On 13 May 2019 the Ministry of Transport (MoT) released an exposure draft of the proposed new Civil Aviation Bill, together with a commentary document. This post summarises ASMS’ submission on the exposure draft and links to our full submission. Most of the commentary below is from the executive summary of the submission. The full submission contains 28 detailed recommendations for change, some of which are points of detail but others of which go to the heart of the design of the aviation regulatory system.
19 August 2020
For immediate release
Independent analysis of research released by the Civil Aviation Authority indicates that the number of drones and drone users may be significantly overstated.
On 12 August 2020 the Civil Aviation Authority released a report from market research agency Colmar Brunton claiming that there may be 15,322 drones in New Zealand used for business or scientific purposes, and 156,610 drones used for recreational purposes. In an analysis released today, aviation consulting firm Aviation Safety Management Systems Ltd (ASMS) calls into question the accuracy of these figures. Dr Andrew Shelley, the Managing Director of ASMS, said that the analysis draws on the firm’s own private data set of commercial drone operators as well as casting a critical eye over the data and conclusions contained in the survey report.
Dr Shelley stated that “the number of commercial drone operators claimed by the survey report is not consistent with the survey report’s own data.” He said that “using the survey report’s own data, the number of commercial drone users may be overstated by up to 337 percent. Applying the ASMS data set, we estimate that the number of drones used commercially could be overstated by up to 250 percent.”
Dr Shelley questioned “if this is true of the number of commercial users and commercial drones, does the same level of overstatement apply to the number of recreational drones and recreational drone users?”
The ASMS analysis also identifies that the survey report classifies airspace as restricted that is not restricted. In the ASMS analysis Dr Shelley suggests that the term restricted “was chosen to get good headlines that would drive a political agenda.”
Dr Shelley also questioned the implicit bias in survey questions that were clearly designed to garner support for the Ministry of Transport’s drone regulatory programme. “The questions are worded to imply that the proposed interventions will be effective, when there is actually considerable doubt about their effectiveness.”
“The importance of getting these numbers right goes to the heart of the Ministry of Transport’s drone regulatory programme” Dr Shelley said. “With drone users potentially over stated by such a large factor, there is a significant risk that these inflated numbers will be used to justify policy interventions that are not proportionate”.
In addition, Dr Shelley noted that the survey report “lacks basic data and analysis that would be expected from a robust analysis – there are no error bounds and no attempt to identify whether the results are statistically significant. This might not be important to the casual reader, but it is important if policy interventions are to be evidence-based.”
A copy of the ASMS analysis can be downloaded here.
You have an approved SMS Implementation Plan, but now what?
New course dates.
ASMS is pleased to announce two more dates for our popular 2 day practical SMS course. Extensive use is made of case studies and practical exercises to demonstrate how an effective SMS can work in practice.
You will benefit from experience gained implementing SMS for multiple Group 1 organisations, with trainers that also understand the constraints faced by small organisations.
Previous attendees have commented:
"Well worth attending. Some excellent stuff to get our process rolling."
"Great course, instruction was on point."
Audience
This course is intended for Chief Executives, Safety Systems Managers, and other staff involved with implementing and utilising SMS.
| Date: |
20-21 May 2019 |
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24-25 July 2019 |
| Location: |
Ardmore Airport, Auckland |
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Ardmore Airport, Auckland |
| Registration link: |
(register) |
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(register) |
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| Cost: | $1,500+GST |
Places are limited, book now to reserve your place.
 The Pyka Egret. Aviation Safety Management Systems Ltd (ASMS) is excited to welcome Pyka LLC to New Zealand. Pyka will be test flying their 'Egret 4' unmanned aircraft under a certification programme agreed with the Civil Aviation Authority of New Zealand. The Egret 4 has a wing span of 7.8m and maximum take-off weight of approximately 270kg, with 100kg being available for payload.
Once aircraft certification is achieved then Pyka intends to undertake commercial agricultural spray operations.  Simulated spray run (water only)
Our journey together began back in 2017 when we prepared Pyka's exposition for operation under New Zealand's Civil Aviation Rule Part 102. That journey has continued as we have provided regulatory advice, delivered pilot training and competency assessments, and will continue as we provide training for a UAV Agricultural Rating after aircraft certification and full Part 102 certification is achieved.
About Pyka
Based in Palo Alto, California, Pyka LLC ( flypyka.com) is an autonomous electric airplane startup aiming to make agricultural chemical application fast, and precise, and easy – even over challenging terrain.
ASMS is pleased to announce that our SMS course, SMS in Practice, has been approved by the Civil Aviation Authority and added to our Aviation Training Organisation Schedule of Conditions.
Our next SMS course is on 4 and 5 March 2019. Make the commitment to obtain your CAA-approved SMS training and register today.
At ASMS we believe that you should never stop learning. I’ve just spent an excellent day at a Helicopter Safety Seminar with Claude Vuichard, organised by The Helicopter Line in Queenstown. The seminar covered a wide range of relevant topics including specific design faults with common helicopter models, human factors issues including decision making under stress, negative transfers (often a combination of human factors and design), CRM, wire strike avoidance, slope landings, auto-rotations, and the “Vuichard Recovery Technique” for vortex ring state recovery.
The Vuichard Recovery Technique is slightly controversial, primarily because of a lack of understanding of the flight physics involved. The traditional technique for recovery from vortex ring state involves pushing the cyclic forward and diving into the ground. Height loss with the traditional technique may be in the order of 500ft – perfectly acceptable when practiced at 1,000ft AGL as part of flight training, but not so good when close to the ground. The Vuichard Recovery Technique involves increasing the collective, applying the power pedal, and pushing the cyclic in the opposite direction to the power pedal. Height loss with the Vuichard Recovery Technique is just 20-50ft. Details of the Vuichard Recovery Technique are available on the Vuichard Recovery Aviation Safety Foundation website.
It is understood that the FAA Is revising their handbook to include the Vuichard Recovery Technique, and the forthcoming revised edition of the late Walter Wagtendonk’s Principles of Helicopter Flight has a completely revised chapter on vortex ring state which explains the physics and the technique.
Other tips that particularly resonated were
- A negative transfers checklist when introducing a new type or variant to identify every switch or control that looks similar or is in a similar position but has a different function on the new craft.
- Always assume wires are present and brief accordingly, both for approach and departure.
- Talk to yourself in the third person to slow down the decision making process and ensure you have considered the pertinent information. This will result in more effective decisions.
- Slope landings should be nose-in, with the cyclic eased back so that the rotor disk is parallel to the slope rather than horizontal.
A very good seminar and highly recommended to anyone who has the chance to attend, whether in New Zealand or elsewhere in the world.
- Andrew
You have an approved SMS Implementation Plan, but now what?
Updated 26/10/2018: First 2019 course date now available.
ASMS is pleased to announce a 2 day practical SMS course. Extensive use is made of case studies and practical exercises to demonstrate how an effective SMS can work in practice.
You will benefit from experience gained implementing SMS for multiple Group 1 organisations, with trainers that also understand the constraints faced by small organisations.
Audience
This course is intended for Chief Executives, Safety Systems Managers, and other staff involved with implementing and utilising SMS.
| Date: |
15-16 November 2018 |
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4-5 March 2019 |
| Location: |
Dunedin |
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Ardmore Airport, Auckland |
| Registration link: |
(register) |
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(register) |
| |
| Cost: | $1,500+GST |
Places are limited, book now to reserve your place.
The malicious or negligent use of drones gives rise to significant risks. While the risky behaviours are subject to existing legal sanctions, the apprehension of perpetrators can be difficult.
Licensing is sometimes proposed as a means of controlling drone operations. However, licensing, even when coupled with surveillance and enforcement, does not prevent unlicensed individuals from engaging in the activity, or licensed individuals from undertaking the activity in an unsafe manner. Notwithstanding the prohibition on using a hand-held cellphone while driving, in the 2017 calendar year the New Zealand Police recorded 23,412 offences of using a hand held device for calling or texting while driving (New Zealand Police, 2018).
ASMS congratulates Fire & Emergency New Zealand (FENZ) on the first day of their existence as a new crown entity. FENZ ( https://fireandemergency.nz/) has been formed from the amalgamation of the urban-focussed New Zealand Fire Service, the National Rural Fire Authority, and territorial fire authorities.
ASMS is proud to be associated with Life Flight as a Community Partner for the 2017-18 year.
On average, someone in New Zealand requires the help of Life Flight every six hours. In the last half of 2016 Life Flight flew 696 missions, of which 362 were intensive care transfers. Our contribution as a Life Flight Community Partner will pay the cost of at least one emergency flight during the current year.
In addition to our participation in the community partnership programme, Heather also works for the Life Flight’s fixed-wing operations as their contracted and CAA-approved Quality Assurance Manager.
Visit the Life Flight website for more information on their activities.
Aviation Safety Management Systems Ltd (ASMS) congratulates Scion on the award of Part 102 certification for their UAV operations. Scion is a New Zealand Crown Research Institute (CRI) that specialises in research, science and technology development for the forestry, wood product and wood-derived materials and other biomaterial sectors.
Scion utilises its UAVs to capture LiDAR and multi-spectral imagery for a variety of tasks. The technologies can greatly increase forest management efficiencies by allowing companies to track and guide workers on regular forestry maintenance and remediation, and issues such as fire prevention and control.
ASMS is pleased to have prepared Scion's exposition and application for certification. We integrated Scion’s existing health and safety procedures with procedures that we developed to provide a complete exposition. Attaining Part 102 certification is symbolic of Scion’s intent to complement their scientific expertise with best practice in their UAV operations.
About Scion
Scion’s purpose is to drive innovation and growth from the forestry, wood product and wood-derived materials and other biomaterial sectors sector to build economic value and contribute to beneficial environmental and social outcomes for New Zealand. Formerly the NZ Forest Research Institute, Scion employs approximately 340 people and has its head office in Rotorua. For more information, please visit www.scionresearch.com..
Further Information
For further information on Scion’s UAV operations see:
ASMS has provided a submission in response to CAA's discussion paper on fatigue risk management.
CAA proposes to update the prescriptive fatigue management requirements currently provided in Advisory Circulars, and to also provide the option for an operator to implement an Fatigue Risk Management System (FRMS) as an alternative. In theory this would improve the management of fatigue as the prescriptive requirements provide a "backstop" while the optional FRMS enables the operator to adopt a different system if it will better suit its requirements.
Key points in our submission are:
- Get a review of the scientific literature done by a suitably qualified expert, and base the regulated scheme(s) and the principles for FRMS on that review;
- Fatigue is a safety risk, ergo no matter how it is managed it is part of the broader safety management system;
- Don’t make assumptions about what might or might not be reasonably practicable, but instead apply analysis based on the legislative definition of reasonably practicable; and
- Support all safety management initiatives, including fatigue risk management, with a genuine commitment to just culture.
We also noted that any effort to increase reporting will continued to be hampered by enforcement activities, and made reference to the proposal in our Review of Joining Procedures at Unmanned Aerodromes that safety reports should be collected by an organisation independent of the enforcement authority.
A full copy of our submission can be accessed here.
Image courtesy of Ktoine. Used under Creative Commons Licence CC BY-SA 2.0.
Aviation Safety Management Systems (ASMS) congratulates Tiro 360 Ltd on the award of Part 102 certification for their UAV operations. Tiro 360's mission is to transform industries with better information, using a range of technologies to deliver information products that are visually powerful, highly accurate and instantly usable.
Tiro 360 provides a broad range of services backed up by proven expertise, including:
- topographic survey and mapping
- crop health and precision agriculture
- industrial inspection using specialised sensors
- applied use of GIS for analysis, asset management, and modelling
- data integration across multiple software and hardware platforms
- avionics design and electronic engineering
If specialised equipment is needed for your job they can design, build, and fly it.
ASMS is pleased to have prepared Tiro 360's exposition and application for certification. Privileges available under the certificate include operating at night, over persons or property, and within low flying zones.
Aviation Safety Management Systems Ltd (ASMS) congratulates Fighter Jets.nz on the award of their Part 115 Adventure Aviation Operator Certificate. We are proud to have project managed the application process and developed the exposition for the Fighter Jets.nz operation.
Fighter Jets.nz is based in Tauranga and operates the Aerovodochody L-39C, a tandem 2-seat jet training aircraft. The L-39C has a top speed of Mach 0.8, equating to 910km/h at altitudes up to 3,600ft AMSL. The L-39 is also one of the most popular warbird aircraft: over 220 are registered in the United States, with 118 of those being the L-39C variant.
Photo credit: Strikemaster Club Facebook page.
Brett Nicholls, Chief Executive and owner of Strikemaster Ltd, has announced that NZ6362 and NZ6370 will shortly depart New Zealand's shores.
Brett says:
It is with some sadness that I would like to inform you that both my Strikemasters and all spares have been sold to Blue Air Training based in Las Vegas, USA. I understand Blue Air Training has eight Strikemasters and a significant inventory of spare – with my two, they will have four ex RNZAF Strikemasters.
The decision to sell was not taken lightly, however it has to be acknowledged that the landscape for Strikemaster operations has changed significantly over the last few months which had the potential to drastically increase the maintenance costs on the aircraft and the length of time each aircraft would be out of the air.
It came to light in the fourth quarter of last year that this company purchased all Strikemaster and Jet Provost spares from Australia (our main source of spare parts) and they have an extremely close relationship with a company in the UK who has the other significant inventory of Strikemaster spare parts. Obviously, with the reduction in spare part availability it meant that running a Pt 115 operation was going to be increasingly difficult and significantly more costly.
I would like to thank the Strikemaster team for all their support over the years – Dave, Mark, Dean, Heather, Shooter, Paul and the Pioneer team. It has been fun. The Tauranga airshow on Saturday will be the last time these two aircraft will be displayed in front of a New Zealand – a bittersweet moment for all involved.
Time seems to have flown by since July 2012 when Strikemaster Ltd first gained Part 115 certification and ordinary New Zealanders were able to experience a flight in these iconic aircraft. Thanks Brett for bringing these two Strikemasters back to New Zealand and giving everyone this opportunity.
Blue Air Training provides contract Close Air Support (CAS) training to conventional and special operations personnel from all branches of military service. In 2015, their Facebook page included a post noting that they had been awarded a contract to provide 1,000 flight hours per year of CAS training for Air Force Special Operations Command (AFSOC) Joint Terminal Attack Controllers (JTACs).
Aviation Safety Management Systems (ASMS) congratulates Quadcam Drones Ltd on the award of Part 102 certification for their UAV operations. Quadcam's services include detailed inspection in the Oil, Gas, Petrochemical and Utility industries, NDVI vegetation surveys and mapping, farm mapping, and general photography and videography.
ASMS is pleased to have prepared Quadcam's exposition and application for certification. Privileges available under the certificate include operating at night, over persons or property, and within low flying zones.
Aviation Safety Management Systems Ltd (ASMS) congratulates Interpine Group on the award of Part 102 certification for their UAV operations.
Interpine Group is the first forestry and/or rural fire related UAV provider to obtain Part 102 certification. Privileges available under the certificate include operating at night, above 400ft AGL, over persons or property, and within low flying zones.
ASMS is pleased to have worked closely with Interpine Group on their certification application. We integrated Interpine Group's existing operating, maintenance, and safety procedures together with procedures that we developed to provide a complete exposition.
For more information see Interpine's post. To see more about Interpine's use of UAVs in rural fire, see this post, this post and associated Youtube clip of a controlled burn.
Aviation Safety Management Systems is pleased to annouce that it is a silver sponsor of the 2017 NZ UAV Industry Conference. Andrew is also presenting in the late morning session on the second day of the conference, giving a talk on his paper Human Harm from a Falling Unmanned Aircraft.
The conference will be hosted at the Auckland University of Technology, 13-14 February 2017. Come and see us at our trade stand and hear Andrew's presentation. Further details on the conference are available here, including a draft conference programme.
If you've visited here before you might notice that things look a little different; that's because we're rebranding!
The typeface is clean, modern, and simple, reflecting our professionalism and the level of clarity we bring to difficult problems. The logo device reflects our aviation heritage, representing a wing (grey) with slats extended (blue).
We're in the process of rolling out our branding across our website, facebook, business cards and stationery. Keep an eye out for our new branding on the next communications you receive from us.
Andrew Shelley was recently interviewed by Patrick Egan of sUAS News.com. Ostensibly about Andrew's recent paper “Human Harm from a Falling Unmanned Aircraft”, the three-part interview covers a wide range of drone-related topics.
You can listen to the podcast here:
Part 1 (16 mins),
Part 2 (32 mins),
Part 3 (37 mins).
At the time of writing, the subject paper tops the most popular papers list of the International Journal of Aviation, Aeronautics, and Aerospace. A brief abstract for the paper is available on the ASMS website, and the full paper is available for download from http://dx.doi.org/10.15394/ijaaa.2016.1120.
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