NPA

UAV NPA Comments & Feedback

commentsThe following are our comments and feedback sent to Transport Canada as part of the Notice of Proposed Amendment – Unmanned Air Vehicles process.

1. APPLICABILITY
Applicability to UAVs under 25kg and flown LOS makes sense and is in line with the context of the NPA and regulations to date. Main concern is ensuring it encompasses ALL usage of UAVs, both commercial and recreational which currently the regulations do not.

One area that should also be addresses is special use cases such as with first responders where proximity to accidents/fires/etc is part of the operational use.  Including this in the new regulations would make things easier for these groups to make use of UAVs as opposed to having to do an external process or special SFOC.

2. MODEL AIRCRAFT
The issue of model aircraft vs UAVs and recreational vs commercial use is a tricky one but a current grey area/loophole that needs to be addressed.

Tying the classification to having a camera payload is not a good approach in that it links it to very specific technology.  As the industry and devices evolve it may not be a “camera” that becomes the payload of choice, some new sensors or other payloads may become the common application so we feel it is best to not link the regulations to such a specific element.

If the focus of the regulations are around safety then the regulations should apply regardless of how it is being used.  A recreational user is within the same airspace as a commercial user. As such most of the same regulations and guidelines should apply.

We would like to see a licensing/permitting system similar to small pleasure craft or automobile licensing where in ALL operators require to take some sort of test to ensure a minimum level of knowledge on safety and proper use.

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Transport Canada UAV NPA – Get Your Comments In!

commentsOn May 28th 2015 Transport Canada released the Notice of Proposed Amendment – Unmanned Air Vehicles outlining proposed new regulations for UAVs in Canada. As part of the process there are a series of rountables across the country with key stakeholders and a period for comment to get feedback from the industry.

Transport Canada invites stakeholder comments through this Notice of Proposed Amendment that the
department will share with members of the Canadian Aviation Regulation Advisory Council
comprised of approximately 570 representatives of aviation associations, airlines, manufacturers,
maintenance organizations, airports, provincial and federal departments, foreign aviation safety
authorities and unions.

In recognition that the target audience for this consultation is broader than the aviation industry, Transport Canada also invites members of the public to comment. Transport Canada will:
– publicize this NPA on its social media channels (Twitter and Facebook).
– consider comments as it proceeds with drafting the amendments to the regulations and standards.

Transport Canada will then publish proposed regulations in the Canada Gazette, where stakeholders and Canadians will have the opportunity to provide additional comments.

I urge everyone involved in the Canadian UAV industry to get your comments in ASAP.  Transport Canada wants to hear from the industry and it’s participants and this is our opportunity. The more feedback they get the better they can tailor the new regulations to address the needs and concerns of everyone.

Speak up now, it is your chance to have a say and be heard.

We will be submitting and posting our comments to the blog in the coming weeks.

NPA comments need to be submitted by August 28 2015, after this date, Transport Canada will not consider comments for further revisions to the regulations and standards.

They must be sent to carrac@tc.gc.ca

Alternate Presentation of TC NPA for UAVs

unmannedAlternate Presentation of the Notice of Proposed Amendment (NPA) for Unmanned Air Vehicles

By: Kris Ellis Director – Unmanned Systems Canada

On May 28th 2015 Transport Canada released a Notice of Proposed Amendment (NPA) to establish comprehensive and accelerated rulemaking for unmanned aircraft not exceeding 25 kg that are operated within Visual Line of Sight (VLOS). The NPA spans 33 pages with much of the material being redundant across the three classes of UAV operation. Objectives:  This document attempts to present the NPA material with alternative formatting in order to better highlight the differences between the three proposed categories of UAV operations. It is hoped that this document will serve as a starting point for understanding the full scope of the NPA and therefore generate more informed feedback and comments.  Additionally, this document has been prepared to highlight the areas where Transport Canada has specifically requested feedback and comments. This document presents an objective and impartial re-presentation of the NPA material. Unmanned Systems Canada is undertaking a parallel effort to develop an opinion and comment document in order to initiate and focus discussion surrounding the proposed rules and the specific areas in which Transport Canada requests feedback.

View the full document here.

Transport Canada UAV NPA Review Part 2 – VERY SMALL UAV (LOWER THRESHOLD)

The VERY SMALL UAV (LOWER THRESHOLD) can be seen in a lot of ways as bringing the recreational UAV sector under the proposed regulations, and opening up some small scale commercial use.

Transport Canada is considering whether to establish a “lower threshold” or very small UAV category that would be regulated to a lesser extent due to its nature and operating environment, and the lowered risk of damage that the aircraft would cause to a person and property on the ground and other airspace users in case of incident.

It is expected that the vast majority of recreational users would be captured under this category, as well as aerial photography operations for real estate and other small business purposes. As TC expects that all pilots have the requisite knowledge to operate safely, a basic knowledge test would be required, as well as basic identification requirements to assist in accident and enforcement investigations.

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:

  • UAVs NOT required to be registered.
  • Required to have permanent marking for identification (e.g. pilot name and contact information) on their UAV operating in this category.

Personnel Licensing and Training:

  • not required for pilots to obtain a pilot permit or medical certificate
  • no minimum age requirement, min 16 without adult supervision
  • required to demonstrate aeronautical knowledge in specific subject areas, such as airspace classification and structure

Airworthiness:

  • UAVs not required to meet a design standard.
  • required to follow any maintenance instructions provided by the manufacturer.
  • required to conduct a pre-flight check to ensure that the aircraft is in a fit and safe state for flight before take-off.

General Operating and Flight Rules:

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

  • daytime only.
  • uncontrolled airspace only.
  • 5nm (9 km) from aerodromes .
  • maximum altitude 300′ AGL.
  • no restrictions in regards to built-up areas.

Transport Canada UAV NPA Review Part 1 – UAV Categorization

To try and make sense of the Notice of Proposed Amendment – Unmanned Air Vehicles announced on May 28 2015, we will be doing a series of reviews to try and break down the specifics into digestible and understandable smaller bites.


To kick things off the NPA introduces 3 new classifications/categorization of operations for Small UAVs (UAVs 25kg and under):

4. CATEGORIZATION OF THE REGULATORY STRUCTURE
The intent of the proposed regulatory effort is to provide a risk-based regulatory regime that encompasses the widest possible range of small UAV operations. To this end, Transport Canada is seeking comments on establishing categories for various types of operations and/or UAVs, as follows

Complex Operations with Small UAVs
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.

Limited Operations with Small UAVs
This category would have less regulatory requirements than complex operations due to their lower-risk profile although would be limited to remote areas. This would result 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

Operations with Very Small UAVs
Transport Canada has considered whether to establish a “lower threshold” or very small UAV category that would be regulated to a lesser extent due to its nature and operating environment, and the lowered risk of damage that the aircraft would cause to a person and property on the ground and other airspace users in case of incident.

The following table gives a general overview of the requirements and restrictions of each:

28-05-2015 7-13-17 PM

Based on the initial quick review of the 3 levels it seems that things are opened up more on the lower end, with a focus on covering recreational as well as real estate and other small scale commercial uses.

It is expected that the vast majority of recreational users would be captured under this category, as well as aerial photography operations for real estate and other small business purposes. As TC expects that all pilots have the requisite knowledge to operate safely, a basic knowledge test would be required, as well as basic identification requirements to assist in accident and enforcement investigations.

The upper end seems targeted to larger commercial operators and the need for trained operators as well as the UAVs meeting defined design standards.

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.

The middle ground appears to be the worst of both worlds and targeted at remote uses only.

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.

Based on this we have concerns where the small to mid sized commercial operators in the industry currently will fall, it seems they are somewhat left out and forced to either scale back operations to meet the low end or make larger investment to reach the upper.