We received the following update on Transport Canada UAV VLOS Operations Clarification
Recent interpretation from headquarters allows for more flexibility with regard to visual observers. Please reference the direction below from headquarters UAV specialist Mark Wuennenberg.
As requested we are providing the following clarification of the guidance provided in the current Staff Instruction regarding the requirements for a UAV to be operated within Visual Line-of-Sight (VLOS)
To begin we provide the current SI guidance.
Visual Line of Sight (VLOS) –means unaided (corrective lenses and/or sunglasses exempted) visual contact with the aircraft sufficient to be able to maintain operational control of the aircraft, know its location, and be able to scan the airspace in which it is operating to decisively see and avoid other air traffic or objects.
(a) A visual observer is a crew member assigned and trained to perform duties associated with the provision of sense and avoid, such as continuously monitoring the UAV and the airspace (e.g. for other traffic, clouds, obstructions and terrain) both around and sufficiently beyond the UAV. For operations within VLOS, a visual observer(s) will be required unless a safety case can be provided that shows how the risks can otherwise be mitigated.
(b) The primary task of the visual observer is to provide the PIC with information to manoeuvre the aircraft clear of any hazards and any potential collision with ground obstructions or air traffic. Additionally, the visual observer must assist the UAV pilot to comply with applicable SFOC conditions, such as flight visibility and cloud clearance requirements and keeping the aircraft within VLOS. The visual observer must be able to see the aircraft and the surrounding airspace throughout the entire flight. They must be able to determine the aircraft’s relative altitude, flight path, and proximity to all aviation activities and other hazards (e.g. terrain, weather, structures) sufficiently to prevent the aircraft from creating a collision hazard.
The intent of the above guidance is to allow the use of visual observers, in lieu of the pilot maintaining visual contact with the aircraft, in situations where the pilot must focus on the ground station to effectively fly the UAV and/or to allow the extension of the operational area by using several visual observers to provide direction to the pilot as to when and where to maneuver the aircraft and provide the sense and avoid function.
This activity remains visual line-of-sight as the visual observer maintains visual contact with the aircraft and the surrounding airspace.