Coordinating with Nav Canada & ATC for UAV flights in controlled airspace has always been part of UAV operational procedures. Typically it requires 24-48 hours notice, which for the most part works well enough, although it can lead to issues around weekends and holidays when last minute jobs come up.
However under the new proposed regulations this is now pushed to 7 days, which is not acceptable or realistic for most operators.
902.58 No pilot shall operate a small unmanned aircraft in controlled airspace unless the following information is provided to the provider of air traffic services in the area of operation at least seven days before a proposed operation:
- (a) the date, time and duration of the operation;
- (b) the type and registration of the aircraft, including aircraft capabilities and physical characteristics;
- (c) the vertical and horizontal boundaries of the area of operation;
- (d) the route of the flight to access the area of operation;
- (e) the proximity of the area of operation to manned aircraft approaches and departures and to patterns of traffic formed by manned aircraft;
- (f) the means by which two-way communications with the appropriate air traffic control unit will be maintained;
- (g) the contact information of the operator of the aircraft;
- (h) the name, contact information and pilot permit number or licence number of the pilot-in-command of the aircraft;
- (i) the procedures and flight profiles to be followed in the case of a lost command and control link;
- (j) the procedures to be followed in emergency situations;
- (k) process and the time required to terminate the operation; and
- (l) any other information required by the provider of air traffic services required for the provision of air traffic management.
This is not acceptable and makes UAV operators second class citizen within aviation. There needs to be an effective, timely, and easily accessible means to file for flights in controlled areas. Manual submissions via email a week in advance is too slow and open to error and delay. This is one of the major show stoppers in the proposed regulations in our view.