who enjoy that sort of recondite detail, a “Regulation Gazette”. And for those who enjoy formalities, here it goes, full gas: “The Minister of Transport intends, in terms of section 155(1) of the Civil Aviation Act, 2009 (Act No. 13 of 2009) and on the recommendation of the Civil Aviation Regulations Committee (CARCom), to amend the Civil Aviation Regulations, 2011, by the amendment of the following Parts set out in Schedules below.” Same lingo for CATS. Except that it comes from the Director of Civil Aviation (why that difference in status? Because Act 13 of 2009 says so). What follows the declaration is a list of 17 Schedules, that is, sets of changes, no less than nine for CARS and eight for CATS. Each schedule relates to a specific Part. The text of the schedules are usually uploaded a few days later onto the SACAA website (http://www.caa.co.za/Pages/Acts%20 and%20Regulations/Notices.aspx). There is always an instrument lag, call it “hardware-software-humanware interface latency” if you like big words. The Gazette ends on a request: “Interested persons are hereby invited to submit written comments on these draft amendments on or before the 03 May 2020 to the Chairperson.” ‘Verstaan jy?’ What are the changes? Good question. There is an art to reading the Schedules. A Schedule quotes the current version of the regulation or technical standard alongside what is proposed for deletion in [bold and square brackets] and for insertion (read: proposed new wording) underlined with a solid line. When the proposed change is long, it is called a “substitution”. If it happens that a proposed change is entirely new (it does not replace anything), the whole change is underlined, and it can run into pages.
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FlightCom Magazine
Examples speak volumes, if you have switched on your radio, that is. RPAS beware! An example of an important proposed change of a definition (Parts 1.01.1) RPAS enthusiasts must take note of! – “model aircraft” means a heavier-than-air aircraft of limited dimensions, with or without a propulsion device, unable to carry a human being, [and] to be used for competition, sport or recreational purposes [rather than unmanned aeronautical vehicles (UAV) developed for commercial or governmental, scientific, research or military purposes, and not exceeding the specifications as set by the Federation Aeronautique Internationale as listed in Document SA-CATS 24]; Note. -This definition excludes RPAS [developed for commercial, governmental, scientific, research, or military purposes,] and not exceeding the specifications as determined by the organisation approved in terms of Part 149 as listed in Document SA-CATS 24. Verstaan jy? NO? Just compare the current definition for a model aircraft (barring the spelling errors in French) which reads “model aircraft” means a heavier-than-air aircraft of limited dimensions, with or without a propulsion device, unable to carry a human being and to be used for competition, sport or recreational purposes rather than unmanned aeronautical vehicles (UAV) developed for commercial or governmental, scientific, research or military purposes, and not exceeding the specifications as set by the Federation Aeronautique Internationale as listed in Document SACATS 24. with the proposed definition that will probably read if confirmed:
