Transport Canada UAV NPA Review Part 6 – SMALL UAV (COMPLEX OPERATIONS)

For most commercial operators the SMALL UAV (COMPLEX OPERATIONS) would be the category that applies, allowing for the most flexibility in terms of when and where flight operations can be done. It also however is the most involved and seems to fall somewhere between the Restricted Complex and Compliant SFOC processes currently in place.

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.

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.

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 the aircraft to be marked and registered.
  • a unique series of 4 letter registration marks, starting with a specific letter.
  • require persons wanting to register an aircraft 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:

  • require UAV pilots to be properly trained and licensed to assure safe integration within Canadian airspace and hold a pilot permit.
  • issue a pilot permit, versus a pilot licence, as the privileges of the permit would only apply to flight within Canadian domestic airspace.

Specifically, Transport Canada proposes that the following criteria for obtaining a pilot permit:

  • Age –A minimum age requirement of 14 while under adult supervision and 16 without adult supervision. Transport Canada is seeking comments on whether this proposal is considered appropriate for this type of UAV operation.
  • Medical Fitness – A Category 4 Medical Certificate would be required, based on a Self-declaration process. It would be valid for 60 months. This is consistent with other Canadian pilot permits.
  • Knowledge – Pilots would be required to complete a course of instruction in specific aviation knowledge areas and pass a Transport Canada written examination that would be developed specifically for this category of UAV. Training could be provided by a flight training school, a UAV training provider, a third party or be self administered.
  • Experience – Pilots would need to acquire practical training on the category of UAV, including UAV system-specific training. This training may be provided to the pilot by the manufacturer, operator or by a third party, providing the person providing such training held a UAV pilot permit.
  • Skill – Pilots would be required to demonstrate competency in the ability to perform normal and emergency procedures appropriate to the particular type of UAV. Skill tests/proficiency checks would be conducted by qualified UAV operators, manufacturers or third parties.
  • Currency – UAV pilots would be required to maintain currency and proficiency.
  • Privileges – meeting these criteria and the issuance of a permit, would allow a person to be a pilot-in-command of a UAV 25kgs or less, operated within visual line-of-sight within Canadian domestic airspace.


  • manufacturers of a small UAV (complex operations) system 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:

  • always operate within visual line-of-sight through unaided visual contact with the UAV.
  • always give way to manned aircraft.
  • never operate in a reckless or negligent manner
  • operate in visual meteorological conditions.
  • never operate: within Class A and Class B airspace, within Class F Restricted airspace without required permission, within, or in the vicinity of, a forest fire area, at an air show, or o at an aerodrome.
  • advance coordination with the air traffic control.
  • never operate when suffering from fatigue or under the influence of alcohol or drugs.
  • only one UAV operated in flight by a single pilot.
  • operate in accordance with the published UAV operating limitations.
  • do not allow the use of a portable electronic device at the control station.
  • never carry any explosive, corrosive or bio-hazard payloads on a UAV or create a hazard by dropping an object from the UAV.
  • ensure visual observers have reliable communication with the pilot and can perform observation duties for only one (1) UAV.
  • do not allow visual observers to function from a moving surface vehicle.
  • ensure that the UAV System is in an airworthy condition before flight.
  • there must be a means of: controlling and monitoring the UAV, navigating, avoiding other aircraft, terrain and obstacles, lighting the aircraft for night operations, remaining clear of clouds.
  • require liability insurance.
  • always follow a physical and command and control link security plan.
  • the need for the UAV to be properly equipped for the area of operation and the type of operation (e.g. radios, transponders, etc)
  • get permission from the owner(s) of the property on which the UAV intends to take-off from and/or land on.
  • assess the lost link risk before the flight.
  • never operate in areas of high electromagnetic interference.
  • never take off with snow or ice on the aircraft.
  • be familiar with the available information required for the intended flight.
  • comply with Air Traffic Control instructions.
  • remain clear of the take-off, approach and landing routes and the pattern of traffic formed by manned aircraft operating at the aerodrome
  • meet specific communications requirements as detailed in the Canadian Aviation Regulations.
  • notify Air Traffic Control in the case of a UAV fly-away.
  • comply with minimum lateral distance requirements from person, animals, buildings, vehicles, etc.
  • comply with maximum altitude requirements – not above 400 feet above ground level.
  • comply with accident/incident reporting requirements.

One interesting item that only appears in the table chart is “Permission to Fly Over People” is noted for SMALL UAV (COMPLEX OPERATIONS) category, however there are no further details on this in the NPA and it seems to contradict the requirement of lateral distances that is stated for this category.


As with the current Compliant SFOC process, our main concern with SMALL UAV (COMPLEX OPERATIONS) is the impact it will have on the small to mid sized aerial photo and video operators.  The Airworthiness requirements could lead to many UAVs in use currently not meeting the design standards and associated paperwork and thus limit systems to a very few expensive platforms that may not meet the functional needs of many companies for their specific uses.  As the operator is still limited to very tight flight and operational parameters and only within LOS distances we do not see the need for such requirements to be in place, which are much more tailored to full scale aircraft and BVLOS.

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