Skymax supports a registration scheme. We agree that the recreational registration fee should be set low to encourage maximum participation and uptake with the program.
However, regarding commercial operations, we believe the fee structure proposed is too high. As CASA has acknowledged (PP1816U, page 14) the commercial remotely piloted aircraft sector already pays service fees to CASA for operating certificates and permissions on an equitable basis with the remainder of the aviation sector. Considering this and the fact that many commercial operators have several RPAs in their fleet, a registration fee that is charged on an annual basis and per RPA could quickly add up to an amount that materially impacts their business. This would make the scheme burdensome for the industry and could lead to poor compliance and participation rates in the scheme.
CASA states in the Policy Proposal document (PP1816U, page 15) that the indicative higher costs associated with commercial registration is reflective of the higher cost to CASA to appropriately oversight this sub-sector due to the inherently more complex nature of the commercial activities. As true as this statement may be, we do not believe there is enough transparency provided by CASA in the derivation of the cost structure for commercial operators. Taking the example of the US as noted in the consultation document, FAA has set registration fees for both recreational and commercial RPAs at a consistent level of $5 USD/3 years (acknowledging the fact that for recreational users the cost is per person vs commercial use where the cost is per aircraft).
By comparison, the CASA proposed prices for commercial operators is $100-$160/RPA/year which is not only considerably higher than the proposed prices for recreational users, it is also (at a minimum) 60x higher than the prices paid for a similar registration scheme in the US. Acknowledging the issue of economy of scale and the fact that FAA deals with a greater number of RPA registrations, this difference in cost of registration between the two jurisdictions is still significant. We believe at a minimum the registration fee for commercial operators should be set a level which reasonably reflects the actual and reasonable cost of administration.
The cost recovery policy under the Australian Government Charging Framework (the framework) promotes “consistent, transparent and accountable charging for government activities and supports the proper use of public resources”. We are concerned the current indicative pricing is not sufficiently consistent or transparent and therefore fails to satisfy CASA’s obligations under the framework. We understand that CASA is undertaking further work to determine an appropriate fee structure that is consistent with its obligations under the framework.