Alternative Maintenance Plan for Small COTS UAS

In plain language

If your small off-the-shelf drone does not come with a manufacturer maintenance plan, CAA NZ expects you to perform pre-flight and post-flight checks, along with an annual inspection conducted by an experienced person.

Requirement as structured

CAA NZ states that for smaller commercial off-the-shelf (COTS) UAS without a manufacturer maintenance plan, an acceptable alternative maintenance plan must include a pre-flight check, a post-flight check, and an annual inspection by a suitably skilled and experienced person.

Original regulatory text

Ongoing maintenance mitigates the risk of malfunction, so operators need procedures that demonstrate how their UAS will be maintained. For COTS UAS, following the manufacturer’s recommended maintenance schedule is often acceptable. Not all UAS come with a manufacturer’s recommended maintenance schedule, however, and the robustness of manufacture’s schedules also vary. An alternative for smaller COTS UAS that have not come with an acceptable maintenance plan would be: • a pre-flight check • a post-flight check, and • an annual inspection (by someone suitably skilled and experienced) to check all aspects of the UAS. Many operators nominate an external maintenance provider for the annual inspection. The UA sales agent or other industry experts can often help operators find one, as can CAA. For large or complex UAS that have: • more perishable components (filters, hoses) • more mechanical parts (oil or fuel systems, retractable arms and landing gear), or • separate and exchangeable role equipment the manufacturer usually provides a more detailed recommended maintenance schedule that may have lifed components or timed checks (e.g., every 50 hours). When a robust manufacturer’s maintenance plan is provided, CAA expects it to be followed. If an alternative is proposed, CAA expects the operator to demonstrate why that will give an equivalent or higher level of assurance. For UAS that are not COTS (i.e. homebuilt or modified UAS) the applicant will need to provide maintenance procedures proportionate to the risks and scope of the intended operations. Operators who do not have experience in designing an acceptable UAS maintenance programme are strongly recommended to engage an appropriately qualified and experienced consultant.

Applies when

operation

VLOS/BVLOS