Story Updated: 13/01/2023

Unmanned Aerial Spraying Systems (UASS) AKA Spray Drones, UAV, RPAS) have been entering the spotlight over the last 5 years. Multirotor UASS systems in particular have been adopted by some farmers and contractors due to some proven capabilities in specific situations.

The growing interest in drones continues and the biggest question from the industry has surfaced as how can landowners and contractors learn to use this new technology legally and effectively.

Pictured: XAG P30 crop protection UAV with R150 Unmanned ground vehicle

Advantages of UASS operations

  • Precision application to a broad range of cultivations. In some scenarios drones have been good follow up treatments to broadacre spraying operations. After a short survey mission, drones can be quickly sent out to target areas to spot spray.
  • Limiting compaction of soil Not driving over the target areas mean that soil is no longer compacted.
  • Dispersal of treatment through dense canopy When used correctly the downdraft from the UASS disperses the product through the dense crop canopy. UASS have also been known to be able to perform effective applications into tree canopy’s due to their downward force.
  • Boggy Water logged surfaces. Traditional ground based equipment can be risky over waterlogged cropping areas after storms or based on crop types such as rice fields. UASS are much more adept for jobs over boggy terrain which can easily bog groundrig equipment.
  • Smaller Farms It is harder for larger sprayers to enter into some smaller paddocks which require treatment, often a separate application type needs to be brought in to get into some hard to cover areas with wider booms.
  • Difficult to access terrain: UASS can apply where ground rig spray equipment is risky or unworkable. UAV have already proven themselves in clearing infestations of Lantana and Prickly Pear as well as some vertical mountain side/Dam face weeds with forward facing application equipment. Traditionally these areas were only accessible by foot, or by operators with climbing gear.
  • Cost savings over traditional manned aerial application: UASS have shown that they are more cost effective due to their ease of transport to treatment areas as well as targeted application. Multirotor UASS are also more maneuverable around some obstacles which would normally make manned aerial application too dangerous, such as trees or powerlines.
  • Swarm Application: Some UASS like the XAG P30 have been endorsed for their use in swarm operation. This means that productivity increases can be harnessed through the use of multiple UASS operating simultaneously with an autonomous flight plan.
  • Drones for monitoring and surveying Drones have been adopted largely in monitoring activities on farms due to their rapid deployment and relatively powerful photogrammetry surveying hardware and software. When used effectively, UASS can be used to monitor crop health, paddock health, weed infestations, cattle numbers, drainage areas, facility health and many more asset based activities.

Pictured: XAG P30 being setup for swarm operation.

Disadvantages of UASS operations

  • Limited legal compliance Not all chemicals may be applied by aerial application and chemical labels are primarily referencing fixed wing and single rotor aircraft. It is important to understand that the label is a legally binding document. Some chemicals have specific restraints against application by aerial equipment. In many cases Label registrants and the APVMA are still working together to come up with specific label requirements for multirotor UASS which means several operators are applying under “off label” permits.
  • Shared Airspace Drones share the same airspace as manned aviation. Airspace Is strictly governed in some areas around airports. Job planning can take much longer due to planning and CASA air services approvals.
  • Visual Line of Sight – VLOS Although drones are capable of working in autonomous flight plans, for safety reasons CASA for safety and compliance reasons, still requires visual line of sight to be maintained.
  • Meterological conditions affecting both the UASS and the application. Multirotor UASS drift dynamics are affected largely by wind conditions at the application site moreso than traditional ground rig operations. The research and modeling of drift models is still in its early stages. Operators do not yet have readily available training which helps them understand specific drift risks caused by aerial application.
  • Difference in standard equipment Not all drones are created equal. Some systems on the market lack standard equipment normally found in some newer spray systems to ensure efficacy of application. As an example some models on the market do not hold consistent pressure which can mean that ISO nozzle flow rates are not consistent throughout application.
  • Training Pathway is non linear and not facilitated by any single course structure or organisation. This makes it hard for operators seeking which will ensure they are competent and legal by the end of the process.

Training Pathway

ChemCERT have done some investigation to try and provide a general pathway to help guide operators in the right direction to ensure they have everything they need to apply chemical from a drone with all the knowledge and legalities covered.

What are the primary governing bodies that affect drone application?

There are several state and federal acts and laws which affect drone application but the primary governing bodies for drone use and chemical use are as follows:

State Authorities

State Environmental Protection Agencies

  • Each state has different training, licencing and record keeping requirements for aerial application records. In most states ChemCERT provides the required training which is required to apply for state specific operator licences. In the case where harm to humans or the environment by chemical application is committed the EPA will investigate all parties.

Federal Authorities

CASA – Civil Aviation Safety Authority

  • The Civil Aviation Safety Authority is a government body that regulates Australian aviation safety. CASA license both manned and remote pilots, register aircraft, oversee and promote safety. The use of UAV is governed strictly by the Civil Aviation Safety Authority – CASA. Drone operators must be trained, licensed, adhere to airspace rules and keep all required flight records. UAV service providers (companies operating for fee or reward) must demonstrate their operating procedures to ensure they are compliant prior to being allowed to trade. Incidents resulting in injury damage to property or invasion of privacy are investigated by CASA.

APVMA – Australian Pesticides and Veterinary Medicine Authority

  • The Australian Pesticides and Veterinary Medicines Authority (APVMA) supports innovation and the development of new technologies that assist Australian growers and ensure the continued protection of the health and safety of people, animals and the environment
  • They have a clearly defined role as the regulator of agricultural and veterinary (agvet) chemicals in Australia. The APVMA is an independent statutory authority responsible for assessing and registering pesticides and veterinary medicines proposed for supply in Australia. All pesticide registrations and labeling requirements which includes aerial application considerations are investigated by the APVMA prior to approval for use in Australia.
  • The Organisation for Economic Co-operation and Development (OECD) working group established in June 2019 by the OECD Working Party  on Pesticides (WPP) is responsible for the development of regulatory requirements in this area.
  • APVMA Spray drift management findings are shared on their dedicated page here 

Pictured: XAG P30 Crop Protection UASS

Licensing and Requirements to Operate UASS

Because of the size and risk of most agricultural drones used for spraying. Very specific licensing is required to ensure the operator is trained to a specific standard before they may operate. Below is a quick summary of the steps ChemCERT recommends to operators wanting to use drones in their operations. There is a difference in requirements for landowners operating over their own property.

ChemCERT is continuing to monitor the UAV industry space while it continues to develop some useful drone applicator resources which will hopefully facilitate the safe use of UAV application technology.

1. CASA Basic Drone Training <25kg

Aviation Reference Number (ARN) or Organisational ARN. This is a quick and easy to obtain number for the purposes of all training going forward. Find out more

Remote Pilot License (RePL) and AROC aeronautical Radio Operators certificate

Licensing up to 25kg weight class.

If you have your RePL, you can:

  • be employed as a remote pilot for an individual or business that holds a ReOC, or apply for your own ReOC
  • fly a drone more than 25kg but not more than 150 kg for commercial purposes over your own land, without a ReOC.

A RePL does not expire. There is no minimum age to get a RePL Find out more

2. Chemical Accreditation Training

ChemCERT Accreditation

Required units:

  • AHCCHM307 – Prepare and Apply Chemicals to Control Pest, weeds and Diseases
  • AHCCHM304 – Transport and Store Chemicals

Successful completion of the necessary units* allows participants to apply for state specific licenses. To ensure users are continuing to use current best practice, ChemCERT recommends training every 5 years.

*Additional units may be required to apply for state specific licenses / endorsements

Find out more

3. CASA Manufactuer Endorsement Training 25kg> – Fee or Reward

Type Endorsement – Instrument approval (Drones above 25> kg)

Drones above 25 kg require additional assessment by CASA if they are being flown for fee or reward.

You must complete a type specific endorsement training program which consists of both theory and practical (5 hours of command flight minimum). Often the manufacturer of the drone will provide training on the drone and systems, and then a CASA delegate will assess your ability to fly the drone safely.

Drones over 25kg are classified by “Type” and if moving from one model to another, separate endorsement will need to be completed on that new model.

Exceptions:

Drones <25 KG

Do not require type endorsement and are covered under the RePL up to 25kg.

Landowners or private landholder excluded category

You can fly a drone weighing more than 25kg but not more than 150 kg over your own land for business or as part of your job, provided you do not accept any type of payment for the services. Operators still require a basic RePL and must fly within the standard operating conditions Find out more

4. RPA Remote Operator’s Certificate (ReOC)

A remotely piloted aircraft operator’s certificate (ReOC) allows you or your business to trade as a drone service provider including the hiring of RPA pilots for operations. It is effectively a collection of documentation covering all of the companies operating procedures. Using your training in risk management with both UAV and Chemical application, a comprehensive ReOC can be developed.

A ReOC permits your business to conduct a range of remotely piloted aircraft (RPA) operations—subject to approval by CASA—that are not available to other operators such as swarm flight and vertical spraying operations. Find out more

5. State EPA Licences

Each State environmental protection agency has separate licensing requirements for employers and employees carrying out RPA/UAV aerial chemical application.

In most cases, applicants will need to apply for the licence via their State EPA website and provide:

  • RePL license information
  • Chemical Training Units statement of attainment
  • Pay the licensing fee

In cases where an aerial applicator company operates cross boarder, licensing in both states will be required.

Visit your state EPA to find out more

6. Insurances

Liability Insurance of a minimum of 20 million dollars is highly recommended and even required for work in some municipalities. The level of insurance should match the type of work being completed by the company.

7. CASA Registration of Drones

Drone Registration

Registration for drones, or remotely piloted aircraft (RPA), flown for business or as part of your job is required.

Some drones don’t need to be registered now. This applies if:

  • you don’t intend to fly your drone
  • you’re only flying for sport or recreation, including model aircraft flown at CASA-approved model airfields.

Registration is:

  • free
  • quick, easy and online
  • valid for 12 months
  • required from 28 January 2021.

Find out more

For any questions about drone training requirements for your state please email enrol@chemcert.com.au. Our team will do their best to help guide students in the right direction.

Prepared by Harris Karatzetzos – Chief Technology Officer

Background: Harris has undertaken the drone training pathway since early April firstly attaining his RePL and further endorsement training on the XAG P30 Crop protection UAV. He is continuing to combine knowledge and resources from ChemCERT’s training to create a specialized drone supplement which will help new operators gain the critical knowledge to help them spray safely and legally.