CASA births its Part 101 Drone Manual of Standards: the high-level Need-to-Know on this crucial legislative instrument

Published: 27 April 2019


CASA has finally birthed its Part 101 Drone Manual of Standards 2019 (MOS). 188-pages of content more sizzling than the snags at a school fete, which can be accessed here.

For those of us that are thought-rich yet time-poor, here’s the big picture Need-To-Know on the MOS.

Note that if you are a drone training organisation or certified drone operator then you will need to know the MOS like the lyrics to your favourite song. Alternatively, speak with a consultant or lawyer to guide you through the regulatory swamp, lest you end up like Artax in the NeverEnding Story.


The MOS commences on the day of registration: 9 April 2019, however only the following 2 provisions take effect on 9 April:

[a] Beyond Visual Line of Sight (BVLOS) or Extended Visual Line of Sight (EVLOS) operation requirements; and

[b] certain provisions requiring that notifications be given to the Civil Aviation Safety Authority (CASA).

Implementation of the remaining provisions is delayed for 12 to 18 months to enable drone operators, and in particular drone training organisations, to prepare for the transition. I will be writing more on the immediately applicable Standards in another article shortly.


The MOS covers 4 main areas:

[1] drone pilot and teacher training and competency;

[2] airspace use and restrictions;

[3] EVLOS / BVLOS operations; and

[4] essential record keeping and notifications.

Here is an overview of these 4 main areas:

[1] Training and competency

[a] The MOS introduces formal aeronautical knowledge and practical competency standards for the issue of a Remote Pilot Licence (RePL), as well as setting qualifications for RePL training instructors.

[b] Drone training organisations must develop training courses covering prescribed units of competency that must be successfully completed by RePL (or other drone qualification) applicants.

[2] Airspace use and restrictions

[a] The MOS aims to provide sufficient protection for piloted aircraft operations and flexibility for certified drone operators in the vicinity of controlled aerodromes. This includes the ability to receive a standing approval for operations within no-fly areas of a non- controlled aerodrome.

[3] BVLOS / EVLOS operations

[a] The MOS tends to use ‘Extended Visual Line of Sight’ (EVLOS) yet makes some reference to ‘beyond VLOS’ but not ‘BVLOS’ per se. I’ll use the in-vogue ‘EVLOS’.

[b] While drone operations must generally be conducted within VLOS of the drone pilot, the MOS has requirements to facilitate the granting of CASA approvals for certified drone operators to conduct EVLOS class 1 and 2 operations.

[c] Note: class 1 EVLOS operations are when the pilot and the observer are in the same location; class 2 EVLOS operations are when the pilot and observer are in different locations.

[d] You need to jump through more hoops than a lion at Stardust Circus to obtain EVLOS approval, however this is a necessary burden and it’s encouraging to see the procedures in place to facilitate EVLOS flights. This has HUGE potential and I can’t wait to see the growth from this.

[4] Essential record keeping and notifications for certain drones

[a] The MOS sets out FML training and record-keeping requirements for drone operators.

[b] CASA has provided some alleviations for some less complex drone operations by single-person holders of a remote operating certificate (ReOC holders).


What a time to be alive! These are exciting times in the drone industry in Australia. The concerted effort to get this MOS off the ground demonstrates the significance of drones to commerce, the community and the economy.

I look forward to the application of drones facilitated by the MOS.

As always, please be in touch if you have any questions or comments.

Fly Free!

The Drone Lawyer.

27 April 2019