Transport Canada UAV NPA Review Part 1 – UAV Categorization

To try and make sense of the Notice of Proposed Amendment – Unmanned Air Vehicles announced on May 28 2015, we will be doing a series of reviews to try and break down the specifics into digestible and understandable smaller bites.


To kick things off the NPA introduces 3 new classifications/categorization of operations for Small UAVs (UAVs 25kg and under):

4. CATEGORIZATION OF THE REGULATORY STRUCTURE
The intent of the proposed regulatory effort is to provide a risk-based regulatory regime that encompasses the widest possible range of small UAV operations. To this end, Transport Canada is seeking comments on establishing categories for various types of operations and/or UAVs, as follows

Complex Operations with Small UAVs
Operating small UAVs under this category would be considered to be the most challenging as it would occur in and around urban or built-up areas and allow operations close to aerodromes. This category would have the most comprehensive set of regulatory requirements which, in turn, would provide for the greatest level of safety and operational flexibility.

Limited Operations with Small UAVs
This category would have less regulatory requirements than complex operations due to their lower-risk profile although would be limited to remote areas. This would result in:

  • defining specific geographic limitation around where this category of UAV could operate (e.g. specific distances from aerodromes or built-up areas).
  • adding restrictions on the operation to ensure that these UAVs would not encroach on areas where the operation would create a greater risk

Operations with Very Small UAVs
Transport Canada has considered whether to establish a “lower threshold” or very small UAV category that would be regulated to a lesser extent due to its nature and operating environment, and the lowered risk of damage that the aircraft would cause to a person and property on the ground and other airspace users in case of incident.

The following table gives a general overview of the requirements and restrictions of each:

28-05-2015 7-13-17 PM

Based on the initial quick review of the 3 levels it seems that things are opened up more on the lower end, with a focus on covering recreational as well as real estate and other small scale commercial uses.

It is expected that the vast majority of recreational users would be captured under this category, as well as aerial photography operations for real estate and other small business purposes. As TC expects that all pilots have the requisite knowledge to operate safely, a basic knowledge test would be required, as well as basic identification requirements to assist in accident and enforcement investigations.

The upper end seems targeted to larger commercial operators and the need for trained operators as well as the UAVs meeting defined design standards.

The complex operation category is intended to integrate mature UAV pilots into Canadian airspace by allowing operations in more complex environments with comparable requirements to manned aircraft.

The middle ground appears to be the worst of both worlds and targeted at remote uses only.

The limited operation category is intended to allow operations in remote areas, and would be applicable to agricultural operations, rural aerial surveys, or research in remote and Northern regions.

Based on this we have concerns where the small to mid sized commercial operators in the industry currently will fall, it seems they are somewhat left out and forced to either scale back operations to meet the low end or make larger investment to reach the upper.

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