3.4 Operating Beyond the SOC: Approvals and the ReB1

When an Approval Is Needed

The standard operating conditions (SOC) are the baseline limits within which most drone flights must stay. Any operation that wants to exceed one of these limits needs a CASA approval or authorisation. The common cases that trigger an approval are:

• Night operations — flying at night, meaning between the end of evening civil twilight and the beginning of the following morning civil twilight. Note the shortcut here: CASA has already issued a night approval (CASA 01/17) to all ReOC holders, so an operator whose documented practices and procedures adopt the CASA sample night procedures does not need a separate night application. Operators wanting to depart from those procedures, or to fly a large RPA at night, apply through the RPAS multi-purpose form.
• BVLOS (Beyond Visual Line of Sight) — flying the RPA beyond the pilot's unaided visual line of sight.
• Above 120 m (400 ft) AGL — flying higher than the standard height limit.
• Over populous areas — flying over areas where people are gathered or where it would be hazardous to fly in the event of a failure.
• More than one RPA — a single pilot operating more than one RPA at the same time.
• Reduced distance — operating closer than the SOC distances (for example, closer than 30 m to uninvolved people, or closer to aerodromes than the SOC allows).

These approvals are held by the ReOC, not by the individual RePL holder. The ReOC is the operator that has demonstrated to CASA the procedures, equipment, and competency to conduct the higher-risk operation. The RePL pilot flying the operation must be trained and assessed competent for that specific operation under the ReOC's procedures.

This is why a RePL holder cannot, on their own licence, decide to fly at night or beyond VLOS — those privileges exist only where a ReOC holds the approval and the pilot has been signed off under it.

The Approval Process

The approval process generally involves:

1. Application to CASA by the ReOC, describing the operation, the RPA, the procedures, and the risk controls.
2. Form 101-09 — RPA Flight Authorisation, the CASA form used for above-400 ft approvals and for approvals to operate inside an aerodrome no-fly zone. For a civilian controlled aerodrome, CASA recommends submitting at least 60 days before the planned operation so it can liaise with Airservices Australia.
3. A review of local aviation traffic with appropriate mitigators — CASA expects this explicitly for above-400 ft applications.
4. A NOTAM may be required as a condition of the approval so that other airspace users are aware of the operation. It is not an automatic requirement of every application.
5. Pilot training and competency assessment under the ReOC for the specific operation (night, BVLOS, etc.).

Some controlled aerodromes participate in an automated airspace authorisation trial, where operators apply through a CASA-verified drone safety app and receive near real-time approval. Form 101-09 does not apply to flights under the trial — but the trial cannot authorise operations above 400 ft, which must still go to CASA.

CASA may issue the approval with conditions — for example, a maximum height, a geographic boundary, a requirement to monitor a radio frequency, or a requirement to carry specific equipment such as an electronic conspicuity device or transponder.

The ReB1 Examination

The ReB1 is the CASA examination for BVLOS theory, made under instrument CASA 35/23. A RePL holder who intends to conduct BVLOS operations outside an enclosed space must hold a pass in at least one of:

• an aeronautical knowledge examination for an instrument rating under Part 61;
• the former instrument theory examination (IREX) under Part 5 of CAR 1988;
• for operations wholly outside controlled airspace (OCTA), the beyond visual line of sight exam under CASA 35/23 — the ReB1; or
• an alternate exam approved under CASR 101.300(4)(a)(iii) (none currently exist).

Alternatively, the flight may be conducted under a supervising remote pilot who meets the requirement. Note the scope limit that catches candidates out: the ReB1 covers OCTA BVLOS only — BVLOS inside controlled airspace needs the instrument-rating-level examination. Passing the exam is only one part of the authorisation: the ReOC must still hold the BVLOS approval, and CASA currently grants BVLOS to approved operators on a case-by-case basis.

The Key Principle: Included Can Be Approved, Excluded Cannot

A central rule of the framework is that included operations can exceed the SOC only with an approval, while excluded-category operations must stay within the SOC and cannot be approved beyond it. This is the trade-off for the lighter regulatory burden of the excluded categories: in return for not needing a RePL or ReOC, the operator accepts the SOC limits without the ability to extend them.

Consequence:

• A sub-2 kg commercial operator who needs to fly at night cannot do so under the excluded category — they must either operate under a ReOC that holds a night approval, or not fly at night.
• A ReOC operator with the relevant approvals can fly at night, BVLOS, above 120 m, over populous areas, or with multiple RPA, subject to the conditions of those approvals.

This principle explains why operators with commercial ambitions beyond the SOC move from the excluded categories to a ReOC: the ReOC unlocks the approvals needed to exceed the SOC, while the excluded categories are deliberately capped at the SOC.

Summary of Approval Triggers

For an excluded-category operator, none of these approvals are available — the SOC is the ceiling.