Allen William REYNOLDS

Auckland
New Zealand

19 February 2017

Civil Aviation Authority of New Zealand

Dear Sir or Madam

Official information request: Aviation Safety and RPAS (Remotely Piloted Aircraft Systems – ‘drones’)

Please supply the following information under the Official Information Act (OIA):

The objective of the Civil Aviation Authority (CAA) is to undertake its safety, security, and other functions in a way that contributes to the aim of achieving an integrated, safe, responsive, and sustainable transport system.

The CAA introduced new rules in late 2015, Parts 101 and 102, to “better manage safety risks of RPAS” (CAA Vector magazine May/Jun 2015, page 3).

So, how’s it going?

CAA has urged the community to report –
Vector Sep/Oct 2015, page 23 - Reporting RPAS Occurrences
To fully understand the threats that RPAS pose, the CAA needs you to report RPAS occurrences. You can report them online, as you would for any other event, but in the description, describe the other aircraft encountered as an RPAS

CAA indicates some 121 reports in 2015 -
Vector Jul/Aug 2016, page 25 - Correction
In the article “Reporting Drone Occurrences” in the March/April 2016 Vector, we reported that there were 198 occurrences involving drones reported to the CAA in 2015. Unfortunately, duplications were not removed from this figure and the correct figure is 121. We apologise for this error.

A news item indicates at least 172 reports to late 2016 -
‘Drone complaints soar as flying machines get cheaper, more popular’ – Stuff, John Weekes, Last updated 19:09, December 22 2016
“…complaints about drones to the Civil Aviation Authority soared from 33 in 2014 to 172 thus far in 2016…”
http://www.stuff.co.nz/national/87864070...

So, specifically –
- can we please see reports, of Accidents* and Incidents* involving RPAS, reported to CAA (* - per the Civil Aviation Act)
- can we please see reports, of Occurrences involving RPAS, to CAA that fall outside the Act
- can we please see reports involving RPAS, “of what the CAA calls “Aviation Related Concerns” (ARCs)” - (Vector May/Jun 2015 page 13)

- with reporting by both civil aviation participants, and/or by members of the public (including manned fliers, unmanned fliers, and non-fliers)

- for the periods 2014, 2015, 2016
- for the period to date of 2017

- an acceptable response would be to post these reports on the CAA website, in a similar manner to the Safety Reports section of the Accidents and Incidents page -
https://www.caa.govt.nz/accidents-and-in...

listing –
- date and time
- location
- RPAS details
- other aircraft details
- nature of the incident, including details of people, and any injuries…
- agencies involved – eg. CAA, Police, TAIB, military…
- outcomes – eg. Court case, fines, not found…

If you need any more information from me please let me know as soon as possible.

I understand that a decision on a request for information under the OIA should be made within 20 working days of receiving that request.

If you do not normally deal with official information requests, or you need advice on dealing with this request, guidance is available from the Ombudsman at www.ombudsman.parliament.nz.

Yours faithfully

Allen Reynolds

Dear Tom Wheeler,

what does CAA wish to discuss 'off the record'?

Yours sincerely,

Allen Reynolds

Dear Tom Wheeler,

my initial request suggests a suitable response, and the data requested

it follows the same format as the Safety Reports section of the Accidents and Incidents page, as posted on the CAA website

it may be preferable for you to prioritise - Occurrences involving death first; then injuries; then property damage - major, minor... and so forth

after all, there are hundreds of Occurrences reported

Yours sincerely,

Allen Reynolds

Dear Tom Wheeler,

sorry, one more point - military reports and Occurrences - feel free include these too

I know of at least one, an aircraft on descent to Ohakea (I think) spotted something...

Yours sincerely,

Allen Reynolds

Dear Tom Wheeler,

good to see CAA are onto this - I refer to Vector magazine, Jan/Feb 2017, page 16
'New Sport ‘n’ Rec Manager Greg Baum'

the last para says, in reference to the new RPAS rules -
“Also, because these rules are new, it’s wise for the CAA to be evaluating their effectiveness – what is the impact on safety, are they having the desired effect?"

my very points

Yours sincerely,

Allen Reynolds

Dear Tom Wheeler,

Commentary on CAA Data
Summary

The CAA RPAS Data is wholely unsuitable, in toto, to inform on aviation/RPAS safety. Much work is needed to edit, to sort, and to glean reliable, accurate data from the listing.

The quality ranges from the vague – many “RPAS operation concerns”; thru the bizarre – “drones are causing the complainant's house to vibrate”; to RPAS not at fault – “Aircraft performed a touch and go on a runway that was closed, occupied by people and vehicles, was marked with white crosses, and had an AIP supplement and Vector item published” - that's a crewed aircraft in breach, not an RPAS.

Serious events are recorded – the ‘6000-foot drone’ out of Christchurch; a power line strike in Whangarei; and several more.

But, there are duplications – the ‘6000-foot drone’ ex Christchurch; a possible sighting from an A320 into Auckland; cruise ship filming in Wellington; and another.

And errors – the Martin Jetpack is listed once, possibly twice, yet at 200 kg is well over the 25 kg limit for Part 101 or 102 operation, and both were safe landings. Others…

And omissions – another high-voltage power line strike near Fairlie, similar date to Whangarei event, is not listed; what else is missing?

And uncertainty – property owners report ‘drones nearby’, perhaps filming, but the Data does not indicate the action was legitimate, or not. There are just three mentions of the Airshare flight logging service; how many filming, or close-to-aerodrome reports, etc, were legal, booked thru Airshare? Airshare claims 50 flights per week in the Whenuapai Zone alone; and 25,000 nation-wide in 2015 and 2016… Is CAA cross-checking?

And, the CAA claim of 121 Occurrences in 2015 (Vector) is incorrect; as they include 78 ARC’s (‘Concerns’ like the ‘vibrating house’; generic/vague ‘concerns’; etc) in the total. Of their eleven Incidents (INC) since the new Rules, ten are non-breaches – non-required, self-reporting of crashes - into fence, lake, tree, sea; the Martin Jetpack twice; a video and a sighting wrongly coded, compared to similar reports. The two Wellington fly-aways are potentially INC’s – incorrect failsafe settings. Result : 1 (or 3) of 11 correctly coded.

Good news – no deaths; no serious injuries; no aircraft damage or structural failures; no aircraft missing or completely inaccessible – “Accidents [ACC]” in CAA parlance. And only one case of stones being thrown at an RPAS. More good news - no collisions at all, with aircraft, people or property, unless you count fences, trees or bushes.

There has been an increase in reports - 102 for the 19 months prior, against 280 reports for the 19 months after the New Rules. Whether this reflects changes in flier behaviour, the increased availability of RPAS, or raised awareness in the general public remains to be determined.

I believe the CAA Data best indicates an on-going need for improved education – of NZ resident RPAS fliers; of visiting overseas fliers; of crewed aviation; and of the public in general, a lot of whom seem to equate ‘drone’ with ‘illegal’, with no basis in fact.

Yours sincerely,

Allen Reynolds

Dear Civil Aviation Authority of New Zealand,

Commentary 2 – Date and Time Inaccuracies

The date/time data, in the CAA RPAS ‘New Rules’ Data, is unreliable, rendering it unusable in its present form.

The times do not make sense; day and night are likely switched, mostly -

More than a quarter of reports are logged as 0:00 to 0:59, ‘midnight’ (73 of 280 reports).
And, a further 61% are logged as nominal night time reports, 21:00 to 8:59, excluding ‘midnight’, (171 of 280).
So, 87% are ‘at night’, 244 reports; with barely 13%, 36-of, in ‘daylight’, 9:00 to 20:59.

Yet, only 8% of reports describe night flying, 22-of.

And, actually seeing an RPAS at night is tricky, let alone being awake (and outdoors) at all hours.

Other time issues – several events are reported twice, at different times

example :
25/09/2015 3:40:00 a.m. Large object… observed operating at a high altitude
25/09/2015 5:50:00 a.m. …close proximity of an A320 climbing out of Christchurch

This is the ‘6000-ft drone’ near Chch, with two reports 2 hours apart – duplication
And the flight was not at 3:40 AM either – unlikely to see the RPAS in the dark

Date issues - several events are reported twice, on different dates

example :
11/11/2015 8:17:00 a.m.
lost GPS contact… West of Wellington… last seen flying… towards Wellington city centre

15/11/2015 7:00:00 a.m.
at Wrights Hill Fortress [Wellington]… Lost GPS lock on… departed towards the city centre

Two near identical INC’s within four days – either, the operator ‘replicated the error’, or perhaps the report was duplicated

Finally, it is not even clear if the date/time represents the event, or the reporting, for any reports.

Yours faithfully,

Allen Reynolds