Proposed Canadian UAV Regs Review – Still No LiDAR Allowance

Under existing regulations the use of laser payloads, such as LiDAR requires a special approval from Health Canada as well as a “special” SFOC for such use.

This will not change in the proposed new regulations, laser devices such as LiDAR will still require an SFOC, and are excluded under the new regulation primary allowances.

900.26 No person shall operate an unmanned aircraft if the aircraft is transporting explosive, corrosive, flammable or biohazardous material or a payload consisting of a directed bright light source as defined in section 601.14 or a payload that can be jettisoned, self-propelled, dispersed or dropped unless the operation is conducted under a special flight operations certificate — UAS issued under section 904.03 and the pilot may conduct an operation set out in subsection 902.51(2).

This is in our view short sighted by Transport Canada, given the growing industrial use of LiDAR on UAVs and the fact many are eye safe devices, used without restriction on ground based vehicles already.


One of the growing uses of the UAV platform for industrial applications is carrying  LiDAR to provide for aerial high resolution mapping.  Utilizing a LiDAR payload under an SFOC however does require some additional paperwork & approval, as laser devices are an exception to most standard SFOCs, ie it cannot simply be attached and flown as would a more traditional camera or sensor.

As per the Staff Instructions:

6.6 Authorization for the Use of Lasers

Before a Certificate applicant can operate a UAV fitted with laser equipment, the applicant has to complete a “Notice of Proposal to Conduct Outdoor Laser Operation(s)” and submit it to a TC office…

An aeronautical assessment is then conducted and the documentation is forwarded to Health Canada who validates the Nominal Ocular Hazard Distance calculated by the applicant in the “Notice of Proposal to Conduct Outdoor Laser Operations” form submitted. The normal process time is at least 30 days to review the notification and determine if a laser authorization can be issued.

There are no exceptions to the requirement for this process. For example, even if the aircraft is going to be fitted with a short-range laser rangefinder to act as an altimeter the equipment on the aircraft could cause a hazard to aviation safety therefore an assessment is required.

Refer to sections 601.20 (Projection of Directed Bright Light Source at an Aircraft), 601.21 (Requirement for Notification) and 601.22 (Requirement for Pilot-in-command) of the CARs for further guidance.

Basically to carry a LiDAR based payload, a separate NOTICE OF PROPOSAL TO CONDUCT OUTDOOR LASER OPERATION(S) form must be submitted with the SFOC application, which is passed on to Health Canada for review. This additional process takes at least 30 days.

In addition, specific SOPs for the safe deployment and usage of the LiDAR system should be part of the operator’s operational documents.

From our recent research and discussions with Transport Canada on this matter they recognize the growing usage of these payloads and a more streamlined approach is being developed to allow for easier implementation of LiDAR systems on UAVs. The new approach being discussed would be the establish a list of approved LiDAR devices, that have already gone through the Health Canada process, which could then be utilized by operators without the additional paperwork other than filing for an SFOC with a known device. There is no timeline for when this may be put in place. At this time the process is as noted above as per the Staff Instructions.