Routine Agricultural Drone Operations

Certify the person. Register the drone. Notify the operation. Report the events.

Ag drones are the biggest potential improvement to on-farm productivity since aerial topdressing. With this in mind the government has come up with a solution for Routine Agricultural Drone Operations (RADO). RADO is a new pathway that replaces bespoke certification with standardised competency, aircraft, operating conditions and regulatory oversight.

RADO will lift farm efficiency by removing the biggest bottleneck in agriculture: time. It allows farmers to deploy solutions the instant they are needed, bypassing mud, weather, steep slopes and the slow setup of heavy machinery.

The Agricultural Drone Association has spent some time discussing how the new RADO pathway could be delivered. We’ve had lots of feedback from our members and the industry since the announcement and that feedback has been pulled together, so anyone can read it, use it, argue with it or improve it.

What RADO needs to achieve

Keep people, property and the environment safe.

Deliver real economic, safety, environmental and productivity gains.

Utilise the agrichemical rules already in place.

Create genuine monitoring and compliance, with consequences that rise with the risk.

Have clear conditions so operators know exactly what’s required to comply.

Be simpler for the operator and stronger for the regulator at the same time.

Be timely. Certification that is too slow, costly or complex doesn't just restrict productivity. It can drive activity outside the system. A system that makes compliance timely, clear and achievable, while holding operators to a high standard, is a safer system.

What the routine in RADO means

Routine means a standard agricultural operation where the aircraft, pilot and operating conditions conform to a prescribed set of conditions. Where the risks are known, the controls can be known and repeatable. That is the basis of the RADO pathway. A routine agricultural operation should have its safety case established once nationally, rather than reconstructed hundreds of times through individual Part 102 applications.

Standard pilot

One national competency standard, held by the person, and portable between employers. It would have the following three parts.

Pilot Certificate. A test of the CAA rules, has the ability to assess risks for an operation and can show an examiner they can competently fly a large agricultural drone.

Chemical certification. Built to CAA's own AC61-16 syllabus. Ten modules, an exam, and a five year currency. That syllabus already covers classification and formulation, toxicology and exposure routes, PPE and safe handling, calibration and dispersal systems, weather and drift assessment, decontamination, record keeping, emergency procedure, and the hazardous substances law that sits over all of it.

Agricultural Rating. Assessed in the field on real application work, with an instructor watching real jobs before being signed off to work alone. Renewed yearly with a competency assessment.

This pathway can be delivered and assessed by the Part 141 organisations already doing this work under CAA oversight.

Limited Night work (early morning or late afternoon to capture low wind) and terrain constrained (momentarily beyond sight while on an automated flight) work could sit on top as endorsements, earned individually and kept current.

Standard Drone

Commercially produced, and on an accepted list of makes and models built from type assessments performed by CAA approved organisations.

Maintained to the manufacturer's schedule and airworthiness standards, in its unmodified configuration, with the records to show it.

Registered, so that every machine doing this work is a machine the regulator knows about.

Standard Operation

A defined agricultural operating area, under the control of the operator or the client engaging them, with everyone present briefed and involved.

Daylight and within sight of the pilot as the everyday baseline, extended where a pilot holds the endorsements above. Automated agricultural drone operations inside a defined area under supervision fit comfortably within that.

The substances that belong in agricultural application, applied under the same agrichemical rules that govern every other method. Labels, regional plans, hazardous substances law and NZS 8409 continue to run the ground side of this work, and they should.

A hazard assessment done by the pilot on the site, on the day, using a method that is the same for everybody. Clear Pre Defined Risk assessments and Standard operating Procedure that can be iterated on as new understanding or innovation arise.

Non standard operation such as lifting or building wash may not be included. If it doesn’t match the Standard Operation Procedures or Pre-defined risk assessments it likely doesn’t fit the standard operation model.

Standard method. The piece ADA are building

Every operator in this country should be able to open one document and know how an agricultural drone operation is performed properly. The Agricultural Drone Association is writing it.

One national operations manual for standard agricultural drone work, written by the people who have the most experience. It covers operating limits for wind and weather, permissions for roads, rail, conservation land and airspace near aerodromes, airspace checks. Pre-flight planning and the assessment you carry out on site. Briefings for everyone present. Normal, abnormal and emergency procedures. Chemical application, covering buffers, take-off and landing zone security, geofencing the ground risk area, neighbour notification, record retention and compliance with NZS 8409 and the regional plan. Maintenance schedules by aircraft type. Records, and what gets reported and to whom.

Alongside it, one pre-defined risk assessment. The hazards that turn up on every agricultural job get worked through once, nationally, with the likelihood, the consequence and the required controls already set. The operator reviews it and adopts mitigations that are correct for the work in front of them.

It is kept current and when the industry learns something, one amendment goes out to every operator. Adopt the SOPs and the pre-defined risk assessments and they define the operation you notify.

Anything that varies from the RADO standards above is better suited to a bespoke assessment under Part 102.

How you notify

One declaration, made once, before you start. Not per job as we need a system that works at volume.

Three things go in it. The aircraft and its maintenance. The pilot and their training currency. The operation you are notifying, being the SOPs and pre-defined risk assessments you have adopted.

An operator identifier comes back, you go on the register, and get to work. You need to update CAA when something material changes.

How it gets monitored

A live register of operators, aircraft and pilots. For the first time we will see how many machines are working and who is flying them.

There is a strict duty to keep records of what was applied, where, when, by whom and on what aircraft, and to produce them when the regulator asks.

A duty to report defined events.

Risk based and random audit against those records, resourced properly from day one. Move regulatory effort from approving paperwork to monitoring operations.

And a graduated response where the consequence rises with the risk presented, escalating automatically for anyone who keeps getting it wrong.

Certify the person. Register the drone. Notify the operation. Report the events.

What it looks like in practice

A trained pilot with current credentials, flying a machine from the accepted list that is maintained and registered, working a defined block in daylight, applying product under the same chemical rules as always, having assessed the site that morning against a national method, keeping the records as they go, and available to be audited at any time.

What next

This is a genuine opportunity and it does not come along often. New Zealand has land that needs this technology, a large agricultural sector, a regulator willing to look at the problem properly. We also have an Ag Drone industry that has already proved to be safe and sensible with repeatable operations.

Built well, we end up with the most practical Ag drone framework in the world, a workforce trained to one standard everywhere, and a regulator with a clearer view of this sector than most regulators have managed anywhere.

New Zealand invented aerial topdressing. We can lead this too. There is design work and consultation ahead. ADA doesn't expect to have every answer, and we don't expect everyone to agree with every detail. But the principles should be difficult to disagree with: competent pilots, known aircraft, clear operating limits, proper chemical controls, good records, active oversight and consequences when people get it wrong. If we can agree on those outcomes, the remaining job is designing the simplest system that reliably delivers them.