Transport Canada UAV NPA Review Part 5 – SMALL UAV (LIMITED OPERATIONS)

The SMALL UAV (LIMITED OPERATIONS) seems to fit in where the current Exemptions are targeted, for rural applications outside populated areas.

This category would have less regulatory requirements than complex operations due to their lower-risk profile however they would be limited to more remote areas, resulting 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.

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.

UAV Operator Certificate Requirements:

  • an adequate management organization;
  • a method of control and supervision of flight operations;
  • pilot training programs;
  • security procedures;
  • a maintenance control system;
  • a company operations manual;
  • standard operating procedures.

Aircraft Marking and Registration:

  • require small UAVs for limited operations to be marked and registered.
  • a unique series of 4 letter registration marks, starting with a specific letter.
  • require persons wanting to register a small UAV for limited operations to meet the qualifications to be a registered owner of a Canadian aircraft
  • not require this category of UAVs to have an aircraft identification plate.

Personnel Licensing and Training:

  • not required for pilots of the proposed Small UAV (limited operations) category to obtain a pilot permit or medical certificate.
  • no minimum age requirement, min 16 without adult supervision.


  • manufacturers of UAV systems for the Small UAV (limited operations) category be required to declare that the UAV system meets a design standard for UAV systems for this category.
  • not require type certificates or production approvals; or issue a flight authority (i.e. Certificate of Airworthiness).

General Operating and Flight Rules:

In addition to some of the rules proposed in the Small UAV (complex operations) category:

  • operate only during the day.
  • comply with a maximum airspeed limit of 87knots.
  • never operate in Class C, D, E or F airspace.
  • comply with a specified minimum distance from aerodromes*.
  • comply with the minimum distance of 5nm (9 km) from built-up areas (cities, towns or villages).
  • comply with maximum altitude requirements – not above 300 feet above ground level.

* Transport Canada is considering two (2) options with regard to the minimum distance from aerodromes that small UAVs (limited operations) should be permitted to operate.

Approach 1 would mirror the current exemptions that were provided for lower-risk UAV operations and established a minimum distance of 5nm (9 km) from any aerodrome.

Approach 2 is based on the principal of prohibiting the operation of small UAVs (limited operations) within controlled airspace, including control zones. To accommodate the largest control zones in Canada, this proposal would be to restrict operations within 11 nm (20 km) of any aerodrome.

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