21/08/2026
Great post. We agree that the definition of “routine” will be an important part of the defining the new rule
There has been a lot of discussion online regarding the Agricultural Drone Rules Reform. The announcement was clearly aimed at the general public, rather than professional certificated operators who already understand the risks and safety requirements associated with agricultural UAS operations. It was simplified for a broad audience, so we need to look beyond the headline and consider what they are actually trying to achieve.
Part 102 is a non-prescriptive, performance-based rule set. It was designed around the unknown: a way to enable rapid technological development within a structured aviation regulatory system. It is not simply “the drone rules”. It is a flexible, risk-based framework intended to enable new unmanned technologies, where an operator tells the CAA what they want to do and demonstrates how the associated risks will be managed.
That is Part 102’s greatest strength. You can do almost anything, provided you can establish a credible safety case. That is its purpose...., and I think this is sometimes forgotten or misunderstood.
However, the industry has evolved. Many Part 102 applications are no longer about genuinely new technology or novel operations. They are increasingly the same types of operations being submitted again and again, simply because Part 102 is the only suitable rule framework currently available.
That also exposes Part 102’s greatest weakness: every application must be individually assessed by the CAA, even where it is substantially the same as one they have already assessed. Whether you are a farmer, a contractor, or an aerospace engineering organisation, everyone goes through essentially the same process.
Agricultural drone operations are never entirely routine, but the risks are no longer unknown.
What the Ministers are actually proposing (underneath the election-year language) is to move standard private agricultural drone operations conducted on a farmer’s own land out of Part 102 and into a dedicated rule framework.
That does not mean deregulation. It does not mean “send it”. It means developing a prescriptive, tailored rule set in which requirements such as training, airworthiness, maintenance, insurance, operating limitations, and occurrence reporting are defined by the rules, rather than being proposed individually by each operator and assessed by the CAA every time.
In other words, it is intended to create a risk-proportionate regulatory framework for a specific and increasingly common type of operation.
I also raised an eyebrow when I first read the announcement. Words such as “routine” and “low risk” are subjective and do not properly capture what is being discussed. I cannot even think of a correct phrase for it: essentially, it is the same type of operation, involving known and manageable risks, being requested repeatedly from a regulator administering a deliberately non-prescriptive rule part. I can see why they settled on “routine”.
I like the word “licensed” (hint hint to the rule makers), but the reality is that we do not yet know exactly what the framework will look like. That is what consultation is for. This is where industry has the opportunity to help shape a pathway that enables farmers to use agricultural drone technology on their own land while maintaining an appropriate level of safety.
Some contractors may initially see the announcement negatively and worry that farmers doing the work themselves will reduce commercial opportunities. I see the opposite.
Making drone technology a normal, recognised agricultural tool will grow the overall market. Most farmers do not particularly want to become drone pilots; they want the job done properly. There is still an element of, “Ahhh, technology… I’m not sure about that.” A clear regulatory pathway helps shift the perception from uncertainty to, “That’s simply how this job is done... I’ll call the contractor.”
Ministers cannot come out and explain all of the above in an announcement aimed at the general public because most people would understandably respond with, “What?” It is also an election year, so the language was always going to be broad and "exciting".
The eventual rule framework will be shaped through consultation and developed with the CAA. It should be proportionate to the actual risks involved. As Part 102 operators, we already understand the training, oversight, airworthiness, maintenance, and operational controls required for these aircraft. Does anyone genuinely believe we are going from that.... to picking up an agricultural drone from Kmart and heading straight out to spray?
In no world is that the future.
This has the potential to be smarter regulation, not deregulation. The consultation process is the place for industry to make sure safety is properly represented and embodied in the final framework.
Also, a shameless plug: SPS Automation agricultural drones are New Zealand-made, fly for more than an hour, and are genuinely awesome. They provide precise chemical application for targeted spot-spraying operations.
When you buy one ([email protected]) make sure you add a leather jacket and a pair of Ray-Bans to your PPE. 😎