Aerobotika Aerial Intelligence (AAI) is encouraged by the efforts of Transport Canada (TC) to involve the greater community in the development of Unmanned Aerial Vehicle (UAV) regulation. The comments contained within this response reflect the opinions of our team which includes recreational RC pilots with 50+ combined years of experience and manned aircraft pilots with 20+ combined years of experience.
Applicability
The regulations should cover all uses of aircraft and vary in depth according to risk, rather than just purpose, as proposed. Regulations that would take place of the SFOC requirement is needed for aircraft sub 25 kg. The current system is too cumbersome and places barriers to entry by the workload imposed on Transport Canada and the Operators alike.
Model Aircraft
Model aircraft have long been operated safely at MAAC fields, governed by their regulations. For this reason, Approach 1 is a better method by which to define model aircraft.
In addition, AAI suggests there be a provision within the regulations whereby recreational operators can fly over private property or property for which they have received permission, with first person view (FPV) devices, or without.
Terminology and Definitions
AAI is on board with the aircraft being referred to as UA, UAS, RPA and RPAS in the new regulation so long as it is understood that UAV and drone are likely to remain commonplace throughout the industry for some time.
Categorization of the Regulatory Structure
AAI recognizes and agrees with the proposed risk-based regulatory structure. This structure places safety at the forefront rather than basing the structure on commercial vs. recreational operations.
The following comments discuss the subtopics associated with the proposed regulations for Small UAV (Complex Operations), Small UAV (Limited Operations) and Very Small UAV.
UAV Operator Certificate Requirements
AAI agrees with Transport Canada’s requirements for adequate management organization, method of control and supervision of flight operations, pilot training programs, security procedures, maintenance control system, a company operations manual and standard operating procedures for all levels of operation. This brings UAV operations in line with other manned commercial operations.
In regard to feedback on criteria for a UAV operator, AAI believes the number of employees should not be the terminology which is used. Crew is better suited to UAV organizations and avoids foreseeable negative industry effects. Less reputable organizations may try to get around regulation by hiring contractors, rather than employees, and operators could be discouraged from hiring the appropriate number of employees for their organization. AAI believes this change in terminology fits well with the second suggested criteria for an operator; companies who hire persons in commercial UAV enterprises.
In summary, AAI believes UAV operators should be determined based on number of crew, companies who hire persons in commercial UAV enterprises and/or companies with a large scope of operation. “One man show” operators must have provisions in their company materials outlining training for the other required crew members on site.
Aircraft Marking and Registration
AAI proposes all aircraft, regardless of the size or application, should be, at minimum, when operated outside of a MAAC field, identified with a permanent marking such as a metal plate detailing pilot name and contact information. The aircraft registration process should be required for all small UAV, as proposed, and made as straightforward as possible to encourage operators to register their aircraft. If assigned, the aircraft’s unique TC issued registration or identification number should also be inscribed on the metal plate.
Personnel Licensing and Training
Pilot Permit
AAI agrees with the proposal to require all UAV pilots to receive proper training, meeting minimum knowledge requirements, to assure safe integration within Canadian airspace. Operators of Small UAV (Complex Operations) should be required to hold a pilot permit and associated medical. The named criteria to hold a pilot permit is satisfactory in most areas. Suggestions to modify the Medical Fitness requirement is listed below.
- Medical Fitness
The piloting of unmanned aircraft is a much more accessible type of flying. TC should ensure it remains this way by modifying the requirement for pilots to hold a Category 4 Medical. Pilots who have physical disabilities, for example, and who may be deemed unfit to fly manned aircraft by the Category 4 medical standards, may have no issue operating an unmanned aircraft from the ground. Additionally, provisions in the Category 4 Medical Certificate do not necessarily satisfy safety requirements for operators of UAV. For instance, there is no colour blindness test, which can affect an operator’s ability to maintain orientation at a distance on their multirotor.
Proposed Content of Knowledge Subject Areas
In the opinion of AAI, TP15263E does not cover all materials that UAV operators should be familiar with. The listed items in the NPA document are good, but still lack general aircraft knowledge.
- Flight Instruments
Content should include all available telemetry options as well as information on the functionality and purpose of MEMS sensors.
- Meteorology
Content should be approached from a practical standpoint ensuring operators know what weather products and services are available. There shall also be essential theory knowledge for weather affecting the relative lower levels of the atmosphere (1000’ and below) and hazards operating in mountainous regions.
- Human Factors
Items such as operating environment, stress, psychology and physiology shall be approached from a UAV operator standpoint, not copied from manned aircraft text. They must reflect UAV operator situations.
- Theory of Flight
Ensure basic principles of flight are covered for fixed wing, multirotor and helicopter as well as co-axial setups. Operators need to be aware of C of G performance and stability given the growing base of DIY-ers.
- General Knowledge
Basic information on all components such as servos, batteries, propellers, motors, electronic speed controllers, power distribution boards, etc. should be covered.
- Radio Theory and Licensing
All Small UAV operators (Complex Operations) should require the Industry Canada Restricted Operator Certificate- Aeronautical.
It should be clear that anyone intending to use HAM frequencies, such as for FPV, require a HAM license.
AAI would very happily join the conversation with the personnel tasked in developing required knowledge topics and provide our curriculum to aid in the development.
Flight Training
Transport Canada states it is the pilot’s responsibility to ensure they obtain proper training and experience in order to safely operate their aircraft within Canadian airspace. The proposal to not certify flight training units or schools that provide theoretical or flight training to UAV operators and their crews is a major lapse. In an effort to create safe, well integrated airspace users, TC should ensure there is training available which is certified to meet minimum standards.
Training organizations should be given the opportunity to be certified. Otherwise, it is left to the UAV operator to attempt to determine if the course will provide what is required by TC, which is difficult, if not impossible, to do prior to attending.
In addition, if TC mandates a standardized exam, there needs to be standardized curriculum and a format to monitor schools to ensure appropriate content is being taught.
Curriculum, content and other teaching materials should be provided to Transport Canada for review if a training organization wishes to be certified. TC inspectors shall be welcome on an ongoing basis to attend the courses offered by certified training organizations.
Other operators may be allowed to offer training, but not be called certified. This gives schools that have made significant investments in developing curriculum and course structure the ability to distinguish themselves from the rest, lending to industry recognition. It also allows for consistency in training and the ability for TC to enforce industry standards as the industry continues to evolve. TC should have procedures in place giving themselves the authority and ability to shut down unsafe operators.
Aircraft Maintenance Engineers and Maintenance Requirements
AAI agrees with TC’s proposal that maintainers of UAV shall not require licensing nor the aircraft require a flight authority. However, we believe it should be stated that anyone who conducts maintenance on their aircraft must do so in accordance with any information provided by the manufacturer. Some manufacturers state the aircraft must be returned to a manufacturer approved facility for maintenance after a number of flights or at flight hour intervals. Ex. DJI Inspire 1.
When operating with interchangeable payloads, a provision should exist to ensure the operator performs checks to ensure the aircraft remains airworthy after the payload swap. These procedures should include, but are not limited to, gimbal calibration, rebalancing, aircraft calibration, and confirming there is no interference in sensor operation.
General Operating and Flight Rules
AAI respects the intention of TC in imposing specific operating limitations. Suggested amendments are listed below.
- Include a provision to limit operations in the area surrounding natural disasters in a similar method to that already in place regarding forest fires
- Include a provision for the pilot to operate FPV, perhaps by requiring an additional crew member who keeps the aircraft in VLoS and has the ability to take control at all times
- Require operators in at least the Complex Operations category to hold Industry Canada’s Restricted Operator Certificate in the Aeronautical Application
- Require operators of FPV equipment or those intend to utilize +25 mW to hold a HAM radio license
- Allow operators to operate at an aerodrome with permission from ATC unit and aerodrome operator
For Small UAV (Limited Operations), AAI believes that neither approach 1 nor 2 in regard to distance from an aerodrome are satisfactory, or necessary. If aircraft in this category are restricted from class A, B, C, D, E and F then the aerodrome restriction is satisfied without any additional regulation.
Additionally, TC should seek to clarify the definition of “built-up area” to ensure operators have a clear understanding for safe areas of operation.
Special Flight Operations Certificate
The SFOC process will work well to encompass operations that do not fall under the above categories.
Foreign Operators
AAI believes the approach outlined in respect to foreign operators is satisfactory. Operators falling in the category of Very Small UAV should be required to pass an online PSTAR type exam to ensure they understand the boundaries of their operation.
Click to read Transport Canada’s Notice of Proposed Amendments.
