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TP 14371E
RPA—REMOTELY PILOTED
AIRCRAFT
Transport Canada
Aeronautical Information Manual
(TC AIM)
OCTOBER 7, 2021
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TC AIM October 7, 2021
TRANSPORT CANADA AERONAUTICAL INFORMATION MANUAL (TC AIM)
EXPLANATION OF CHANGES
EFFECTIVE—OCTOBER 7, 2021
NOTES:
1.
Editorial and format changes were made throughout the
TC AIM where necessary and those that were deemed
insignificant in nature were not included in the “Explanation
of Changes.”
2.
Effective March 31, 2016, licence differences with ICAO
Annex 1 Standards and Recommended Practices, previously
located in LRA 1.8 of the TC AIM, have been removed and
can now be found in AIP Canada GEN 1.7.
3.
The blue highlights in the manual represent the changes
described in this section.
RPA
(1) RPA 2.0 Micro Remotely Piloted Aircraft
Systems (mRPAS)—Less Than 250 g
Information was added regarding the modification of
a micro RPA.
(2) RPA 3.2.3.2 Controlled Airspace
A reference to NAV
CANADA’s drone flight
planning tool was added.
(3) RPA 3.2.15.3 Identifying Classes of Airspace
A reference to NAV
CANADA’s drone flight
planning tool was added.
(4) RPA 3.2.37 Incidents and Accidents
The text was amended to reflect the text found in the
Ca
nadian Aviation Regulations (CARs). The section
on reporting RPA incidents and accidents to TC when
an RPA is operated under an SFOC—RPAS has been
modified.
(5) R PA 3.2.38 Tethered Drone
The text was amended to clarify the circumstances
u
nder which a tethered drone is not considered an
RPA. The text has also been amended to take into
account a sufficient safety margin in order to mitigate
the risks of injury or damage in the event of a tethered
drone/RPA accident.
(6) RPA 3.4.3 Manufacturer Declaration
A reference to Advisory Circular
(AC) 922-001—
RPAS Safety Assurance was added.
(7) RPA 3.4.4 Operations in Controlled Airspace
A reference to NAV
CANADA’s drone flight
planning tool was added.
(8) RPA 3.4.5 Operations at or in the Vicinity of an
Airport or Heliport—Established Procedure
A reference to NAV
CANADA’s drone flight
planning tool was added.
(9) RPA 3.4.8 RPA Modification
This new section was added in reference to
AC
922-001.
(10) RPA 3.5.3 Conduct of Flight Reviews
Information was added regarding the conduct of a
flight review and also about the use of an sRPA.
(11) RPA 3.6.1 General
A reference to Subpart
3 of Part IX was added to
coincide with the text found in the CARs.
(12) RPA 3.6.2 Application for a Special Flight
Operations Certificate (SFOC)—RPAS
Two references were added, one to AC
903-001—
Remotely Piloted Aircraft Systems Operational Risk
Assessment (R PAS ORA) and one to AC 903-002—
Application Guidelines for a Special Flight
Operations Certificate for a Remotely Piloted
Aircraft System (SFOC—RPAS).
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Table of Contents
RPA—REMOTELY PILOTED AIRCRAFT 429
1.0 GENERAL INFORMATION ............................................................................................................................... 429
2.0 MICRO REMOTELY PILOTED AIRCRAFT SYSTEMS (mRPAS)—LESS THAN 250 g ......................... 429
3.0 SMALL REMOTELY PILOTED AIRCRAFT SYSTEMS (sRPAS)—250 g TO 25 kg .................................. 430
3.1 Registration .................................................................................................................................................................................................430
3.1.1 Modifying a Registration ........................................................................................................................................................... 430
3.1.1.1 Cancelling a Registration ........................................................................................................................................................... 430
3.1.1.2 Change of Name or Address ....................................................................................................................................................... 430
3.2 General Operation and Flight Rules ........................................................................................................................................................ 430
3.2.1 Line-of-sight .............................................................................................................................................................................. 430
3.2.1.1 Visual line-of-sight (VLOS)....................................................................................................................................................... 431
3.2.1.2 Radio line-of-sight (RLOS) ........................................................................................................................................................ 431
3.2.2 Emergency Security Perimeters ................................................................................................................................................ 431
3.2.3 Airspace ...................................................................................................................................................................................... 431
3.2.3.1 Canadian Domestic Airspace ..................................................................................................................................................... 431
3.2.3.2 Controlled Airspace .................................................................................................................................................................... 431
3.2.3.3 Drone Site Selection Tool ........................................................................................................................................................... 433
3.2.3.4 Inadvertent Entry Into Controlled Airspace .............................................................................................................................. 433
3.2.4 Flight Safety ............................................................................................................................................................................... 433
3.2.5 Right of Way and Risk of Collision ........................................................................................................................................... 433
3.2.6 Detecting and Avoiding Traffic ................................................................................................................................................. 433
3.2.6.1 General ........................................................................................................................................................................................ 433
3.2.6.2 Seeing Traffic ............................................................................................................................................................................. 434
3.2.6.3 Hearing Traffic ........................................................................................................................................................................... 434
3.2.6.4 Avoiding a Collision ................................................................................................................................................................... 435
3.2.7 Fitness of Crew Members ........................................................................................................................................................... 435
3.2.8 Visual Observers ......................................................................................................................................................................... 436
3.2.9 Compliance With Instructions ................................................................................................................................................... 436
3.2.10 Living Creatures ......................................................................................................................................................................... 436
3.2.11 Procedures ................................................................................................................................................................................... 436
3.2.11.1 Normal Operating Procedures ................................................................................................................................................... 436
3.2.11.2 Emergency Procedures ............................................................................................................................................................... 436
3.2.12 Pre-flight Information ................................................................................................................................................................ 437
3.2.12.1 Pre-flight Inspections ................................................................................................................................................................. 437
3.2.12.2 Fuel and/or Energy ...................................................................................................................................................................... 438
3.2.13 Maximum Altitude ..................................................................................................................................................................... 438
3.2.13.1 Types of Altitudes ....................................................................................................................................................................... 438
3.2.13.2 Measuring Altitude ..................................................................................................................................................................... 438
3.2.14 Horizontal Distance .................................................................................................................................................................... 439
3.2.15 Site Survey .................................................................................................................................................................................. 439
3.2.15.1 Understanding Your Area of Operation ..................................................................................................................................... 439
3.2.15.2 Locating Local Aerodromes and Airports .................................................................................................................................440
3.2.15.3 Identifying Classes of Airspace .................................................................................................................................................440
3.2.16 Other Pre-flight Requirements ................................................................................................................................................... 440
3.2.17 Serviceability of the RPAS .........................................................................................................................................................440
3.2.17.1 Airframe (All Types) ..................................................................................................................................................................440
3.2.17.2 Landing Gear .............................................................................................................................................................................. 441
3.2.17.3 Powerplant................................................................................................................................................................................... 441
3.2.17.4 Propellers .................................................................................................................................................................................... 441
3.2.17.5 Battery—Lithium Polymer ......................................................................................................................................................... 441
3.2.17.6 RPAS Control Station/Receiver/Transmitters ........................................................................................................................... 441
3.2.18 Availability of RPAS Operating Manuals .................................................................................................................................. 441
3.2.19 Manufacturer’s Instructions ....................................................................................................................................................... 441
3.2.20 Control of RPAS ......................................................................................................................................................................... 441
3.2.21 Takeoffs, Launches, Approaches, Landings, and Recovery .....................................................................................................442
3.2.22 Minimum Weather Conditions ................................................................................................................................................... 442
3.2.22.1 Sources of Weather Information ................................................................................................................................................ 442
3.2.22.2 Micro vs. Macro Climate Environments....................................................................................................................................442
3.2.22.3 Wind ............................................................................................................................................................................................ 443
3.2.22.4 Visibility...................................................................................................................................................................................... 443
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3.2.22.5 Clouds.......................................................................................................................................................................................... 443
3.2.22.6 Precipitation ................................................................................................................................................................................ 443
3.2.22.7 Fog ............................................................................................................................................................................................... 443
3.2.22.8 Temperature ................................................................................................................................................................................ 443
3.2.22.9 Sun ...............................................................................................................................................................................................444
3.2.23 Icing .............................................................................................................................................................................................444
3.2.24 Formation Flight .........................................................................................................................................................................444
3.2.25 Operation of Moving Vehicles, Vessels, and Manned Aircraft ................................................................................................444
3.2.26 First-person View (FPV) Devices .............................................................................................................................................. 445
3.2.27 Night Flight ................................................................................................................................................................................. 445
3.2.27.1 Detecting Aircraft During Night Operations ............................................................................................................................ 445
3.2.27.2 Aircraft Lighting ......................................................................................................................................................................... 445
3.2.27.3 Use of Lights ............................................................................................................................................................................... 446
3.2.27.4 Night Vision Goggles .................................................................................................................................................................446
3.2.28 Multiple Remotely Piloted Aircraft (RPA) ................................................................................................................................ 446
3.2.29 Special Events ............................................................................................................................................................................. 446
3.2.29.1 Special Aviation Events .............................................................................................................................................................. 446
3.2.29.2 Advertised Events ....................................................................................................................................................................... 446
3.2.30 Handovers ...................................................................................................................................................................................446
3.2.31 Payloads ...................................................................................................................................................................................... 446
3.2.32 Flight Termination Systems ....................................................................................................................................................... 447
3.2.33 Emergency Locator Transmitters (ELT) .................................................................................................................................... 447
3.2.34 Transponders and Automatic Pressure-Altitude Reporting Equipment ................................................................................... 447
3.2.34.1 Transponder-required Airspace ................................................................................................................................................. 447
3.2.34.2 Transponder Requirements ........................................................................................................................................................ 447
3.2.35 Operations at or in the Vicinity of an Aerodrome, Airport, or Heliport .................................................................................. 447
3.2.36 Records ........................................................................................................................................................................................448
3.2.37 Incidents and Accidents .............................................................................................................................................................. 448
3.2.38 Tethered Drone............................................................................................................................................................................449
3.3 Basic Operations ......................................................................................................................................................................................... 449
3.3.1 General ........................................................................................................................................................................................ 449
3.3.2 Pilot Requirements ..................................................................................................................................................................... 449
3.3.2.1 Pilot Certificate ........................................................................................................................................................................... 449
3.3.2.2 Recency Requirements ............................................................................................................................................................... 449
3.3.2.3 Access to Certificate and Proof of Currency ............................................................................................................................. 450
3.3.2.4 Examination Rules ...................................................................................................................................................................... 450
3.3.3 Small Remote Pilot Aircraft (sRPA) Requirement .................................................................................................................... 450
3.4 Advanced Operations ................................................................................................................................................................................. 450
3.4.1 General ........................................................................................................................................................................................ 450
3.4.2 Pilot Requirements ..................................................................................................................................................................... 450
3.4.2.1 Pilot Certificate ........................................................................................................................................................................... 450
3.4.2.2 Recency Requirements ............................................................................................................................................................... 450
3.4.2.3 Access to Certificate and Proof of Currency ............................................................................................................................. 450
3.4.2.4 Examination Rules ...................................................................................................................................................................... 450
3.4.3 Manufacturer Declaration .......................................................................................................................................................... 450
3.4.4 Operations in Controlled Airspace ............................................................................................................................................ 451
3.4.5 Operations at or in the Vicinity of an Airport or Heliport—Established Procedure .............................................................. 451
3.4.6 Operations Near People .............................................................................................................................................................. 452
3.4.7 Operations Over People .............................................................................................................................................................. 452
3.4.8 RPA Modification ....................................................................................................................................................................... 452
3.5 Flight Reviewers .......................................................................................................................................................................................... 453
3.5.1 General ........................................................................................................................................................................................ 453
3.5.2 Pilot Requirements ..................................................................................................................................................................... 453
3.5.2.1 Flight Reviewer Rating ............................................................................................................................................................... 453
3.5.2.2 Examination ................................................................................................................................................................................ 453
3.5.3 Conduct of Flight Reviews ......................................................................................................................................................... 453
3.6 Special Flight Operations—RPAS............................................................................................................................................................453
3.6.1 General ........................................................................................................................................................................................ 453
3.6.2 Application for a Special Flight Operations Certificate (SFOC)—RPAS ................................................................................ 454
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R PA
RPA—REMOTELY PILOTED
AIRCRAFT
1.0 GENERAL INFORMATION
The following parts of this chapter provide detailed information
for the safe operation of a remotely piloted aircraft system (RPAS).
This information is intended to be used in conjunction with
regulations and associated standards found in Part IX of the
Canadian Aviation Regulations (CARs). Part IX rules apply
regardless of the purpose of the RPAS use (e.g. recreational,
commercial, work, research).
This chapter has been organized to follow the order in which
information is described in Part IX of the CARs with a description
of the regulation, ways to meet the regulation’s objective, and
additional related information.
While an RPA refers to the aircraft vehicle itself, RPAS includes
the aircraft as well as the related system components – battery,
payload, control station, and command and control (C2) link.
As RPA is defined as a navigable aircraft under CAR 101.01 -
Subpart 1, other sections of the CARs may also apply, such as
CAR 601.04 and 601.16, and section 5.1 of the Aeronautics Act.
These regulations restrict the use of airspace to all “aircraft”.
For more information, refer to RAC 2.8.6 Class F Airspace in
the Transport Canada Aeronautical Information Manual (TC AIM).
The Part IX of the CARs is enforced by delegated peace officers
such as a member of the Royal Canadian Mounted Police (RCMP)
or by Transport Canada (TC) inspectors and investigators. TC
is also partnering with other provincial and municipal law
enforcement agencies to obtain delegation to enforce Part IX.
Refer to TC AIM LRA 6.4 for more information on monetary
penalties and to CAR 103 Schedule II, where they are designated
and listed.
In addition to Part IX and other regulations in the CARs, other
regulations apply when an RPAS is flown. The provisions of
the Criminal Code could apply if an individual is creating
mischief, fatigued, flying under the influence of alcohol or
drugs, or endangering the safety of people or an aircraft. Other
rules such as the Privacy Act, the Personal Information Protection
and Electronic Documents Act, or provincial privacy legislation
may also apply. Be respectful of people’s privacy. It is a good
practice to let people know you will be flying in the area and
what you are doing with your RPA; you should also obtain an
individual’s consent if you are going to record private information.
Privacy guidelines can be found online at <www.canada.ca/
drone-safety>.
Be mindful of other laws that may apply to drone flying like the
Species at Risk Act, Marine Mammal Regulations, Migratory
Birds Regulations, etc.
2.0 MICRO REMOTELY PILOTED
AIRCRAFT SYSTEMS (mRPAS)—LESS
THAN 250 g
Micro remotely piloted aircraft systems (mRPAS) are made up
of a remotely piloted aircraft (RPA) weighing less than 250 g
and its control station. The weight of the control station is not
factored in to the weight calculation when determining whether
an RPA is a micro RPA (mRPA) (< 250 g) or a small RPA (250 g
to 25 kg). However, the weight of any payload carried by the
RPA, such as an optional camera, a lens filter, pegs, propeller
guards, stickers, and lights, will be considered part of the total
weight. The micro RPA could thus reach 250 g or more and be
made in the category of small RPA (sRPA) from 250 g to 25 kg
and have to comply with Subpart 1 of Part IX of the Canadian
Aviation Regulations (CARs), requiring, among other things,
an RPA registration and an RPA pilot certification.
If an mRPA is modified or has accessories added that bring the
weight up to or over 250 g (such as propeller guards), the sRPA
shall be registered under CARs Part IX. The registration is done
in the Drone Management Portal (DMP), by selecting the option
“The drone was built using either a kit, off-the-shelf or custom-
built parts.” Once registered, the sRPA may be used in the conduct
of a Flight Review, taking into account that it will not have an
RPAS Safety Assurance declaration to operate in controlled
airspace or close to people. If the sRPA is de-modified back to
its original sub 250 g version, then the RPA shall be de-registered
in the DMP and is again an mRPA.
Pilots of mRPAS are not subject to Subpart 1 of Part IX of the
CARs, so they are not required to register their RPAs or obtain
a certificate to fly them. However, they must adhere to CAR 900.06
and ensure they do not operate their RPA in such a reckless or
negligent manner as to endanger or be likely to endanger aviation
safety or the safety of any person. While there are no prescriptive
elements of the regulation that inform the pilot how to accomplish
this objective, there is an expectation that the pilot of an mRPA
should use good judgment, identify potential hazards, and take
all necessary steps to mitigate any risks associated with the
operation. This should include having an understanding of the
environment in which the RPA pilot is operating, with particular
attention paid to the possibility of aircraft or people being in the
same area.
As a rule of thumb:
(a) Maintain the mRPA in direct line of sight;
(b) Avoid flying your mRPA above 400 ft in the air;
(c)
Keep a safe distance between your mRPA and other people;
(d)
Stay far away from aerodromes, water aerodromes, and
heliports;
(e) Avoid flying near critical infrastructure;
(f ) Stay clear of aircraft at all times;
(g) Conduct a pre-flight inspection of your mRPA;
(h) Keep the mRPA close enough to maintain the connection
with the remote controller;
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R PA
(i) Follow the manufacturer’s operational guidelines; and
(j) Avoid advertised events.
These guidelines will help you avoid flying in a negligent or
reckless manner and being subject to monetary fines. They will
also help ensure that you enjoy a safe flight and minimize the
risk of an incident. Remember: if you feel that a flight is risky,
do not fly.
If CARs 601.04 and 601.16 as well as section 5.1 of the Aeronautics
Act prohibit for all “aircraft” the use of airspace, they therefore
apply to micro RPAs because they are considered aircraft under
the Aeronautics Act and the CARs. For more information, see
RAC 2.8.6 Class F Airspace in the Transport Canada Aeronautical
Information Manual (TC AIM).
Micro RPAs are therefore prohibited from entering the following
zones without proper authorization:
(a) Class F Special Use Restricted airspace;
(b)
Zones for which a NOTAM for forest fire aircraft operating
restrictions has been issued; and
(c) Zones in which section 5.1 of the Aeronautics Act restricts
the use of airspace for all aircraft.
A pilot that is found to have created a hazard either to aviation
safety or to people on the ground is subject to an individual
penalty of $1,000 and/or a corporate penalty of $5,000 (CAR 103,
Schedule II).
3.0 SMALL REMOTELY PILOTED
AIRCRAFT SYSTEMS (sRPAS)—250 g
TO 25 kg
3.1
RegistRation
All small remotely piloted aircraft (sRPA) in Canada must be
registered, and the registration number must be on the aircraft
and clearly visible (Canadian Aviation Regulation [CAR] 901.02,
901.03). The method of marking the registration on the RPA is
left to the discretion of the owner. The RPA pilot should consult
the manufacturer’s instructions to ensure affixing the registration
will not affect the aircraft’s airworthiness. The registration
should be located on the main body of the aircraft and not on
frangible or removable parts such as batteries, motor mounts,
or payloads; it should contrast with the primary colour of the
RPA and be clearly visible when the aircraft is not in motion;
and it should be durable because, in most cases, the registration
will stay with the RPA for the duration of its service life regardless
of any changes of ownership. If the marking degrades (e.g.
permanent marker wears off or a label’s glue wears out) such
that the number is no longer visible, the pilot is responsible for
making the number visible again (e.g. re-write or create a new
label).
Registration is completed online through the Drone Management
Portal (<www.canada.ca/drone-safety>) and a registration number
is provided immediately once the required information is
submitted and the associated fee is paid. In order to register a
small RPA, the applicant must meet the requirements of
CAR 901.04.
A pilot is required to present proof of registration, digital or
physical, upon request from a peace officer or a person delegated
by the Minister of Transport such as a Transport Canada inspector
(CAR 103.02(1) and 901.09). Failure to register, mark, or present
proof of registration of an RPA can result in individual penalties
of up to $1,000 and/or corporate penalties of up to $5,000.
3.1.1 Modifying a Registration
3.1.1.1 Cancelling a Registration
An RPA registration is cancelled once any of the conditions
detailed in CAR 901.07 are met. It is the responsibility of the
registered owner to notify the Minister within 7 days if their
registered RPA is destroyed, permanently out of service, missing
for more than 60 days, missing with a terminated aircraft search,
or transferred to a new owner. The registration is also cancelled
if the owner of the aircraft dies, the entity that owns the aircraft
ceases to exist, or the owner no longer meets the requirements
of CAR 901.04.
Notification can be provided to the Minister through the Drone
Management Portal.
It is important to note that the registration is cancelled immediately
when any of the conditions above are met and not when the
Minister is notified.
If an RPA for which the registration has been cancelled and for
which the Minister has been notified has been found, fixed, or
otherwise brought back into service, an application for a new
registration must be completed.
Failure to notify the Minister in accordance with CAR 901.07
may result in individual penalties of up to $1,000 and/or corporate
penalties of up to $5,000.
3.1.1.2 Change of Name or Address
Registered owners of RPAs are required to notify the Minister
within 7 days of a change of name or address. Notification can
be provided to the Minister through the Drone Management
Portal.
Failure to notify the Minister in accordance with CAR 901.08
may result in individual penalties of up to $1,000 and/or corporate
penalties of up to $5,000.
3.2 geneRal opeRation and Flight Rules
This subpart describes general rules for small RPASs; these
rules apply to both basic and advanced operations unless there
are specific exclusions.
3.2.1 Line-of-sight
Visual line-of-sight (VLOS) RPAS operations rely on the LOS
concept to ensure safety and regulatory compliance. This concept
assumes an imaginary line between the pilot, through the control
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station, and the RPA, unimpeded by any obstacles or excessive
distance. Line-of-sight can be broken into two distinct categories:
1.
Visual line-of-sight by way of the pilot keeping a visual
reference with the RPA unaided throughout the flight.
2. Radio line-of-sight (RLOS), which is a function of the C2
data link between the control station and the RPA for the
purposes of managing the flight. Both the VLOS and the
RLOS share the same foundational idea but can have different
applications in RPA operations.
3.2.1.1 Visual line-of-sight (VLOS)
The CARs define VLOS as “unaided visual contact at all times
with the remotely piloted aircraft that is 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 detect
and avoid other aircraft or objects.” (CAR 900.01). CAR 901.11(1)
requires that pilots operating RPASs maintain VLOS at all times
during flight. Losing sight of the RPA behind buildings or trees
or into clouds or fog is strictly prohibited even for a short period
of time.
Maintaining VLOS can be achieved by an individual pilot keeping
the RPA within sight for the duration of the flight or by using
one or more trained visual observers. The RPA must remain in
VLOS with the pilot or at least one visual observer at all times.
The pilot may take his or her eyes off the aircraft for brief moments
to operate the control station or perform other flight-critical
tasks without being considered to have lost VLOS. If a task will
require extended loss of visual contact, the pilot should use a
visual observer or land the aircraft until the task is complete.
While the maximum range for VLOS is not prescribed by
regulation, pilots are required to determine the maximum distance
the RPA can travel away from them before it becomes a hazard
(CAR 901.28(c)). The factors to consider when determining this
range are discussed in paragraph 3.2.6.2(a) Limitations of the
Eye in this chapter. However, the manufacturer’s instructions
or user manual takes precedence in this matter and should be
consulted prior to determining the maximum range.
It is important to note that the regulations require VLOS be
unaided. Pilots and visual observers may not use binoculars,
telescopes, or zoom lenses to maintain VLOS, but unmagnified
night-vision devices are permitted for night VLOS operations
provided they are able to detect all light within the visual spectrum
(CAR 901.39(2)). Glasses, such as sunglasses or prescription
glasses, are not considered to be aids and are permitted.
Maintaining VLOS is a fundamental requirement for safe RPA
operations as it is the primary, and often only, means of avoiding
other airborne traffic. Failure to maintain VLOS can result in
individual penalties of up to $1,000 and/or corporate penalties
of up to $5,000.
3.2.1.2 Radio line-of-sight (RLOS)
The signal used by most small RPAs is often transmitted in the
2.4 GHz part of the electromagnetic spectrum, mainly because
of range performance and the fact that it is a part of the spectrum
that does not require a licence to transmit. This frequency band
is crowded by many users, and an RPA pilot can experience
electromagnetic interference from these other devices. In addition,
signals in this band are susceptible to interruption by physical
interference from buildings and trees. It is critical, therefore, to
ensure that there is uninterrupted RLOS between the control
station and the RPA, regardless of the distance between the two.
A control station that is powerful enough to transmit a signal a
few kilometres away may nevertheless be unable to control an
RPA a few metres away if there is an obstacle or interference
in RLOS.
3.2.2 Emergency Security Perimeters
In cases where a public authority has established a security
perimeter around an emergency area (e.g. fire, police incident,
earthquake, or flood) RPA pilots are required to stay outside of
the perimeter unless they are acting in the service of the public
authority that created the perimeter, acting to save a human life,
or working with first responders such as police or fire authorities
(CAR 901.12).
Security perimeters can generally be identified as places where
public officials limit or restrict access, where caution or police
perimeter tape has been erected, or where first responders are
on the scene. It is critical that RPA pilots and their aircraft do
not enter or fly over these areas as they may conflict with or
prevent lifesaving activities.
Failure to respect these perimeters can result in individual
penalties of up to $1,000 and/or corporate penalties of up to
$5,000.
3.2.3 Airspace
3.2.3.1 Canadian Domestic Airspace
Canadian RPA pilots are required to keep their RPA within CDA
as detailed in RAC subpart 2.2 of the TC AIM and the Designated
Airspace Handbook (DAH) (CAR 901.13).
Failure to remain within CDA can result in individual penalties
of up to $1,000 and/or corporate penalties of up to $5,000.
3.2.3.2 Controlled Airspace
RPA pilots are required to keep their RPA clear of controlled
airspace unless:
(a)
the pilot holds a Pilot Certificate—RPA (VLOS)—Advanced
Operations as described in section 3.4.1 of this chapter;
(b)
the RPAS manufacturer has declared that the unit meets
the appropriate safety assurance profile as described in
section 3.4.3 of this chapter; and
(c)
the RPA pilot has received an authorization from the
appropriate air navigation service provider (ANSP) as
described in section 3.4.4 of this chapter.
All three conditions must be met to gain access to controlled
airspace and each will be discussed in an individual section of
this chapter.
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For the purposes of RPAS operations, controlled airspace includes
Class A, B, C, D, and E. Class F airspace can be controlled
airspace, uncontrolled airspace, or a combination of both.
A basic description of controlled airspace can be found below.
Additional information can be found in the DAH and in subpart
RAC 2.8 of the TC AIM. Flight within each class is governed
by specific rules applicable to that class and are contained in
CAR 601.01, Division I — Airspace Structure, Classification
and Use. CAR 601 can be found at <https://lois-laws.justice.
gc.ca/eng/regulations/SOR-96-433/FullText.html#s-601.01>.
(a) Class A Airspace
RPA Pilots wishing to operate in Class A airspace require
specific authorization from both TC and NAV CANADA.
See section 3.6.1 of this chapter for information about
SFOC—RPAS.
Class A airspace is generally defined as high-level airspace
starting at FL 180 or approximately 18 000 ft in Southern
Domestic Airspace, FL 230 in Northern Domestic Airspace,
and FL 270 in Arctic Domestic Airspace. This type of
airspace is not denoted on aeronautical charts. Given the
high-level nature of Class A airspace, it is rarely a concern
for small RPA pilots. More information on Class A airspace
can be found in the TC AIM RAC 2.8.1.
(b) Class B Airspace
RPA pilots wishing to operate in Class B airspace require
specific authorization from both Transport Canada and the
ANSP. See section 3.6.1 of this chapter for information
about SFOC—RPAS.
Class B airspace is generally defined as low-level controlled
airspace and exists between 12 500 ft and the floor of Class
A airspace but it may include some control zones and control
areas that are lower. The specific dimensions of Class B
airspace in Canada can be found in the DAH.
(c) Class C Airspace
Class C airspace is considered an advanced operating
environment. See section 3.4.3 of this chapter for more
information.
Class C airspace is controlled airspace, generally exists
around large airports, and extends from the surface to an
altitude of 3 000 ft AGL, but the exact size and shape of the
space is dependent on local airspace management needs.
Class C airspace is depicted on all VFR Navigation
Charts (VNC) and VFR Terminal Area Charts (VTA) as
well as in the DAH, using NAV CANADA’s drone flight
planning tool and the National Research Council Canada
Drone Site Selection Tool.
(d) Class D Airspace
Class D airspace is considered an advanced operating
environment. See section 3.4.3 of this chapter for more
information.
Class D airspace is controlled airspace and generally exists
around medium-sized airports and extends from the surface
to an altitude of 3 000 ft AGL, but the exact size and shape
of the space is dependent on local airspace management
needs. Class D airspace is depicted on all VNCs and VTAs
as well as in the DAH, using NAV CANADA’s drone flight
planning tool and the National Research Council Canada
Drone Site Selection Tool.
(e) Class E Airspace
Class E airspace is considered an advanced environment.
See section 3.4.3 of this chapter for more information.
Class E airspace is controlled airspace for aircraft operating
under IFR and can exist around an airport as a control zone
or away from an airport where an operational need exists
to control IFR aircraft. Class E control zones usually extend
from the surface to an altitude of 3 000 ft AGL. It can also
often exist from 2 200 ft AGL and up in a control area
extension surrounding a control zone. When this type of
airspace is not associated with an airport it usually begins
at 700 ft AGL and extends to 12 500 ft ASL, but the exact
size and shape of the space is dependent on local airspace
management needs. Class E airspace is depicted on all
VNCs and VTAs as well as in the DAH, using NAV CANADA’s
drone flight planning tool and the National Research Council
Canada Drone Site Selection Tool.
(f ) Class F Airspace
Class F airspace is special use airspace and can be either
restricted or advisory. Class F can be controlled airspace,
uncontrolled airspace, or a combination of both, depending
on the classification of the airspace surrounding it.
(i) Class F Restricted Airspace
Class F restricted airspace is denoted as CYR
followed by three numbers (e.g. CYR123). The letter
D for danger area will be used if the restricted area
is established over international waters. Class F
restricted airspace is identified on all VNCs and
VTAs as well as in the DAH, using NAV CANADA’s
drone flight planning tool and the National Research
Council Canada Drone Site Selection Tool, and
should be avoided by all airspace users except by
those approved by the user agency. CYRs can be
found over federal prisons and some military training
areas, for example. Additional information can be
found in RAC 2.8.6 of the TC AIM. To gain access
to Class F restricted airspace, RPA pilots should
contact the user agency as listed for the specific
block of airspace in the DAH.
(ii) Class F Advisory Airspace
Class F advisory airspace is denoted as CYA followed
by three numbers (e.g. CYA123). Class F advisory
airspace is identified on all VNCs and VTAs as well
as in the DAH, using NAV CANADA’s drone flight
planning tool and the National Research Council
Canada Drone Site Selection Tool. CYA denotes
airspace reserved for a specific application such as
hang-gliding, flight training, or helicopter operations.
RPA pilots are not restricted from operating in
advisory airspace and no special permission is
required, but pilots should be aware of the reason
the airspace has the advisory and take steps to
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identify any additional risks and mitigate them. Many
activities in a CYA often bring directly piloted
(manned) aircraft into airspace below 400 ft AGL
and are therefore a greater risk to RPA operations.
Additional information can be found in RAC 2.8.6
of the TC AIM.
(g) Class G Airspace
Class G airspace exists in any space that is not Class A, B,
C, D, E, or F. Class G airspace is uncontrolled and is
considered the basic operating environment for RPAS,
assuming the conditions regarding proximity to people,
airports, and heliport are met. These will be discussed in
RAC 3.2.14 and 3.2.35.
3.2.3.3 Drone Site Selection Tool
This online interactive tool provides information regarding
airspace restrictions around airports, heliports, and aerodromes
to facilitate flight planning and ensure compliance with the
regulations. It was designed to help RPA pilots determine areas
where drone flight is prohibited, restricted, or potentially
hazardous. The Drone Site Selection Tool can be found at <https://
cnrc.canada.ca/en/drone-tool/>.
The tool is powered by a Google Earth engine that uses colour
to identify areas that require additional caution or where RPA
flights are prohibited according to a basic or advanced RPA
operation category. Users should start by selecting the appropriate
category of drone operations (i.e. basic or advanced). Areas
filled with red are prohibited. Areas filled with yellow require
additional caution due to other air traffic. Areas filled with
orange require permission from NAV CANADA, Parks Canada,
National Defence, or an airport operator.
When a user clicks on the control zones, information is displayed
regarding the emergency contact information, airspace class,
flight permission requirements, and more. It is important that
the user verify the information before initiating the RPAS
operation; it is the pilot’s responsibility to contact the responsible
authorities if he or she wishes to enter restricted airspace.
Data regarding airports and heliports comes from the Canada
Flight Supplement (CFS), a NAV CANADA publication, and is
updated every 56 days. The airspace data comes from the
Designated Airspace Handbook (DAH) of NAV CANADA.
The national park data was extracted from the Canada Lands
Surveys web services. A limited amount of data has been added
manually to extend and improve upon the tool. An example of
this is the inclusion of the restrictions surrounding Quebec
corrections facilities as identified in NAV CANADA’s
AIP Supplement 20/19.
3.2.3.4 Inadvertent Entry Into Controlled Airspace
RPA pilots must be aware of not only the airspace in which they
are operating but also the surrounding airspace, specifically
their proximity to controlled airspace and restricted airspace,
both laterally and vertically. If the RPAS operation is taking
place at a location from which the RPA might enter controlled
or special use airspace in the event of a fly-away, the RPA pilot
should have the contact information for the appropriate ANSP
or user agency immediately available. In the event that the RPA
enters or is about to enter controlled airspace or special use
airspace, the pilot must immediately notify the appropriate air
traffic control (ATC) unit, flight service station (FSS), or user
agency (CAR 901.15). Failure to notify the appropriate agency
or agencies when unauthorized entry into controlled or restricted
airspace may occur could result in individual penalties of $1,000
or corporate penalties of $5,000.
3.2.4 Flight Safety
RPA pilots are legitimate airspace users but are new entrants
into a complex environment. It is the responsibility of the RPA
pilots to take their role in the aviation environment seriously
and ensure all necessary steps are taken to mitigate any possible
risks. RPA pilots must keep in mind that the risk of injuring a
person is greater than colliding with another aircraft, and a good
safety margin should be kept according to the situation, especially
for advanced operations within 30 m of the public. It is the RPA
pilot’s responsibility to manage the flight to ensure a safe outcome.
He or she is to use all resources available to make appropriate,
safe decisions to continue with the RPA flight or to end or
re-schedule operations if needed.
If, during an operation, the pilot becomes aware of any situation
that endangers aviation safety or the safety of persons on the
ground he or she must immediately cease the operation until it
is safe to continue (CAR 901.16). Failure to do so may result in
individual penalties of up to $1,000 and/or corporate penalties
of up to $5,000.
3.2.5 Right of Way and Risk of Collision
RPA pilots must give way to all other aircraft, including balloons,
gliders, airships, and hang gliders heavier than air aircraft
(CAR 901.17). It is critical that this rule is respected and that
RPA pilots take their role in ensuring collision avoidance seriously
as pilots of other aircraft may not be able to see the RPA as well
as the RPA pilot can see and hear other aircraft. RPA pilots must
not operate so close to another aircraft as to create the risk of
collision (CAR 901.18). If a collision with another aircraft becomes
likely, RPA pilots must take immediate action to exit the area
by the quickest means possible. This often means rapidly reducing
altitude.
Failure to give way to other aircraft or to remain far enough
away from other aircraft to avoid the risk of collision may result
in individual penalties of up to $1,000 and/or corporate penalties
of up to $5,000 and could constitute endangering an aircraft
under the Criminal Code.
3.2.6 Detecting and Avoiding Traffic
3.2.6.1 General
When flying an RPA within VLOS, pilots practise “detect-and-
avoid” (DAA) as a primary method of minimizing the risk of
collision with other aircraft. DAA requires the pilot to look away
from the control station and become aware of his/her aircraft
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and the surrounding environment. If the pilot can acquire skills
to compensate for the limitations of the human eye, the DAA
practice can be greatly improved and effective in facilitating a
safer flight environment altogether. More information on how
pilots can improve their visual skills is available in 3.2.6.2(b)
Visual Scanning Technique.
In addition, the RPA pilot has other tools to detect traffic, such
as hearing an approaching aircraft, monitoring a local ATC
frequency, and using transponder or ADS-B monitoring devices,
which are becoming more common.
3.2.6.2 Seeing Traffic
(a) Limitations of the Eye
The eye is the primary means of identifying what is
happening around us, as 80% of our information intake is
conducted through the eyes. During flight we depend on
our eyes to provide basic input necessary for flying, such
as proximity to other air traffic, direction, speed, and altitude
of the RPA. A basic understanding of the eyes’ limitations
in target detection is important for avoiding collisions.
Vision is influenced by atmospheric conditions, glare,
lighting, temperature, aircraft design, and so forth. On a
sunny day, for example, glare is worse. Glare makes it hard
to see what is at a distance as well as making the scanning
process uncomfortable.
Vision can be affected by different levels of illumination:
(i) Bright illumination: reflected off of clouds, water,
snow, and desert terrain; produces glare resulting
in eye strain.
(ii) Dark Adaptation: Eyes must have at least 20 to 30
minutes to adjust to reduced light conditions.
(A)
Red light helps night vision; however, it distorts
colour and makes details hard to perceive;
(B) Light adaptation can be destroyed in seconds,
though closing one eye may preserve some.
Additionally, vision is impaired by exposure to altitudes
above 5 000 ft ASL, carbon monoxide inhaled from smoking
and exhaust fumes, a deficiency of Vitamin A in one’s diet,
and prolonged exposure to bright sunlight.
One significant limitation of the eye is the time required
for accommodation, or refocusing of objects both near and
far. It takes 1 to 2 seconds for the eyes to adjust during
refocusing. Considering that you may need up 10 seconds
to spot aircraft traffic, identify it, and take action to avoid
a mid-air collision, each second is critical. Looking at an
empty area of the sky causes empty field myopia and will
impair your ability to focus. You should look at a cloud
patch or tree line to allow your eyes to focus.
Another eye limitation is the narrow field of vision. While
the eyes can observe an approximate 200-degree arc of the
horizon at one glance, only a very small centre area called
the fovea, in the rear of the eye, has the ability to send clear,
sharply focused messages to the brain. All other visual
information that is not processed directly through the fovea
will be less detailed. More information is available in subpart
AIR 3.5 Vision.
(b) Visual Scanning Technique
Avoiding collisions requires effective scanning from before
takeoff until the aircraft comes to a stop at the end of a
flight. The best way to avoid collisions is by learning how
to use your eyes for efficient scanning, as well as
understanding the visual limitations described above and
not overestimating your visual abilities.
Before takeoff, visually scan the airspace around your
intended take-off location. Assess traffic audibly as well,
listening for engine sounds and, if possible, radio
transmissions. After takeoff, keep scanning throughout the
flight to ensure that no other traffic will be a hazard to your
aircraft.
Scanning your eyes over a large area of sky at once without
stopping to focus on anything is ineffective. Because the
eyes can focus only on a narrow viewing area, effective
scanning is achieved through short, regularly spaced eye
movements that bring successive areas of the sky into the
central visual field. Movement can be detected more
effectively through peripheral vision, so this pause in a
visual scan allows for easier detection of threats such as
aircraft and birds. An effective scan is a continuous process
used by the pilot and observer to cover all areas of the sky
visible from the control station.
Although horizontal back-and-forth eye movements seem
to be preferred by most pilots, every pilot should develop
a scanning pattern that is most comfortable for them and
then adhere to it to assure optimum scanning. Pilots should
realize that their eyes may require several seconds to refocus
when switching views between items in or on the control
station and distant objects. The eyes will also tire more
quickly when forced to adjust to distances immediately
after close-up focus, as required for scanning the control
station. While there is no “one size fits all” technique for
an optimum scan, many pilots use some form of the “block”
system scan. This scan involves dividing the sky into blocks,
each spanning approximately 10 to 15 degrees of the horizon
and 10 to 15 degrees above it. Imagine a point in space at
the centre of each block. Focus on each point to allow the
eye to detect a conflict within the foveal field, as well as
objects in the peripheral area around the centre of each
scanning block.
Good scanning requires constant attention-sharing with
other piloting tasks, and pilots should remember that good
scanning is easily degraded by conditions such as boredom,
illness, fatigue, preoccupation with other tasks or ideas,
and anxiety.
3.2.6.3 Hearing Traffic
One advantage an RPA pilot has over a pilot of a manned aircraft
is the ability to hear approaching traffic. The first indication an
RPA pilot will have of approaching traffic will often be the noise
from the engines and/or rotors, both of which can be useful cues
to direct the pilot’s attention to traffic detection. Even though
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these noise cues can be distorted by terrain, buildings, or wind,
they are still a credible means for the RPA pilot to focus on
identifying approaching aircraft until they can be visually
acquired.
(a) Monitoring Air Traffic Frequencies
It is possible that an RPA pilot will have access to a radio
for monitoring ATC frequencies. This radio may be part of
a pilot’s risk-mitigation efforts in the event of a non-standard
operation. In any event, this radio can be an extremely
valuable source of traffic information, provided the RPA
pilot is aware of the correct frequency to monitor. Aviation
frequencies can be found on aviation maps as well as in
the CFS.
Table 3.1—Air Traffic Frequencies
Frequency (MHz) Usage
126.7 Uncontrolled airspace
123.2 Uncontrolled, unassigned aerodromes
While monitoring the radio, a pilot can build up a mental
picture of the other traffic in the local area and, depending
on the level of the pilot’s knowledge of aviation, he or she
can use the radio calls from other aircraft to determine
potential hazards to the RPA operation.
In accordance with section 33 of the Radiocommunication
Regulations, a person may operate radio apparatus in the
aeronautical service [...] only where the person holds [a
Restricted Operator Certificate with Aeronautical
Qualification (ROC-A), issued by Innovation, Science and
Economic Development Canada]. Also, all radio equipment
used in aeronautical services must be licensed by
Industry Canada.
For more information on the standard radio phraseology
used in aviation, see Innovation, Science and Economic
Development’s study guide RIC-21 for the ROC-A, COM
1.0 in the TC AIM, or NAV CANADA’s VFR Phraseology
Guide.
3.2.6.4 Avoiding a Collision
Once an aircraft is detected and it is determined to be a conflict,
the RPA pilot is responsible for avoiding a mid-air collision. The
best way to fulfill this obligation will vary depending on the
scenario, and RPA pilots should plan how they are going to react
to a potential collision prior to taking off or launching to ensure
their strategy best fits the operation. The fastest method of
resolving a potential conflict is likely reducing altitude.
The RPA pilot must always give way to other airspace users
(CAR 901.17), and RPA pilots should recognize that the pilot of
the other aircraft likely will not see the RPA with sufficient time
to react. The responsibility of avoiding a collision lies with the
RPA pilot, and it is a responsibility that should be taken very
seriously as the lives of the people in the other aircraft may
depend on it.
3.2.7 Fitness of Crew Members
All members of the crew including the visual observers, pilots,
and others involved in the operation of the RPAS must not be
under the influence of any drugs or alcohol or fatigued when
conducting an operation with an RPAS (CAR 901.19). Additional
information can be found in the TC AIM AIR – Airmanship,
Part 3.0 Medical Information.
It is strictly prohibited under CAR 901.19 to act as a pilot or
crew member of an RPAS within 12 hours after consuming an
alcoholic beverage, while under the influence of alcohol, or
while using any drug that impairs a person’s faculties. It is also
strictly prohibited under PART VIII.1 section 320.14(1) of the
Criminal Code for a person to act as a pilot or crew member of
an RPA while the person’s ability to operate is impaired, to any
degree, by alcohol, drugs, or a combination of both. All aircraft
pilots and crew members must remain fit to fly.
If an RPA pilot takes prescription drugs, it is his or her duty to
ensure they do not alter his or her ability to safely engage in
RPA operations. It is each individual’s responsibility to consult
with a physician in a case of doubt and to advise other members
of the team of the situation if deemed necessary.
Cannabis became legal, for both recreational and medical
purposes, in Canada in October 2018 by virtue of the Cannabis
Act. Whether it is used recreationally or medically, cannabis has
the potential to cause impairment and adversely affect aviation
safety. All aircraft pilots and flight crew members (including
RPA pilots and visual observers) must abstain from cannabis
use for at least 28 days when conducting operations with an
R PAS.
Fatigue is as dangerous as drugs or alcohol when it comes to
impairment and is oftentimes harder to detect. Fatigue will
influence judgment, motor response, and mental capability. Its
effects can be present without the person realizing it, making it
particularly dangerous. It is important to consider that sleep
itself is not the only factor influencing the degree of a person’s
fatigue. Lack of sleep, work-related stress, family issues,
emotional state, and general health are all factors that contribute
to the fatigue level of a particular individual. A comprehensive
guide to manage fatigue, the Fatigue Risk Management
System (FRMS) Toolbox for Canadian Aviation, is available on
Transport Canada’s Web site: <www.tc.gc.ca/en/services/aviation/
commercial-air-services/fatigue-risk-management/frms-toolbox.
htm>. It is a great tool to help understand, manage, and mitigate
the risks associated with fatigue in an aeronautical context.
It is not just fatigue, alcohol, or drugs that can leave a crew
member unfit for duties. Illness and many other conditions may
diminish crew members’ ability to perform their functions and
might render them unfit for the operation. It is the responsibility
of individual crew members to conduct a self-assessment to
ensure they are fit before accepting any duties related to the
operation.
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Reviewing a checklist prior to flight can help a crew member
determine if they are fit to fly. A simple IM SAFE checklist can
be found below but several other examples can be found online.
If the answer to any of the questions below is “Yes”, you are
likely not fit to act as a crew member.
Table 3.2—IM SAFE Checklist
I
Illness
Are you suffering from any illnesses that could
impair your ability to complete your duties?
M
Medication
Are you under the influence of any drugs (over-
the-counter, prescription, or recreational) that will
impair your ability to complete your duties?
S
Stress
Are personal or professional matters causing stress
to the point that you are distracted or otherwise
impaired?
A
Alcohol
Have you consumed any alcohol within the
previous 12 hours?
F
Fatigue
Have you had sufficient rest in the previous
24 hours and do you feel alert?
E
Eating and drinking
Have you had sufficient and proper nutrition and
hydration?
Failure to abstain from acting as a crew member of an RPAS
while unfit may result in individual penalties of up to $1,000
and/or corporate penalties of up to $5,000. Acting as a crew
member within 12 hours of consuming alcohol or while under
the influence of drugs or alcohol may result in individual fines
of $5,000 and/or corporate penalties of $15,000.
3.2.8 Visual Observers
In some cases, a visual observer is needed to assist the pilot in
maintaining a constant VLOS with the RPA to comply with the
CARs. In complex operating environments like urban areas, the
RPA pilot and the visual observer have to maintain communication
for updates to any impending conflict between the RPA and
terrain, obstacles, aviation traffic, weather, etc. Visual observers
shall be trained to perform any duties as assigned to them by
the pilot. This includes visual scanning techniques, aircraft
identification, communications, and any other knowledge that
may be required to successfully perform their duties. The pilot
and visual observer(s) shall remain in constant and immediate
communication throughout the RPAS operation, as stated in
CAR 901.20.
Before beginning an operation, the crew should agree upon
consistent communication language specific to the mission at
hand. Important information sought by the pilot could be the
RPA’s relative distance, altitude, and flight path in relation to
manned aircraft but also other hazards like terrain, weather, and
structures. The visual observer must be able to determine the
RPA’s proximity to all aviation activities and sufficiently inform
the pilot of its relative distance, altitude, flight path, and other
hazards (e.g. terrain, weather, structures) to prevent it from
creating a collision hazard.
The visual observer will also help the RPA pilot to keep the
operational environment sterile (that is, free of irrelevant
conversation) during the flight and minimize the disturbances
to the RPA pilot and crew.
Visual observers are not required to possess an RPA pilot
certificate.
3.2.9 Compliance With Instructions
In any type of safety-critical operation there is a requirement
for one person to have the final word on how and when various
tasks will be performed. In aviation this person is called the
pilot-in-command or pilot. For RPAS operations all crew members
are required to follow the instructions of the pilot.
Failure to follow the instructions of the pilot can result in unsafe
situations and may be punishable by individual penalties of up
to $1,000 and/or corporate penalties of up to $5,000.
3.2.10 Living Creatures
RPA pilots are prohibited from operating an RPA with a living
creature on board (CAR 901.22). As with the entirety of Subpart
I of Part IX, this regulation applies only to sRPAs. In order to
operate large RPAs for the purpose of carrying persons, an
SFOC—RPAS issued in accordance with CAR 903.03 is required
(see subpart 3.6 of this chapter).
The operation of an sRPA with a living creature on board may
result in individual penalties of up to $1,000 and/or corporate
penalties of up to $5,000.
3. 2 .11 Procedures
3.2.11.1 Normal Operating Procedures
RPA pilots are required to establish procedures for the pre-flight,
take-off, launch, approach, landing, and recovery phases of
flight. The procedures established must allow the aircraft to be
operated within any limitations prescribed by the manufacturer
and should be reviewed by the pilot on a regular basis to ensure
they contain the most up-to-date information and be available
to the pilot at the crew station during all phases of flight in either
a written or digital format. Caution should be exercised if the
procedures are on the same mobile device that is being used to
pilot the RPAS. This practice is not recommended.
3.2.11.2 Emergency Procedures
RPA pilots are required to establish emergency procedures for
control station failures, equipment failures, RPA failures, lost
links, flyaways, and flight terminations. The procedures
established must allow the aircraft to be operated within any
limitations prescribed the by manufacturer and should be
reviewed by the pilot on a regular basis to ensure they contain
the most up-to-date information and be available to the pilot at
the crew station during all phases of flight in either a written or
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digital format. Caution should be exercised if the procedures
are on the same mobile device that is being used to pilot the
RPAS. Following all emergencies, the PIC should log the events
and follow-up actions in accordance with CAR 901.49.
(a) Control Station Failure
Whether the RPAS is controlled via a laptop, RC, or another
device, its crew should have troubleshooting items committed
to memory for immediate action. Pilots should know and
be prepared for how their aircraft will respond to a crashed
app, powered down transmitter, or low battery scenario.
(b) Equipment Failure
While some equipment will not be flight-critical, crews
should know which items require aircraft grounding and
which are safe to fly without. Establishing a manufacturer-
advised minimum equipment list is a good practice.
(c) RPA Failure
Crews should be aware of items that will cause a critical
failure of the RPA and what flight condition these failures
will create. While fixed wings may glide, most multirotors
will descend with varying levels of control. Immediate
actions should involve establishing a safe area and preparing
for injury or incident response.
(d) Lost Link
Immediate action items should include troubleshooting
(which, depending on the system used, may involve
reorienting antennas), confirming or exchanging the cable
connection, or selecting a flight termination system. The
crew should monitor the aircraft and the airspace until
connection can be regained or the aircraft lands safely;
otherwise, flyaway procedures should be initiated.
(e) Flyaway
A flyaway indicates an unresponsive aircraft and should
warrant immediate action by the crew to mitigate associated
risks both in airspace and on the ground. After initial
troubleshooting, action should be taken to alert the ANSP
of a deviation from the planned flight path and any potential
conflict that may exist. This is why it is critical that pilots
understand the airspace surrounding their operating
environment both laterally and vertically.
(f ) Flight Termination
Flight termination can take many forms and may be as
simple as a normal landing or as complex as a fragmentation
system or parachute. Another common flight termination
system is return-to-home, or RTH. Crews should know
when and how to activate RTH and how to cancel or override,
if possible.
3.2.12 Pre-flight Information
3.2.12.1 Pre-flight Inspections
Pre-flight inspections should be conducted before every takeoff
the aircraft conducts in order to verify the physical, mechanical,
and electronic integrity of the RPAS. The following is a brief
example of components to be inspected prior to flight and is not
all-encompassing. In all instances, the RPAS manufacturer’s
instruction manual shall be consulted to determine all the
components that must be inspected or require a function check
prior to flight. The initial inspection to confirm the RPAS is in
a fit and safe state for flight is the most extensive to be conducted
before each new day of operations and should include a thorough
inspection of the following components, in compliance with the
RPAS manufacturer’s operating manual recommendations,
including (but not limited to):
(a) Airframe;
(b) Landing gear;
(c) Power plant;
(d) Propellers/rotors;
(e) Battery or fuel;
(f ) Control station/receivers/transmitter;
(g) Control station device and cables (tablet, phone, laptop, or
other).
The crew also needs to be briefed on the following points before
takeoff:
(a)
Roles and responsibilities of each individual crew member;
(b)
Flight plans and anticipated procedures (e.g. command
hand-off);
(c) Emergency and contingency plans;
(d)
Location of the safety equipment and who is trained to
use it;
(e) Public management plan.
Just after takeoff, a brief test flight should be conducted first
within short VLOS range in order to verify commands response,
flight behaviours, response to current weather conditions, and
crew cohesion beforehand.
A brief inspection should also be conducted after each landing
(e.g. battery change) and a full inspection should be conducted
after each crash or malfunction, or when changing location.
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3.2.12.2 Fuel and/or Energy
Estimation of the fuel/energy consumption for the operations
should be considered prior to takeoff and described in the flight
planning summary. It is important to take into consideration
that the stated endurance of the aircraft with a given amount of
fuel/energy is a suggested indication from the manufacturer that
might change according to different variables. Those factors
might include but are not limited to environmental factors (e.g.
wind, outside temperature, and altitude), human factors (e.g.
piloting skills and/or behaviour), fuel/energy sources quality
(e.g. quality of the fuel or battery), and mechanical factors (e.g.
engine malfunction, motor friction). The aircraft might not
operate properly or predictably when its fuel/energy levels are
low. Unexpected circumstances might arise between the initiation
of the return procedure and the landing of the aircraft. Therefore,
it is recommended that the pilot consider factors that might
influence the aircraft endurance and plan the flight time
accordingly.
Finally, it is important to consider that RPASs are multi-
component systems and that the factors listed above will influence
the endurance of other components such as the remote control,
ground station, first-person view (FPV) goggles, etc. These
should also be taken into consideration when estimating the
endurance of the RPAS. Refer to the manufacturer’s instructions
provided to verify the aircraft and the components endurance
rating. In the absence of specific guidance from the manufacturer,
it is recommended that pilots take a cautious approach.
3.2.13 Maximum Altitude
In uncontrolled airspace, RPAs are normally limited by regulation
to a maximum altitude of 400 ft AGL or 100 ft above the tallest
obstruction within 200 ft laterally (CAR 901.25). However, if a
pilot is operating under an SFOC—RPAS, the conditions of the
SFOC may state a maximum altitude higher or lower than 400 ft
(CAR 903.01). In controlled airspace, the maximum altitude
permitted for a specific flight will be determined by the ANSP;
in most cases, this will be NAV CANADA. The RPA pilot must
keep the RPA in VLOS at all times, regardless of the altitude
allowed by the ANSP. The maximum altitude possible in VLOS
depends on several factors including the RPA’s visibility, colour,
size, etc. The vast majority of small RPAs are not visible at more
than 400 ft AGL in good weather conditions.
3.2.13.1 Types of Altitudes
In aviation, the altitude at which an aircraft flies is normally
measured as above sea level (ASL). RPASs usually display above
ground level (AGL) altitude from the launch site location. The
difference between AGL and ASL can be a few feet, or as much
as several thousands of feet, so it is important to know what
type of altitude your RPA control station is displaying. This is
important because traditional aviation aircraft are usually flown
with reference to ASL, so procedures and communication will
be conducted using altitudes in feet ASL that may seem odd to
an RPA pilot. Please also note that the unit of measurement used
in aviation for altitudes, elevations, and heights is feet. Conversion
to feet AGL would be difficult for an RPA pilot using metres AGL
as an altitude reference in their RPAS. TC AIM GEN 1.4 provides
additional information on units of measurement used in aviation.
For instance, an RPA operation may have a limit of 400 ft AGL,
but in a location like Calgary, this altitude equates to approximately
4 000 ft ASL, as the Calgary airport is at 3 600 ft ASL. An
RPA pilot monitoring ATC radio frequencies in this situation
might get confused when trying to determine the location of
aircraft if differing altitude measurements are used. In another
scenario, an RPA flying near Tofino, BC would have a much
easier time trying to reconcile AGL and ASL as the Tofino
airport is only at 80 ft ASL.
(a) Station Height
Station height is the altitude measured at a weather reporting
station, often an aerodrome, relative to sea level.
(b) Above Ground Level (AGL)
AGL involves an altitude of zero feet (or metres) measured
when the RPA is sitting on the ground and, as the aircraft
flies, altitude changes are measured in reference to the
ground below the RPA, or the initial ground position. In an
RPA, this altitude is often calculated by a GPS position or
a downward-pointing laser rangefinder.
It is important to note that many RPAs reference their altitude
AGL from the point of launch. This means that the aircraft’s
altitude AGL may have to be inferred as the aircraft travels
over uneven ground. For operations with large ground level
height changes where the aircraft is operated near the
operational limit of 400 ft, a buffer may need to be included
to prevent exceeding the allowable maximum altitude.
(c) Above Sea Level (ASL)
ASL requires a pressure measurement from a local weather
station, which is then input into a pressure altimeter on the
aircraft. This will then provide an altitude read-out which
is relative to sea level. Traditional aircraft and some larger
RPAs will be equipped with pressure altimeters and use
ASL altitude measurements.
3.2.13.2 Measuring Altitude
(a) Pressure Altimeters
The pressure altimeter used in aircraft is a relatively accurate
instrument for measuring flight level pressure but the altitude
information indicated by an altimeter, although technically
“correct” as a measure of pressure, may differ greatly from
the actual height of the aircraft above mean sea level or
above ground. As well, the actual height of the aircraft
above ground will vary as the aircraft flies between areas
of different pressure.
For more information on pressure altimeters and their uses
and errors, see subpart 1.5 Pressure Altimeter in the AIR—
Airmanship chapter of the TC AIM.
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(b) Global Positioning System (GPS) Altimeters
The GPS receiver in an RPA typically needs to clearly see
a minimum of four satellites to get an accurate position over
the earth. GPS is a helpful aid to aviation, but it is important
to recognize that there are errors that may affect the accuracy
of the position and altitude calculated and displayed by your
RPA. In altitude, errors resulting from poor satellite
geometry, reception masking by obstacles, or atmospheric
interference can result in errors of up to 75 ft (approx. 23 m).
For more information on GPS and other GNSSs, see subpart
5.1 Global Navigation Satellite System (GNSS) in the COM—
Communication chapter of the TC AIM.
3.2.14 Horizontal Distance
RPA pilots are required to remain 100 ft or 30 m from people
not associated with the operation. The distance from people
must be maintained regardless of the altitude at which the RPAS
is operating.
It is the RPA pilot’s responsibility to plan the route of flight in
a manner that ensures the RPA does not fly within 30 m of any
person, except for crew members and other people involved in
the operation. (CAR 901.26) Examples of people involved in the
operation are: construction site or mine workers, film crews, or
wedding guests and others involved in a wedding (facility staff,
caterers, etc.). These people are considered part of the operation
if they have been briefed on the RPA hazard and have the
opportunity to leave the RPA operation site if they are
uncomfortable with it. People inside vehicles or inside buildings
are not factored into the 30-metre horizontal distance rule
(CAR 901.26). Even if an RPA can fly within 30 m of vehicles,
buildings, crew members, or other people involved in the
operation, this needs to be done safely (CAR 900.06). The RPA
pilot should have contingency plans in place in the event that a
person not associated with the operation comes within 30 m of
the RPA and should be prepared to take immediate action to
restore the safety buffer. Some examples of contingency plans
may be rerouting the RPA, returning to land, or holding over a
secure area until the minimum distance can be restored. Whatever
action is taken to maintain the safety distance, the pilot must
ensure the RPA does not fly within 30 m of one person while
trying to remain 30 m away from another person. Pre-planning
and site preparation during the site survey have proven to be
effective at reducing the risks associated with maintaining the
required 30-metre safety buffer.
Operations between 30 m and 5 m from another person are
considered “near people” and are an advanced operation.
To operate an RPA “near people”, the RPA pilot needs to:
(a) possess a Pilot Certificate—Advanced Operations; and
(b)
use the right RPAS in accordance with CAR 901.76 and
CAR Standard 922 Remotely Piloted Aircraft Systems Safety
Assurance. This eligibility is written on the RPAS certificate
of registration.
Different Systems for Measuring Distance - km/SM/NM
km: The kilometre is a standard metric measurement that is the
most commonly used in the world; 1 km equals 1 000 m. Most
maps and software will use the metric system.
SM: The statute mile comes from the imperial system and refers
more commonly to the U.S survey mile, which is equal to 5 280
ft or 1 609.347 metres. It is most commonly used in the U.S.A.
and the United Kingdom and is still commonly used in aviation.
NM: A nautical mile represents one latitudinal minute of the
earth spheroid. The most commonly used spheroid for calculating
the nautical mile is the WGS84 geoid, which equates 1 nautical
mile to 6 046 ft, 1 825 metres, or 1.15 statute mile. It is the main
distance unit used in aviation and marine applications.
Two methods can be used to measure distances at the field site
without being directly on the ground. Using the scale on your
maps or chart, calculate the distance using a metric or imperial
ruler and translate the distance calculated on the map. For
example, if the map scale is 1:20 000, then 1 linear centimetre
calculated on the map represents 20 000 centimetres on the
ground. The second method would consist of using an online
Geographic Information System platform (e.g. Google Earth
and ArcGIS Earth) that has spatial calculation tools that provide
instant measurements of the terrain surface.
3.2.15 Site Survey
3.2.15.1 Understanding Your Area of Operation
It is important to understand your area of operation prior to
conducting your flight mission. Multiple options are available
for this preliminary step, including looking at satellite imagery
or topographic/aviation maps and visiting the site in person.
Satellite imagery is now freely available on the web through
multiple service providers and applications (e.g. Google Earth
and Bing). The GeoGratis spatial products portal of Natural
Resources Canada also offers free topographic information,
Digital Elevation Models (DEMs), satellite imagery, and more.
Aviation charts are available at a cost through NAV CANADA
and through mobile and web apps. Ensure that these third-party
applications are using up-to-date and official NAV CANADA
information. It is best to use site coordinates in order to localize
the area of operation on a map or other imagery source. If
coordinates are not available, using a landmark, nearby structure,
or point of reference is a reasonable substitute.
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Once the site has been identified, the following points must be
defined:
(a) Operation boundaries;
(b) Airspace classes and applicable regulatory requirements;
(c)
Routes and altitudes to be followed during the entire
operation;
(d) Proximity of manned aircraft and/or aerodromes;
(e) Location and height of nearby obstacles;
(f )
Security measures for warning the public of the RPAS
operations site;
(g) Predominant weather conditions for the area of operation;
(h) Minimum separation distances from persons;
(i)
An alternate landing site in case of precautionary or
emergency landing; and
(j) Aviation maps and symbols.
3.2.15.2 Locating Local Aerodromes and Airports
To identify an aerodrome or an airport, it is recommended that
a combination of aeronautical charts and the CFS issued by
NAV CANADA be used. The two main charts used by pilots
are the VNC, meant for low- to medium-altitude flights at a
1:500 000 scale, and the VTA, meant for providing information
about the most congested airspace within Canada at a scale of
1:250 000. The CFS is a reference document updated every 56
days containing all the information relevant to the registered
aerodromes and certified airports in Canada. For information
regarding water aerodromes, refer to the Canada Water Aerodrome
Supplement (CWA S).
To identify the different symbols presented on the maps and
charts, you should refer to the legend presented in the first pages
of the charts and the CFS. Information with regard to date of
publication, author, projection, scale, and more would also be
found there.
3.2.15.3 Identifying Classes of Airspace
To identify the classes of airspace present at the field site, it is
recommended that you use resources such as NAV CANADA’s
drone flight planning tool, the Drone Site Selection Tool, the
CFS, the aeronautical charts of the area of operation, and the
DAH. Airspace will be classified according to the Canadian
airspace classification (a range from A to G). A basic description
of the classes of airspace can be found in section 3.2.3.3 of this
chapter. Additional information can be found in the DAH and
in subpart RAC 2.8 of the TC AIM.
Anyone holding an RPA Pilot Certificate (Basic or Advanced)
can operate an RPA within uncontrolled airspace only, in class G
and some class F airspace.
For flight within controlled airspace, the RPA pilot must:
(a) possess an RPA Pilot Certificate—Advanced Operations;
(b) receive an authorization from the local ANSP; and
(c)
use the right RPAS in accordance with CAR 901.76 and
CAR Standard 922—Remotely Piloted Aircraft Systems
Safety Assurance. This eligibility is written on the RPAS
certificate of registration.
3.2.16 Other Pre-flight Requirements
Prior to commencing flight the pilot must be satisfied that the
RPA has a sufficient amount of fuel/energy to safely complete
the flight, the crew members have received sufficient instruction
to perform their duties, and any required emergency equipment
is on site, with its location and method of operation known and
readily accessible.
In addition to the requirements above, the pilot must determine
the maximum distance the RPA can safely be flown from the
control station for the planned flight. This distance may vary
depending on the environment (e.g. visibility, cloud cover, and
wind), the location (e.g., a background of buildings can make
the RPA difficult to see), and the RLOS (the strength of the radio
signal and the presence of interfering signals).
3.2.17 Serviceability of the RPAS
All RPASs, just like all aircraft, must be inspected before flight
to ensure they are safe to operate and also after landing at the
conclusion of the flight to check that they are safe for the next
flight. The RPA pilot is responsible for ensuring that the RPA
is serviceable and the RPAS has been maintained (CAR 901.29).
The list below is generic in nature but includes points for
inspection applicable to most RPAs. For details, refer to the
manufacturer’s instructions for the specific type of RPAS.
Following the “walk around” or RPAS visual inspection, a fully
charged battery can then be installed for the next flight. For a
larger RPAS, a normal engine ground run can be carried out on
the ground for a check of the flight controls and avionics systems.
Just after takeoff, a short test flight and/or a ground run should
be completed to make sure all controls and switches are
functioning and correct.
3.2.17.1 Airframe (All Types)
Depending on the weight of the aircraft (25kg or less), pick up
the RPAS or walk around it and inspect the entire aircraft. Pay
attention to the following:
(a) Check all antennas, ensuring they are secure and in good
condition;
(b)
Check the battery emplacement and secure attachment, and
ensure that there are no cracks;
(c) Check that all lights are operating normally;
(d)
Check the pitot tube (if applicable) and make sure it is secure
and clear of any obstructions;
(e) Check that the GPS is receiving satellites and providing a
navigation solution (if applicable).
For fixed wings, check:
(a)
Wings, ensuring that they are securely attached to fuselage;
(b) Wing leading edge surfaces;
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(c) Top and bottom of wing surfaces;
(d) Wing tip surfaces;
(e) Rear of wing and all flight control surfaces for freedom of
movement, security, and any skin damage (composite/metal).
For rotary aircraft:
(a) Inspect the top and bottom of the airframe arms for cracks,
loose parts, or signs of damage;
(b) Check that the levels of all fluids (oil/hydraulic fluid) are
within limits and ensure there are no leaks.
3.2.17.2 Landing Gear
Check that the landing gear is secure, as applicable.
Larger RPASs may have retractable or fixed landing gear and
may have wheel brakes. Check for leaks on oleos and leaks in
the brake system as appropriate. Check brake wear indicators
if applicable.
For servicing and scheduled maintenance items, always refer to
the manufacturer’s maintenance manual. If in doubt, contact
the manufacturer directly for technical support.
Inspect skids or wheels as applicable depending on type,
especially the attachment points, which should be secure with
no cracks. In addition, check for cracks in welds.
3.2.17.3 Powerplant
Inspect the following:
(a) Cowling or motor casing as applicable;
(b) Power plant for security of engine mounts;
(c) The presence of any cracks;
(d)
All lines, ensuring there are no fluid leaks (fuel, oil, or
hydraulic);
(e)
All wiring and connectors, ensuring there are no cracks,
loose connections, or chaffing;
(f ) The oil level, ensuring it is within limits, if applicable.
3.2.17.4 Propellers
Inspect the following:
(a)
Spinner(s), if installed, ensuring that they are secure and
there is freedom of movement;
(b) The propeller, ensuring it is secure;
(c) The propeller blades, checking for nicks, chips, or cracks,
especially on the plastic blades on RPASs weighing 25kg
or less. Chips, nicks, or cracks on a plastic blade mean it is
time to replace the propeller. For metal blades refer to the
manufacturer’s instructions to see what the limits are to
file the nicks or chips before replacing the propeller.
3.2.17.5 Battery—Lithium Polymer
Inspect the battery for overall condition. There should be no
signs of swelling, external leaking, or other defects.
Ensure the battery wiring and connectors from the battery and
the aircraft are connected securely.
The battery and spare batteries necessary to complete the
operation should be adequately charged before flight to complete
the mission.
Be careful not to pinch the wires when installing the battery,
attaching the connectors, and closing the battery door.
3.2.17.6 RPAS Control Station/Receiver/Transmitters
The battery and spare batteries (if applicable) necessary to
complete the operation should be adequately charged before
flight to complete the mission.
Check that all flight interface is functioning normally.
3.2.18 Availability of RPAS Operating Manuals
In order to ensure the RPAS can be operated within the limitations
specified by the manufacturer, it is important that the pilot and
crew members have access to the most current system operating
manuals. These manuals can be available either in digital format
or in print; the key is that they are immediately available for the
pilot and crew members (CAR 901.30).
Failure to have manuals immediately available could result in
individual penalties of up to $1,000 and/or corporate penalties
of up to $5,000.
3.2.19 Manufacturer’s Instructions
RPASs are complex systems that have both system and
environmental limitations that allow them to operate in a
predictable manner. To ensure the maximum reliability of the
RPAS it is required that the RPAS be operated in accordance
with the manufacturer’s operating instructions (CAR 901.31).
Failure to operate the RPAS in accordance with the manufacturer’s
instructions could result in individual penalties of up to $1,000
and/or corporate penalties of up to $5,000.
3.2.20 Control of RPAS
RPA pilots are not permitted to operate autonomous RPAs for
which they are unable to take immediate control of the aircraft.
(CAR 901.32).
Automation (i.e. “automated” or “automatic”) refers to a
deterministic system that behaves in a predictable manner using
pre-set rules. This type of system will always produce the same
output given the same set of inputs, user error notwithstanding.
An example of this in an RPAS context would be a user plotting
a route on the control station and the aircraft following that route
on autopilot while the pilot monitors the flight.
In contrast, an autonomous system is goal-based and not
deterministic. The path to the desired outcome may not be easily
predicted and the system may model behaviours that result in
unique outcomes in each instance of operation. An autonomous
RPA is one that operates without pilot intervention in the
management of the flight, and in fact, there may be no mechanism
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for pilot intervention by design. An autonomous RPA may react
to changing environmental conditions or system degradations
in a manner that it determines on its own.
Pilots found to be operating autonomous RPAs for which they
are unable to take immediate control are subject to individual
penalties of up to $1,000 and/or corporate penalties of up to
$5,000.
3.2.21 Takeoffs, Launches, Approaches, Landings,
and Recovery
Prior to conducting an RPAS operation the pilot must ensure
that there is no likelihood of a collision with another aircraft, a
person, or an obstacle and that the site chosen is suitable for the
operation (CAR 901.33).
When choosing a site for an RPA’s takeoff, launch, landing, or
recovery, the pilot should ensure that he or she has the land
owner’s permission to use the site and that the site is free of
obstacles that could interfere with the operation of the RPA.
Obstacles include physical obstacles like trees, buildings, or
open water as well as non-physical obstacles like electronic or
magnetic interference. It is also important that the site selected
be secured to ensure bystanders do not venture too close to or
enter the take-off or landing area. Securing a site can be done
by erecting physical barriers to ensure the public does not access
the area during the operation or by having crew members perform
a crowd control function. It is important that the RPA pilot
understand and follow any municipal, provincial, and federal
laws and regulations when securing a site. In some situations,
restricting public access to a site may not be allowed.
3.2.22 Minimum Weather Conditions
The weather is a primary concern for pilots of all types and
should be something of which they have a thorough understanding.
The minimum weather requirements for sRPA pilots are different
from those of more traditional aircraft pilots and even large
RPAs. For sRPAs, the weather need only be sufficient to ensure
the aircraft can be operated in accordance with the manufacturer’s
instructions (i.e. temperature, wind, precipitation, etc.) and to
allow the pilot or visual observer to keep the RPA within VLOS
at all times.
3.2.22.1 Sources of Weather Information
Climate data, weather forecasts, and real-time weather conditions
are a central pillar of every aeronautical operation. Aircraft are
particularly vulnerable to the elements due to the medium in
which they operate, as the atmosphere does not provide any
shielding from the weather. Various sources of information are
available for monitoring weather and ensuring the safe conduct
of the RPAS operations. Depending on the time scale at which
the weather or climate needs to be determined, different sources
of weather information might be required.
For climatic and long-term predictions of a few months or more
Environment and Climate Change Canada’s (ECCC) Canadian
Climate Normals is available on the ECCC Web site:
<http://climate.weather.gc.ca/climate_normals/>. This tool is
more suitable for evaluating whether operations at a given time/
location would be possible given the historical climatic patterns.
This should be used as a means of evaluation for long-term
operation planning and/or in Canadian regions where pilots are
not familiar with the weather patterns at a given time. The portal
gives pilots access to a large array of data and graphs giving
punctual measurements of weather conditions along the Canadian
weather stations system. Data is freely available to download
in .csv format. Thirty-year averages (1981-2010/ 1971-2000/
1961-1990) are also available for analysis. For example, this
would help a pilot to establish when the ground is snow-free and
the air temperature is above 5°C according to the last 30 years,
permitting the planning mission in advance.
For medium- to short-term predictions of the weather, multiple
online and broadcast versions exist. ECCC offers daily weather
forecasts and forecasts up to two weeks in advance on its Web site,
<https://weather.gc.ca/canada_e.html>. Weather radar data is
available for up to 3 hours and satellite imagery is offered at
varying time intervals for the present day. This source of weather
information can be used for mission planning and/or the same day.
For same-day weather information one of the most detailed
sources of information is the online tool provided by
NAV CANADA called the Aviation Weather Web Site (AWWS):
<https://flightplanning.navcanada.ca/>. This Web site is one of
the main sources of weather forecasts, reports, and charts used
for flight planning by aviation professionals. For more information
regarding the AWWS, how to interpret different charts and
reports, and the general procedures associated with the Web
site, see the MET—Meteorology chapter of the TC AIM.
Additionally, there are a variety of weather apps available that
pull weather data from a variety of sources. Check to ensure
you are using NAV CANADA official data whenever possible.
Finally, no matter what tool is used, which preparations have
been made, and what the given predictions are for the day of
operation, it is essential to evaluate the weather at the site before
launching the operation. Weather is a complex science and can
be subject to unpredicted fluctuations, especially on a small
geographic scale. Never operate an RPAS if the weather on site
is outside your manufacturer’s recommended operating limits,
or if you judge based on your experience that local weather could
adversely affect your flight, even if the weather forecasts say
otherwise.
3.2.22.2 Micro vs. Macro Climate Environments
(a) Micro Climate
Micro climate is defined as climatic variations localized in
a small or restricted area that differs from the surrounding
region. It is important to consider small climatic variations
when planning RPAS flights. The altitude, nearby water
bodies, topography, ground surface, and obstacles are all
factors that can and will influence the conditions experienced
at a specific site. Those variations might manifest themselves
in the form of variable wind strength and/or directions,
convecting/advecting air movements, variable temperatures,
localized precipitation, variable visibility levels, and more.
These must be considered carefully; weather forecasts for
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the region might be good, but localized variations might
compromise flight operation safety.
Due to the nature of most RPAS VLOS flights, which are
flown at low altitudes and over short distances, it is most
likely that the pilot will experience some impact from the
micro climate at the site. Recognizing factors that might
influence weather patterns at the site prior to takeoff will
help mitigate possible accidents or annoyances during the
operations. Due to the high variability of micro climate it
is hard to establish the site-specific conditions on a given
day, before being physically there.
(b) Macro Climate
A macro climate will describe the overall climate of a large
area and represents the normal climatic patterns. This is
what the pilot needs to consider as the general pattern for
the operation, and it serves as a first step when considering
weather information in flight planning. As mentioned above,
the low flight altitude of most RPASs makes it more likely
they will be subject to micro climatic variations. Macro
climate will be more significant for beyond visual line-of-
sight (BVLOS) flight over a large area, as a simpler means
to evaluate weather due to the altitude and distance covered
by the RPAS.
3.2.22.3 Wind
RPA pilots should refer to the manufacturer’s RPAS operating/
flight manual with regards to the aircraft’s wind speed tolerance.
If no such recommendation is made, the pilot should exercise
common sense and avoid conducting an RPAS flight in winds
that might compromise safety.
Wind is the movement of air across the earth’s surface and is
one of the most important weather phenomena for pilots of all
types of aircraft. Wind speeds are expressed in kilometres per
hour (km/h) or knots (kt) and the direction will represent where
winds originated.
RPA pilots will most likely be subject to surface wind, which
generally extends a couple thousand feet AGL. Surface winds
vary depending on surface roughness, temperature, waterbodies,
and obstacles (see the paragraph on micro climate above), and
they can therefore be very different from one geographical
location to the next. Wind speed in aviation weather forecasts
is usually expressed in knots and is classified according to the
Beaufort Wind Scale (see AIM MET 2.6 Pilot Estimation of
Surface Wind), which is a scale ranging from breeze to hurricane.
Upper-level winds will not influence the vast majority of RPA
pilots as the altitude is much higher than standard flight altitude.
However, BVLOS flights with a large RPAS and a specially
trained crew might be conducted within this environment.
3.2.22.4 Visibility
For an RPAS flight conducted in VLOS, visibility should be at
a minimum equal to or greater than the extent of the desired
operation. While there is no minimum visibility prescribed in
Part IX of the CARs, the visibility must be sufficient to keep
the RPA in VLOS at all times.
Visibility is dynamic, can change rapidly, and might require the
pilot to adjust or end an ongoing operation if conditions change.
Local factors such as waterbodies and topography might create
heterogeneous visibility levels on a large or small scale. Flight
planning should take those variables into consideration.
3.2.22.5 Clouds
RPA pilots are prohibited from entering clouds as the RPA would
no longer be within VLOS.
Clouds are a great source of meteorological information for
pilots since they are a direct manifestation of the atmospheric
conditions at a given moment. Clouds are classified as low,
middle, or high altitude clouds and vertical development clouds.
The cloud ceiling is important information for RPAS flight and
is established based on the lowest layer of clouds on that day.
Cloud conditions and types will be influenced by the presence
of weather fronts, atmospheric pressure, winds, and topography.
Information regarding cloud conditions for a given day can be
found on the AWWS Cloud and Weather chart. For more
information on this matter, please see MET–Meteorology 4.11
Clouds and Weather Chart of the TC AIM.
3.2.22.6 Precipitation
In the absence of manufacturer guidelines for flights in
precipitation, it is recommended that pilots avoid flying in
precipitation as it might compromise the airworthiness of the
aircraft and create hazards.
Precipitation is atmospheric water vapour produced from
condensation that falls under gravitational force toward the
ground. Precipitation will manifest itself in liquid (drizzle and
rain) or solid forms (hail, snow pellets, snow ice prisms, and ice
pellets) and will have significant impact on RPAS operations.
Exposure to precipitation can impact an RPAS’ ability to perform
as expected. RPASs have varying levels of tolerance with respect
to precipitation. Refer to the RPAS manufacturer’s operating/
flight manual to verify the aircraft capability in precipitation.
3.2.22.7 Fog
Do not operate an RPAS in fog if visibility is too poor to maintain
proper VLOS with the RPA, even if it is equipped with lights.
Fog represents condensed water droplets found at the ground
level, or in other words, a low-level cloud. It usually brings
precipitation in the form of drizzle and will cause low visibility
conditions at ground level. This is of high concern for RPAS
operations in VLOS, as direct visual contact will be greatly
reduced in fog. Fog is dynamic, thus conditions at takeoff might
change during the operation and cause a threat to the RPA,
manned aircraft, and the public.
3.2.22.8 Temperature
Air temperature is also an important concept for RPA pilots.
Since the human body is accustomed to a narrow temperature
range, cold temperature can physically impair the efficiency of
pilots and ground crews if they are not dressed properly. A pilot’s
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dexterity can decrease significantly and cold temperature stress
can add to other stress, such as that caused by fatigue. Cold
temperature will directly affect all other components of the
weather system and thus have a great impact on the aircraft
itself. You must operate the RPAS within the operational limits
set by the manufacturer of the RPA, as each aircraft will have
a different range of temperature tolerance. Operating an RPA
outside of those suggested ranges will compromise the
airworthiness and safety of the aircraft, and your operation. It is
also important to consider that RPASs are multi-component
systems. Although the aircraft might be approved for a certain
temperature range, other parts of the system might not be—
particularly if you have made any modifications to the payload
or aircraft. Consider all components when assessing flight
suitability in the field.
RPASs are operated within the airspace and are therefore subject
to atmospheric temperature changes, due to the adiabatic lapse
rate. Under normal conditions, atmospheric air temperature will
decrease with an increase in altitude due to lower atmospheric
pressure. This phenomenon is called the adiabatic lapse rate.
Water vapour content within the air column will decrease the
lapse rate experienced, as more latent energy is required for an
equal change in temperate change in moist air. The adiabatic
lapse rate of unsaturated air is 3°C/1 000 ft and1.5°C/1 000 ft
for saturated air. Those values are set as standard but will be
variable in real-world scenarios as the water content will dictate
the precise lapse rate value. RPA pilots need to take the lapse
rate into consideration if operating in high-altitude BVLOS
flight or within a high-altitude environment as the weather
forecast and the conditions experienced by the aircraft might
differ greatly.
3.2.22.9 Sun
Sun will influence the conditions encountered by the RPAS in
direct and indirect ways. The pilot and visual observers need to
be aware of the sun glare that might prevent them from maintaining
proper visual line-of-sight with the RPA. Crew members should
take care to reduce the amount of time facing into the sun and
looking at the sky. In the event that the RPA is flying in line
with the sun, the crew should stare to the side of the aircraft and
the sun. Polarized sunglasses can cause visibility issues on tablet
displays, so they may not be a viable option for all crew members.
Solar activities can also create geomagnetic interferences that
have been shown to impact the navigation system (e.g. GPS,
GLONASS) and electronic components of the RPAS, specifically
the C2 link. For more information about the solar activity forecast
in Canada, refer to the Space Weather Canada forecast Web site:
<www.spaceweather.gc.ca/index-en.php>
<https://www.spaceweather.gc.ca/forecast-prevision/index-en.
php>
It is recommended that pilots refer to the Energetic Electron
Fluence forecast and use caution in periods of moderate or higher
radiation. The greater the electron fluence, the lesser the range
and quality of the C2 link, and the greater the possibility of
lost link.
3.2.23 Icing
Icing refers to atmospheric water droplets that are often defined
as supercooled (< 0 °C), which freeze upon contact with a surface.
Icing intensity is classified from trace to severe and icing types
are rime, clear, and mixed ice. Icing is common on all types of
aircraft and RPAs are no exception. Icing can occur before and
during the flight, greatly compromising the ability of the aircraft
to operate properly. Formation of ice on the propeller and frame
of the aircraft will increase take-off weight, change the aircraft’s
aerodynamic properties, and prevent components from operating
properly. Critical surfaces such as wings, control surfaces, rotors,
propellers, and horizontal and vertical stabilizers should all be
confirmed clear of contamination prior to takeoff and must
remain so, or the flight be terminated. Refer to the RPAS
operating/flight manual provided by the manufacturer to verify
the aircraft’s tolerance of icing. In the absence of an RPAS Safety
Assurance, it is recommended that you avoid flying in icing
conditions unless a method exists to de-ice and provide anti-ice
capabilities in flights. For more details about icing, please see
MET—Meteorology subpart 2.4 of the TC AIM.
3.2.24 Formation Flight
Formation flights between two or more RPAs or between an
RPA and another aircraft are permitted. If a formation flight is
to be undertaken, it must be pre-arranged; impromptu formations
are not permitted (CAR 901.36). Formation flights of more than
5 RPAs that are controlled by a single pilot from the same control
station are only authorized under an SFOC—RPAS (CAR 903.01 e).
The purpose of the pre-arrangement requirement is to ensure
that all the pilots associated with the operation are aware of how
the aircraft are to be flown to eliminate the risk of collision
(CAR 901.18 prohibits the operation of an RPA in such proximity
to another aircraft as to create a risk of collision) and to identify
and mitigate any risks associated with the flight.
3.2.25 Operation of Moving Vehicles, Vessels, and
Manned Aircraft
Pilots are prohibited from operating an RPA while at the same
time operating a moving vehicle (CAR 901.37). If it necessary
to operate an RPA from a moving vehicle, there must be a
dedicated person operating the vehicle while the pilot operates
the RPAS. If a visual observer is used in the operation, they are
also prohibited from operating the vehicle while performing
their duties as a visual observer (CAR 901.20(4)).
When launching from a vehicle (e.g. a boat) that is in motion or
that will be in a different location when the RPA is recovered,
consider that the return to home (RTH) automatic function may
register the initial position at takeoff. Some RPASs give you the
option of using the launch point or alternatively, going to the
location of the transmitter. Plan ahead for manual landing, or
other landing procedures, in a specifically designated location
and adjust the contingency plans to avoid having the RPAS
return to a dangerous location.
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Failure to abide by these prohibitions may result in individual
penalties of up to $1,000 and/or corporate penalties of up to
$5,000.
3.2.26 First-person View (FPV) Devices
FPV offers an immersive RPA piloting experience but cuts the
pilot off from his or her surroundings and greatly affects detect
and avoid capability (i.e. the pilot’s ability to scan for other
aircraft). If you are using an FPV system that reduces the field
of view of the pilot, visual observers must be used. The number
of visual observers needed will depend on the complexity and
area of the operation. The area surrounding the pilot should also
be safe and free of hazards, as the FPV will also prevent the
pilot from being aware of his or her own surroundings.
3.2.27 Night Flight
There are risks associated with night flight that result from
operating in an environment of reduced visibility. From the RPA
pilot’s perspective, the greatest concern is maintaining VLOS
with the RPA and detecting and avoiding unlit objects on or near
the ground like trees and power lines.
Night is legally defined in aviation as the period of time that
starts at the end of evening civil twilight and ends at the start
of morning civil twilight. In the evening, civil twilight ends
when the centre of the sun’s disc is 6° below the horizon and is
descending, approximately 25-35 min after sunset. In the morning,
civil twilight begins when the centre of the sun’s disc is 6° below
the horizon and is ascending, approximately 25-35 min before
the sunrise. The evening civil twilight is relative to the standard
meridians of the time zones, the period of time that begins at
sunset and ends at the time specified by the Institute for National
Measurement Standards of the Standards Council of Canada
and available at: <https://www.nrc-cnrc.gc.ca/eng/services/
sunrise/index.html>.
Night, in practice, is when you cannot effectively see the hazards
that would be visible during the day. In these situations, a day
site survey is advisable to ensure separation between the RPAS
flight path and any dangers that are not visible.
Night operations are permitted in both the basic and advanced
operating environments provided that the RPA is equipped with
position lights sufficient to allow the aircraft to be visible to the
pilot and any visual observer.
3.2.27.1 Detecting Aircraft During Night Operations
(a) Scanning Technique
The approach to scanning the sky for aircraft at night is
much the same as scanning the sky during the day; however,
limitations of equipment and human physiology should be
taken into account. With sufficient lighting on the aircraft,
it is very often easier to track your aircraft and other aircraft
than doing so during the day.
Aircraft are easier to identify at night, but it is more difficult
to determine the range of these aircraft. It is therefore possible
the RPAS could be within VLOS, but much farther away
than what would be by day operations.
Manned aircraft will also be easier to detect but may be at
a greater distance and appear much closer than they
actually are.
Depth perception at night is difficult, which affects the
assessment of relative position. Although it may be easier
to spot aircraft lights at night, judging the distance to an
aircraft is challenging.
(b) Noise
In some cases sound may be the only way to detect other
aircraft when operating at night. For this reason it is important
that the crew enforce a sterile environment around the control
station and anywhere visual observers are stationed. Any
unnecessary talking or noise should be avoided to ensure
the best chance of detecting other aircraft. Sound is also
useful to monitor your own aircraft’s performance when
visual cues are limited. Rapidly changing motor sounds on
a multirotor may indicate wind at altitude, for example.
(c) Vision
Vision can be affected at night, and there are several illusions
that can affect the pilot or observer’s ability to detect aircraft.
Additional information on vision can be found in AIR 3.5
Vision of the TC AIM.
3.2.27.2 Aircraft Lighting
Traditional aircraft are equipped with special lights to aid in
their detection and orientation. Traditional aircraft are required
to have position lights, which include a red light on the port side
(left side when sitting in the pilot’s seat), a green light on the
starboard side (right side when sitting in the pilot’s seat), and a
white light on the tail. An observer can determine which way
an aircraft is travelling by identifying the lights they can see.
For example, if the observer can see a red and white light, the
aircraft is travelling across their field of view from right to left
and moving away from them. If the observer can see only a
green light the aircraft is moving across their field of view from
left to right and may be moving towards them. If the observer
can see both a green light and a red light, the aircraft is coming
at them.
Aircraft are also equipped with anti-collision lighting, typically
an omnidirectional rotating or flashing red beacon. This light
can be affixed to either the top or bottom of the aircraft. Some
aircraft are equipped with strobe lights, landing lights, or
recognition lights. Strobe lights are generally white and attached
to the wing tips or the sides of the aircraft. They flash in a
repeating pattern and make an aircraft very visible, especially
at night. Landing lights are generally white and affixed to the
inboard sections of the wing, the front of the fuselage, or the
landing gear. Landing lights will be brightest when an aircraft
is coming towards the observer. Not all aircraft will have landing
lights on when flying at night so they should not be relied upon
to detect aircraft. Recognition lights are generally white and
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affixed to the sides of the aircraft. Unlike strobe lights, they do
not flash and generally point in the direction of flight much like
a landing light.
Not all aircraft are required to have lights when operating at
night. Some aircraft such as those used by law enforcement
pilots, military, and first responders may have mission
requirements that necessitate operations without lights. RPA
pilots and visual observers should be particularly alert for an
aircraft that may only be identifiable by sound.
3.2.27.3 Use of Lights
Pilots operating RPASs at night shall ensure their RPA is lighted
sufficiently to ensure the pilot and the visual observer (if used)
can maintain VLOS with the RPA. It’s the pilot’s responsibility
to ensure the lights are functioning prior to takeoff or launch.
3.2.27.4 Night Vision Goggles
Night vision goggles can be used to supplement the RPAS crew’s
view of the RPA but caution should be exercised as night vision
may inhibit the pilot’s ability to detect and avoid other aircraft.
Many aircraft are equipped with LEDs instead of the traditional
incandescent lights. These LED lights may emit light that is
outside the combined visible and near infrared spectrum of night
vision goggles and, as a result, may not visible. For this reason
it is required that all RPA crews have a method of detecting all
light within the visible spectrum. The simplest way to meet this
requirement is to employ a visual observer using unaided vision
as part of the detect and avoid system.
3.2.28 Multiple Remotely Piloted Aircraft (RPA)
Pilots may operate up to five RPAs from one control station
provided the system is designed for such an operation
(CAR 901.40). Special care must be taken when operating more
than one RPA from a single control station as there is a significant
risk the pilot can become distracted and lose track of one or
more of the RPAs.
The risks associated with this type of operation can be mitigated
by careful pre- planning and site surveys. Pilots should take
extra care to ensure that sufficient visual observers are employed
to ensure that each aircraft is kept within VLOS and monitored.
Piloting more than five RPAs from one control station requires
a Special Flight Operations – RPAS (see subpart 3.6).
3.2.29 Special Events
3.2.29.1 Special Aviation Events
An SFOC—RPAS for a special aviation event is needed when
a pilot is operating an RPA as a performer in this event (referred
to as an “airshow”). See CARs 901.41 and 903.01(f).
If the RPAS operation is not a performance that is part of the
special aviation event (i.e. the operation is conducted for taking
videos or photos of the event, or for surveillance or security
purposes), the SFOC—RPAS application is to be processed as
it would be for an advertised event.
3.2.29.2 Advertised Events
An SFOC—RPAS for an advertised event is needed when a pilot
is operating an RPAS less than 100 ft away from the boundaries
of an advertised event (CAR 901.41 and 903.01(f)). For reference,
see also the following sections and subpart in this chapter: 3.4.6—
Operations Near People, 3.4.7—Operations Over People, and
3.6—Special Flight Operations – RPAS.
The boundaries of an advertised event (outdoor event including
a concert, performance, festival, market, amusement park, or
sporting event) are limited by perimeter fences and the gates
where people are restricted by the event personnel, volunteers,
and security or peace officers.
Where no such perimeter is defined for outdoor advertised events
like marathons, triathlons, cycling, swimming, skiing, fishing
derbies, sailing, cruise ships, fireworks, and so on, it is expected
that the boundaries of the advertised event be at least 100 ft from
people participating in the advertised event and 100 ft from the
track of the sporting event for all categories of RPA pilot
certificates and models of RPAs.
3.2.30 Handovers
If an RPAS command handover is to be conducted during the
operation, a handover plan agreed upon by all responsible parties
has to be established before takeoff (CAR 901.42). The plan must
lay out the procedures to follow for the handover, the plan to
mitigate the loss of control during the handover, and the plan
for how the see and avoid measures are to be continued during
the exchange.
3.2.31 Payloads
Laser-based systems, including LIDAR, are becoming
increasingly popular payloads on RPASs for a number of
operations. Class 1 lasers, as designated by Health Canada, are
considered to be incapable of causing harm and will not create
a hazard to manned aircraft provided that they are operated as
per the manufacturer’s specification. If the laser equipment that
the operator intends to use is classified as Class 1 or Class 1M,
has an average output power of less than 1 mW, and utilizes a
non-visible beam, no further assessment or notification is
required. The operator is still responsible for safe operation
within the bounds of the manufacturer’s specifications and
operating instructions.
Operators who want to operate an RPAS fitted with laser
equipment other than the types noted in the previous paragraph
in accordance with the manufacturer’s instructions must notify
TC that they intend to operate a laser in airspace shared with
manned aircraft (CAR 601.21). RPAS operators shall complete
a Notice of Proposal to Conduct Outdoor Laser Operation(s)
and submit it to their TC regional office. An aeronautical
assessment is then conducted and the NOHD calculated by the
operator is validated. The normal processing time is at least 30
days to review the notification and determine if a laser
authorization can be issued.
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For more information and further guidance on the regulation of
lasers, refer to sections 601.20, 601.21, 601.22, and 901.43 of the
CARs.
In addition, if the RPA pilot intends to carry or deliver payloads
with an RPA, the pilot must also comply with Transportation
of Dangerous Goods Regulations and Canadian Transportation
Agency (CTA) regulations, as applicable.
A pilot may operate an RPAS when the aircraft is transporting
a payload referred to in CAR 901.43 (1) if the operation is
conducted in accordance with an SFOC—RPAS. For more
information, see section 3.6.1 of this chapter.
3.2.32 Flight Termination Systems
A Flight Termination System is a system that, upon initiation,
terminates the flight of an RPA in a manner so as not to cause
significant damage to property or severe injury to persons on
the ground. In order to avoid flyaway situations and safeguard
other airspace users, RPASs that lack redundancies may need
to have an independent flight termination system that can be
activated by the RPA pilot. The process and procedures for
initiating and activating a flight termination system vary
significantly depending the manufacturer and operating
procedures for each system. Initiation of a flight termination
system may only be done if it does not endanger aviation safety
or the safety of any person (CAR 901.44). Attachment of a flight
termination system to an RPAS which is not standard equipment
for the RPAS is a modification and must meet the requirements
of CAR 901.70.
3.2.33 Emergency Locator Transmitters (ELT)
RPAs are prohibited from being equipped with ELTs (CAR 901.45).
RPAs are permitted to have other types of tracking devices that
would allow pilots to locate them without notifying first
responders.
ELTs provide an emergency signal to SAR in the event of a
missing aircraft. In order to ensure valuable resources are not
dispatched to find missing aircraft where no life is at stake,
RPAs are not permitted to have ELTs on board. More information
on ELTs can be found in SAR part 3.0 Emergency Locator
Transmitter (ELT) of the TC AIM.
Pilots operating RPAs equipped with ELTs are subject to
individual penalties of up to $1,000 and/or corporate penalties
of up to $5,000.
3.2.34 Transponders and Automatic Pressure-
Altitude Reporting Equipment
Transponders augment the capabilities of ATS surveillance,
allowing ANSPs to determine an aircraft’s position and, when
a transponder is capable of pressure-altitude reporting, its altitude.
Small RPAs are not typically equipped with transponders and,
as a result, they pose a challenge from an air traffic surveillance
perspective due to their small size, low operating altitude and
lack of a common altitude reference system. For that reason,
ANSPs cannot offer these aircraft the same, traditional air traffic
services (i.e. aircraft separation or conflict resolution) that they
provide to VFR or IFR aircraft.
In order to ensure the safe operation of all aircraft in controlled
airspace, RPAs need to obtain authorization from the ANSP (either
NAV CANADA for civil-controlled airspace or the Department
of National Defence in the case of military-controlled airspace)
before operating in controlled or transponder airspace.
3.2.34.1 Transponder-required Airspace
Transponders are required in all Class A, B, and C airspace as
well as some Class D and Class E airspace. The requirement for
a transponder in Class D and E airspace can be found in the
DAH (CAR 601.03). Additional information can be found in
COM subpart 8.2 of the TC AIM.
3.2.34.2 Transponder Requirements
ANSPs may allow an RPAS to enter transponder-required airspace
without a transponder if the pilot requests permission prior to
entering the area and aviation safety is not likely to be affected
(CAR 901.46(2)). Except when permitted by the ANSP, all aircraft
flying in transponder-required airspace including RPAs are
required to have transponders (CAR 901.46(1)).
The decision as to whether aviation safety is likely to be affected
depends on a variety of factors that may not be readily apparent
to the RPA pilot. These factors may include the volume of air
traffic in the area, a potential emergency or priority situation,
system capability, equipment failures, and a myriad of other
factors. RPA pilots should understand that ANSPs may not be
able to grant all requests to enter transponder airspace without
a transponder. Flexibility and patience on the part of the pilot
will be required.
Entering transponder airspace without a transponder or without
permission from the ANSP puts other aircraft in the area at risk
and may result in individual penalties of up to $1,000 and/or
corporate penalties of up to $5,000.
3.2.35 Operations at or in the Vicinity of an
Aerodrome, Airport, or Heliport
Operations in the vicinity of or at aerodromes, airports, and
heliports are higher risk. Operations inside a 3-NM (5.6 km)
radius from the centre of airports or a 1-NM (1.8 km) radius
from the centre of heliports are prohibited to RPA pilots holding
a basic certificate (CAR 901.47).
Operations inside a 3-NM (5.6 km) radius from the centre of
airports or a 1-NM (1.8 km) radius from the centre of heliports
are reserved for RPA pilots holding an advanced certificate.
When operating an RPA in the vicinity of an airport or heliport
located outside controlled airspace, the RPA pilot should establish
communication with the aerodrome operator. RPAs should stay
clear of the established traffic pattern and shall give way at all
times to manned aircraft (CAR 901.17).
If the airport or heliport is inside controlled airspace, the RPA
pilot needs an advanced pilot certificate, has to receive an
authorization from the appropriate ANSP as described in section
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3.4.4 of this chapter, and requires a manufacturer declaration
that the RPA meets the appropriate safety assurance profile as
described in section 3.4.3 of this chapter. See subsection 3.2.3.2
for information about RPA operation in controlled airspace. See
section 3.4.5 of this chapter for information on the established
procedure (as per CAR 901.73) and communication with an
airport or heliport located outside controlled airspace
An aerodrome means any area of land, water (including the
frozen surface thereof) or other supporting surface used,
designed, prepared, equipped, or set apart for use either in whole
or in part for the arrival, departure, movement, or servicing of
aircraft and includes any buildings, installations, and equipment
situated thereon or associated therewith. All registered and
certified aerodromes are listed in the CFS or the CWAS.
An airport means an aerodrome in respect of which an airport
certificate issued under Subpart 302 of the CARs is in force. In
practice, you can tell if an aerodrome has a certificate by looking
in the CFS for the word “Cert” in the Operator (OPR) section.
A heliport means an aerodrome in respect of which a heliport
certificate issued under Subpart 305 of the CARs is in force.
An operation within 3 NM (5.6 km) of an aerodrome conducted
under the authority of the Minister of National Defence is possible
if the operation is conducted in accordance with an SFOC—
RPAS. To be issued an SFOC for the operation of an RPA within
3 NM of an aerodrome operated under the authority of the
Minister of National Defence (CAR 903.01(h)), the pilot must
receive authorization from the Department of National Defence
aerodrome authorities. If the aerodrome is in controlled airspace,
the pilot needs an advanced RPA pilot certificate and requires
a manufacturer declaration stating that the RPA meets the
appropriate safety assurance profile as described in section 3.4.3
of this chapter. See section 3.6.1 for information about SFOC—
R PAS.
3.2.36 Records
Every owner of an RPAS shall keep a record containing the
names of the pilots and other crew members who are involved
in each flight and, in respect of the system, the time of each
flight or series of flights. This record shall be available to the
Minister on request and is retained for a period of 12 months
after the day on which it is created (CAR 901.48 1)(a)).
Every owner of an RPAS shall keep a record containing the
particulars of any mandatory action and any other maintenance
action, modification, or repair performed on the system, including
the names of the persons who performed them and the dates
they were undertaken. In the case of a modification, the
manufacturer and model, as well as a description of the part or
equipment installed to modify the system and, if applicable, any
instructions provided to complete the work are required. This
record shall be available to the Minister on request and is retained
for a period of 24 months after the day on which it is created
(CAR 901.48(1)(b)).
Every owner of an RPAS who transfers ownership of the system
to another person shall also deliver to that person at the time of
transfer all of the records containing the particulars of any
mandatory action and any other maintenance action, modification,
or repair performed on the system (CAR 901.48(3)).
3.2.37 Incidents and Accidents
A pilot who operates an RPA shall immediately cease operations
if any of the listed incidents or accidents (CAR 901.49(1)) occur,
until such time as an analysis is undertaken as to the cause of
the occurrence and corrective actions have been taken to mitigate
the risk of recurrence:
(a) injuries to any person requiring medical attention;
(b) unintended contact between the aircraft and persons;
(c)
unanticipated damage incurred to the airframe, control
station, payload, or command and control links that adversely
affects the performance or flight characteristics of the
aircraft;
(d)
any time the aircraft is not kept within horizontal boundaries
or altitude limits;
(e) any collision with or risk of collision with another aircraft;
(f ) any time the aircraft becomes uncontrollable, experiences
a flyaway, or is missing; and
(g)
any incident not referred to in paragraphs (a) to (f) for which
a police report has been filed or for which a CADORS report
has resulted.
The RPA pilot shall keep a record of the incident or accident
analyses for a period of 12 months after the day on which the
record is created and make it available to the Minister on request
(CAR 901.49(2)).
If any incident or accident occurs while an RPA is being operated
under an SFOC—RPAS, it shall be reported to TC using the
RPAS Aviation Occurrence Reporting Form sent with the issuance
of the SFOC—RPAS.
In addition to the criteria listed in CAR 901.49, certain types of
RPAS occurrences need to be reported to the TSB, including
when:
(a)
an RPA weighing more than 25 kg is involved in an accident,
as defined by paragraph 2(1)(a) of the TSB Regulations; or
(b) a person is killed or sustains a serious injury as a result of
coming into direct contact with any part of a small RPA
(an aircraft with a maximum take-off weight of at least
250 g [0.55 lb] but not more than 25 kg [55 lb]), including
parts that have become detached from the small RPA; or
(c)
a collision occurs between an RPA of any size or weight
and a manned aircraft.
The purpose of an aviation safety investigation into an aircraft
accident or incident is to prevent a reoccurrence; it is not to
determine or assign blame or liability. The TSB, established
under the CTAISB Act, is responsible for investigating all aviation
occurrences in Canada involving civil aircraft registered both
in Canada and abroad. A team of investigators is on 24-hr standby.
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TC AIM GEN 3.0 provides additional information on aircraft
accident reporting to the TSB, including time limits and what
information to report. An RPA is defined as an aircraft in
the CARs.
3.2.38 Tethered Drone
CAR 101.01 defines a remotely piloted aircraft (RPA) as “a
navigable aircraft, other than a balloon, rocket, or kite that is
operated by a pilot who is not on board.”
Therefore, when a drone that is not designed to be navigable is
tethered to the ground in a way that prevents it from being
steered, manoeuvred or piloted, it no longer meets the definition
of an RPA and the regulatory requirements contained in Part IX
of the CARs no longer apply; instead, operators of tethered
objects must meet the obstruction requirements of CAR
Standard 621 Chapter 11.
This interpretation recognizes that drones that are prevented
from being navigated along a path pose a different set of hazards
from drones that are free-flying. If the RPA is being manoeuvred
or the navigation is controlled while on the tether, it is navigable
and it once again meets the definition of an RPA, and Part IX
of the CARs will apply.
A tether can be used to extend the flight time of the RPAS by
supplying power to the RPA from the ground. A tether can also
be used as a means to mitigate the risk of the flyaway by physically
restricting the drone from reaching certain locations. A tether
should not be used as a means to circumvent or exempt an
operation from the safety requirements of Part IX.
As an example:
(a) A drone tethered to the ground by a power cable hovering
at a specific location without pilot input while it serves to
boost a communication signal does not meet the definition
of an RPA.
(b) An RPA attached to a line while it is being manoeuvred or
navigated by a pilot does meet the definition of an RPA,
and the regulations governing sRPASs apply.
(c)
A tether should not be used for the sole purpose of exclusion
from the safety requirements of Part IX. Tethered RPAs
should comply with the requirements of Part IX that are
applicable to the type of operation being performed.
The addition of a tether is considered a modification to an RPA.
Therefore, if a safety assurance declaration has been made under
CAR section 901.76 for Advanced Operations, the installation
of a tether will invalidate these safety assurance declarations
unless (a) the modification was performed according to the
instructions from the manufacturer of the part or equipment
used to modify the system (CAR 901.70(b)), or (b) the pilot
installing the tether is able to demonstrate that the system
continues to meet the technical requirements set out in
Standard 922—RPAS Safety Assurance that are applicable to
the operations referred to in subsection 901.69(1) for which the
declaration was made (CAR 901.70(a)).
Best practices dictate that tethered RPA operations should not
be conducted closer to people than the length of the tether
restraining the RPA plus at least 5 m. For example, if the length
of the tether is 120 m, a safety margin of more than 125 m from
people extending laterally from the point the tether is attached
to the ground should be maintained. Moreover, to mitigate
significant risk of injuries or damages, sufficient space is to be
allocated to allow for post-crash RPA flying debris (e.g. spinning
rotor components can be flung a great distance). This is to be
taken into account at the planning stage and confirmed during
the site survey.
3.3 Basic opeRations
3.3.1 General
Basic Operations require sRPA pilots to have the necessary
qualifications and skills.
Basic Operations are for those intending to operate an RPA:
(a) in uncontrolled airspace (CAR 901.14);
(b) at a distance of 100 ft (30 m) or more from another person
except from a crew member or other person involved in the
operation (CAR 901.26);
(c) at a distance of three nautical miles (5.6 km) or more from
the centre of an airport or an aerodrome operated under the
authority of the Minister of National Defence or one nautical
mile (1.8 km) or more from the centre of a heliport (CAR
901.47).
For more information, refer to 3.2.35 Operations at or in the
Vicinity of an Aerodrome, Airport, or Heliport.
Pilots carrying out Basic RPA operations without a Pilot
Certificate—Small Remotely Piloted Aircraft (for basic or
advanced operations) may be subject to individual penalties of
up to $1,000 and/or corporate penalties of up to $5,000.
3.3.2 Pilot Requirements
3.3.2.1 Pilot Certificate
A Pilot Certificate—Small Remotely Piloted Aircraft (VLOS)—
Basic Operations is issued by the Minister to those that are at
least 14 years of age and have successfully completed the RPAS
Basic Operations examination (CAR 901.54, 901.55). A person
of less than 14 years of age may fly in basic operations if they
are under the direct supervision of the holder of a basic or
advanced RPA pilot certificate (CAR 901.54 (2)).
3.3.2.2 Recency Requirements
Holders of the Basic or Advanced RPA pilot certificate must
keep up their skills and knowledge by showing that they have
met the recency requirements within the last 24 months (section
921.04 of CAR Standard 921). This involves being issued a Basic
or Advanced RPA pilot certificate (CAR 901.55 or 901.64) and
successfully completing a flight review (CAR 901.64(c)) or
recurrent training (section 921.04 of CAR Standard 921), including
attendance of a safety seminar or self-paced study program
endorsed by Transport Canada Civil Aviation (TCCA), or
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completion of an Advanced RPAS recurrent training program
which includes human factors, environmental factors, route
planning, operations near aerodromes/airports, and applicable
regulations, rules and, procedures.
RPA pilots who fail to maintain recency but continue to undertake
operations may receive individual penalties of up to $1,000 and/
or corporate penalties of up to $5,000.
3.3.2.3 Access to Certificate and Proof of Currency
When operating an RPAS, the pilot must be able to easily access
both their Basic or Advanced RPA pilot certificate (CAR 901.55
and 901.64) and documentation demonstrating recency
(CAR 901.56).
RPA pilots failing to demonstrate recency may receive individual
penalties of up to $1,000 and/or corporate penalties of up
to $5,000.
3.3.2.4 Examination Rules
It is not permitted to copy or remove all or any portion of the
RPAS examination, to help or accept help from any person
during the examination, or to complete any portion of the
examination on behalf of any other person (CAR 901.58). If a
person fails the examination or flight review they must wait at
least 24 hours before a retake (CAR 901.59).
3.3.3 Small Remote Pilot Aircraft (sRPA)
Requirement
No RPA manufacturer declaration is needed for Basic operations
but the RPA needs to be operated in accordance with the
manufacturer’s instructions (CAR 901.31). The sRPA must have
an issued registration number issued that is clearly visible on
the remotely piloted aircraft (CAR 901.03 and 901.05).
3.4 advanced opeRations
3.4.1 General
Advanced Operations are for those intending to operate an RPA
(CAR 901.62):
(a) in controlled airspace;
(b) near people (horizontally less than 30 m, up to 5 m);
(c) over people (horizontally less than 5 m over people);
(d)
within 3 NM from the centre of an airport or a military
aerodrome; or
(e) within 1 NM from the centre of a heliport.
RPA pilots require the necessary qualifications and skills and
must follow the established procedures of airports and heliports
(CAR 901.73) and operate an RPA that has a manufacturer safety
assurance declaration for the type of operations and distances
from people (CAR 901.76(1)). The manufacturer’s safety assurance
declaration eligibility is written on the RPAS certificate of
registration.
RPA pilots carrying out advanced operations without the
advanced RPA pilot certificate and necessary RPA manufacturer’s
safety declarations may receive individual penalties of up to
$1,000 and/or corporate penalties of up to $5,000.
3.4.2 Pilot Requirements
3.4.2.1 Pilot Certificate
A Pilot Certificate—Remotely Piloted Aircraft (VLOS)—
Advanced Operations is issued by the Minister to those that
have demonstrated they are at least 16 years of age and have
successfully completed the RPAS Advanced Operations
examination and flight review (CAR 901.64). A person younger
than 16 years of age or a person undergoing a flight review may
fly in advanced operations if they are under the direct supervision
of the holder of an Advanced RPA pilot certificate (CAR 901.64(c)).
3.4.2.2 Recency Requirements
Holders of the Advanced RPA pilot certificate must keep up
their skills and knowledge by showing that they have met the
recency requirements (CAR 901.65) within the last 24 months.
This involves being issued a pilot certificate (CAR 901.64) and
completing a flight review (CAR 901.64(c)) or a recurrent training
program (section 921.04 of CAR Standard 921), including
attendance of a safety seminar or self-paced study program
endorsed by Transport Canada Civil Aviation, or completion of
an Advanced RPAS recurrent training program which includes
human factors, environmental factors, route planning, operations
near aerodromes/airports, and applicable regulations, rules, and
procedures.
RPA pilots failing to maintain recency that continue to undertake
operations may be subject to individual penalties of up to $1,000
and/or corporate penalties of up to $5,000.
3.4.2.3 Access to Certificate and Proof of Currency
When operating an RPAS, the pilot must be able to easily access
both their advanced RPA pilot certificate (CAR 901.64) and
documentation demonstrating recency (CAR 901.65).
RPA pilots failing to demonstrate recency may be subject to
individual penalties of up to $1,000 and/or corporate penalties
of up to $5,000.
3.4.2.4 Examination Rules
It is not permitted to copy or remove all or any portion of the
RPAS examination, to help or accept help from any person
during the examination, or to complete any portion of the
examination on behalf of any other person (CAR 901.58). If a
person fails the examination or flight review they must wait at
least 24 hours before a retake (CAR 901.68).
3.4.3 Manufacturer Declaration
Advanced operations require that the manufacturer of an RPA
provide the Minister with a safety assurance declaration
(CAR 901.76) stating that it is intended for these advanced
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operations (CAR 901.69), has all necessary documentation
(CAR 901.78), and meets the technical requirements set out in
CAR Standard 922—RPAS Safety Assurance. The RPA eligibility
is written on the RPA’s certificate of registration.
Advisory Circular (AC) 922-001—RPAS Safety Assurance
provides a means (but not the only means) of compliance to the
technical requirements in CAR Standard 922. AC 922-001 is a
good place for RPAS manufacturers to start their due diligence
with respect to compliance. AC 922-001 is available at <https://
tc.canada.ca/en/aviation/reference-centre/advisory-circulars>.
Manufacturers failing to maintain or demonstrate adherence to
these requirements may be subject to individual penalties of
$3,000 and/or corporate penalties of $15,000.
3.4.4 Operations in Controlled Airspace
Operations in controlled airspace are advanced operations, and
the RPAS must have the relevant manufacturer’s safety assurance
declaration (CAR Standard 922), which states that the RPA has
the required positional accuracy, at least +/- 10 m laterally and
+/- 16 m altitude. The required accuracy for operations within
controlled airspace is identified for purposes of communications
with other users of the airspace (e.g. the control tower) in order
to provide a minimum confidence related to the altitude and
position reports from an RPA pilot (CAR Standard 922.04). This
eligibility, stipulated in 922.04, is written on the RPAS certificate
of registration.
The ANSP unit may approve the use of airspace above 400 ft AGL
only within the airspace under that unit’s jurisdiction, subject
to all other provisions (CAR 901.71(2)).
The RPA pilot must communicate with the ANSP in the area of
operations in advance of the operations. A pilot may not operate
an RPA in controlled airspace unless he or she has received a
written RPAS Flight Authorization from the ANSP (CAR
901.71(1)). The pilot must then comply with all instructions given
by the ANSP (901.72).
An RPA flight authorization can be completed and obtained
using NAV CANADA’s drone flight planning tool at <https://
www.navcanada.ca/en/flight-planning/drone-flight-planning.
aspx>.
The following information is required:
(a) the date, time, and duration of the operation;
(b)
the category, registration number, and physical characteristics
of the aircraft;
(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 ATC unit will be maintained;
(g)
the name, contact information, and pilot certificate number
of any pilot of the aircraft;
(h) the procedures and flight profiles to be followed in the case
of a lost command and control link;
(i) the procedures to be followed in emergency situations;
(j)
the process and the time required to terminate the operation;
and
(k)
any other information required by the ANSP that is necessary
for the provision of air traffic management.
3.4.5 Operations at or in the Vicinity of an Airport
or Heliport—Established Procedure
Advanced RPA pilots are required by CAR 901.73 to conduct
their operations in accordance with the established procedure.
The official TC established procedure is stated below and should
be followed when the pilot is operating an RPA in an advanced
environment at or in the vicinity of an uncontrolled airport,
heliport, or water airport. Please also refer to the Drone Site
Selection Tool or NAV CANADA’s drone flight planning tool.
RPA pilots must make every reasonable attempt to contact the
airport, heliport, or water airport operator to fly within the zones
indicated by orange-shaded shapes on the Drone Site Selection
Tool or NAV CANADA’s drone flight planning tool. If unable
to establish communications with air traffic through the airport
operator, the advanced RPA pilot should establish communications
with and avoid other aircraft using standard radio and visual
procedures.
TC established procedure:
(a) Ensure that you have a pilot certificate—RPA (VLOS)—
advanced operations.
(b)
Adhere to the CARs, and prior to your RPA operation,
consult the CFS to research the airport/heliport/water airport
where operations are to be conducted so that you understand
the relevant information.
(c) Contact the airport operator to establish communications
and exchange information regarding air traffic for the
duration of the proposed operation.
(d)
Comply with the airport operator’s guidance, schedule, and
other requests.
(e)
If you are unable to establish communications with the
airport operator, contact air traffic on the applicable
frequency found in the CFS. This could mean making a
general position report initially to attract attention and
inform other airport airspace users. Use standard radio
communication procedures. The person operating the VHF
Radio must have a valid Restricted Operator Certificate
with Aeronautical Qualification (ROC-A). TC AIM COM 1.0
provides additional information on radiotelephony
procedures.
A radio call generally consists of four parts: the call-up, the
reply, the message, and the acknowledgement, for example:
(i) Pilot Call-up:
(A)
Who you are talking to—Determine if it is
airport traffic or a specific aircraft.
(B)
Who you are—Include the category of the
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aircraft you are operating (RPA).
(C) Where you are—Provide cardinal quadrant or
distance and direction relative to the runway
as well as the RPA’s altitude in feet ASL, which
is the standard in aviation.
(ii) Station Reply: Wait for a reply on that frequency.
(iii)
Pilot Message: State your intentions and the duration
of the operation.
(iv) Station Acknowledgement: Wait for an
acknowledgement on that frequency.
(f )
Respect the limits of the privileges granted by your TC
RPAS certificate with regards to Part IX of the CARs.
(g)
Always give way to manned aircraft and keep the RPAS
within VLOS (CAR 901.11, 901.17, and 901.18).
RPA pilots should note that they are not obligated to follow this
established procedure if their operational area is located outside
of the orange-shaded areas depicted on the Drone Site Selection
Tool or NAV CANADA’s drone flight planning tool. The
procedure is applicable only if pilots are within uncontrolled
airspace. The orange areas on the Drone Site Selection Tool or
NAV CANADA’s drone flight planning tool represent the areas
with the highest air traffic due to approach, landing, and take-off
patterns at the airport/heliport/water airport in question and are
therefore protected.
Even if no established procedure is in place for the area outside
of the orange areas on the Drone Site Selection Tool and
NAV CANADA’s drone flight planning tool, pilots are required
to apply due diligence. If a pilot chooses to fly in these areas
and sees other aircraft being operated, it is recommended that
the pilot land the RPA and reassess the situation. If regular
aircraft activities are observed in those areas, it is recommended
that RPA pilots contact the airport/heliport/water airport operator
to have a better understanding of the local traffic patterns and
to coordinate their operations.
Although registered and certified aerodrome operators can
prohibit someone from using their ground installations, they
cannot forbid the use of the airspace surrounding a registered
or certified aerodrome. Airspace access is regulated through
the CARs, and any aircraft and pilot meeting the requirements
therein could use the airspace.
NOTE:
Under Section 5.1 of the Aeronautics Act, only the Minister or
delegate can restrict access to airspace: <https://laws.justice.
gc.ca/eng/acts/A-2/page-7.html>.
3.4.6 Operations Near People
Operations near people (section 922.05 of CAR Standard 922)
are those less than 100 ft (30 m) but more than 16.4 ft (5 m)
horizontally from people, except for the crew or people involved
in the operation. For these operations, the pilot must have their
Advanced RPA pilot certificate (CAR 901.64) and the RPAS
must have the relevant Manufacturer’s Declaration (CAR 901.76).
This eligibility, stipulated in CAR Standard 922, is written on
the RPAS certificate of registration.
3.4.7 Operations Over People
Operations that pose the highest risks when it comes to the
system reliability of the RPAS are those over people (CAR
922.06) less than 16.4 ft (5 m) away who are not included in the
crew and are not involved in the operation. For these operations,
the pilot must have his or her Advanced RPA pilot certificate
(CAR 901.64), and the RPAS must have the relevant manufacturer’s
declaration (CAR 901.76) required by Standard 922—RPAS
Safety Assurance, confirming that no single failure of the RPAS
may result in severe injury to a person on the ground and that
any combination of failures of the RPAS which may result in
severe injury to a person on the ground must be shown to be
remote. This 922.06 eligibility is written on the RPAS certificate
of registration.
3.4.8 RPA Modification
Modifications to an RPAS that has a safety assurance declaration,
including the addition of add-on equipment, should be made in
accordance with the manufacturer’s recommendations
(CAR 901.70). The integration of third-party add-on equipment,
changes to an RPAS structure or electrical systems (hardware
and software), or any other changes that are not within the
manufacturer’s specifications may constitute a modification to
an RPAS. Modifications that do not impact the original RPAS
Safety Assurance declaration and thus do not alter the declared
capabilities of the RPAS do not require notification to the Minister.
An RPAS must still be operated within the operating limits as
defined by the RPAS manufacturer (CAR 901.31) who made the
RPAS Safety Assurance declaration. Modifications that can
affect the declared capabilities of the original RPAS, add
additional advanced operating capabilities, or have an adverse
effect on the safety or “airworthiness” of the original RPAS
require a new RPAS Safety Assurance declaration to the Minister
as a modified RPAS by the party making the modification.
It is the responsibility of the party making the modification or
adding equipment to evaluate whether there is an effect on the
declared capabilities of that RPAS and that the RPAS remains
within the published specifications from the manufacturer. The
evaluation on the impact the modifications may have should
ensure that the modification or add-on equipment can be
integrated safely with existing systems and does not introduce
new failure conditions not accounted for in the original design
by the manufacturer. If the modification can affect the declared
capabilities of the original RPAS, or the party making the
modification does not possess the technical information on the
original design to properly conduct the evaluation, the RPAS
manufacturer declaration is invalidated and the RPAS is limited
to operations in Basic environments only, unless the RPAS
modifier makes a new safety assurance declaration. A modifier
that makes a declaration for a modified RPAS takes on the same
regulatory responsibilities as a declared RPAS manufacturer
(CAR 901.76). AC 922-001—RPAS Safety Assurance serves as
guidance to the considerations that should be made for parties
making safety assurance declarations.
The addition of a parachute system may constitute a modification
if its integration affects the ability of the RPAS to continue to
meet its declared capabilities, or it serves to add additional
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operating capabilities, such as operations over people. The
inclusion of a parachute on its own does not allow the RPA to
operate over people; rather, a safety assurance declaration for
operations over people is required (CAR Standard 922.06).
Operators of RPA equipped with parachute systems are
responsible for ensuring they have properly registered their RPA
to reflect the operating environments afforded by the parachute,
and that the RPA is operated within the published limitations
from the manufacturer (including but not limited to altitude,
wind, temperature, or other operational limits and minimums).
For example, if the parachute manufacturer has identified a
minimum deployment altitude for their parachute to function,
it is the RPA pilot’s responsibility to ensure that they abide by
this operational limitation and fly above the manufacturer’s
stated altitude minimum. RPA operated outside of the
manufacturer’s operational limitations are not considered to be
within the declared capabilities of the RPAS and are not safe
for flight (CAR 901.31).
3.5 Flight RevieweRs
3.5.1 General
The flight review is an in-person, holistic operational assessment
of an RPA pilot’s skills. Flight reviews are conducted by qualified
flight reviewers who have undergone additional Transport Canada
testing and are monitored closely by both the self-declared RPAS
training organization with which they associate as well as
Transport Canada. In addition to confirming that advanced
category applicants have the CARs-required documentation—
pre-flight information (CAR 901.24), normal checklists,
emergency checklists, and site survey (CAR 901.27)—they are
also acting to validate the identity and knowledge of the candidate
as well as their operational and flight skills.
3.5.2 Pilot Requirements
3.5.2.1 Flight Reviewer Rating
Flight Reviewers must meet and maintain several requirements
before they are able to qualify as flight reviewers. Flight reviewers
must be over 18, have a good record with respect to aviation,
and have no enforcement action against them, past or pending.
They are expected to read, understand, and comply with TP115395
(Flight Reviewer’s Guide for Pilots of RPAS) and meet the
knowledge requirements outlined in TP-15263 (Knowledge
Requirements for Pilots of sRPAS). Additionally, they must hold
an Advanced RPA pilot Certificate for at least 6 months before
qualifying to write the flight reviewer exam to receive the
endorsement and must remain affiliated with a TP-15263 Self-
Declared RPAS Training provider to exercise the privileges of
their endorsement.
3.5.2.2 Examination
The flight reviewer exam is available in the Drone Management
Portal to Advanced Certificate holders with more than 6 months
of experience. The examination is 30 questions, requires a mark
of 80% to pass, and focuses on both advanced category operations
and flight review requirements. Once successful, applicants pay
a fee to have the flight reviewer endorsement added to their pilot
certificate. To exercise the privileges of a flight reviewer, the
reviewer must remain associated to at least one TP15263 Self-
Declared RPAS Training Provider, though multiple associations
are also permitted.
3.5.3 Conduct of Flight Reviews
Flight reviews are conducted in-person at a site of the candidate’s
choosing. They can be conducted in controlled or uncontrolled
airspace though as the flight review itself is not exempt from
complying with Part IX of the CARs. The applicant must be
able to meet the requirements to operate the RPA within that
airspace with the exception of having the Advanced RPA pilot
certificate.
Prior to the flight review, the candidate may be assigned by the
flight reviewer of an advanced RPA operational type of mission.
This will be used during the ground portion of the flight review
to validate the candidate’s ability to plan and execute an advanced
RPA operation.
Only an sRPA (250 g to 25 kg) may be used to conduct a flight
review. Standard 921.06(1)(c)(i) states the RPA used for the flight
review must be registered under CAR 901.02: <https://tc.canada.
ca/en/corporate-services/acts-regulations/list-regulations/
canadian-aviation-regulations-sor-96-433/standards/standard-
921-small-remotely-piloted-aircraft-visual-line-sight-vlos-
canadian-aviation-regulations-cars>.
The flight review consists of both ground-based and flight
assessment items. If any of the eight assessed items are determined
to not meet the requirements or if the candidate displays unsafe
flying or behaviour, does not complete an appropriate site survey,
lacks training or competency, or does not use effective scanning
techniques, the flight review is marked a failure. Candidates
who have failed flight reviews may reattempt after 24 hours
have elapsed.
Following a successful flight review, the flight reviewer shall
enter the required information into the Drone Management
Portal within 24 hours. The successful candidate will then be
automatically notified via email and routed to the Drone
Management Portal to pay for the issuance of the Advanced
RPA pilot certificate.
3.6 special Flight opeRations—Rpas
3.6.1 General
Not every operational consideration can be addressed through
regulation. This is particularly true in industries where technology
is rapidly evolving, such as the RPAS industry.
Subpart 3 of CARs Part IX allows the Minister to issue an
SFOC—RPAS to allow certain operations that are not covered
by the Part IX regulation. These operations include:
(a) RPAS with a maximum take-off weight greater than 25 kg;
(b) BVLOS operations;
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(c) foreign operators;
(d) operation at altitudes greater than 400 ft AGL;
(e)
operation of more than 5 RPAs from a single control station;
(f ) operation at a special aviation event or an advertised event;
(g) operations with restricted payloads;
(h)
operations within 3 NM of an aerodrome operated under
the authority of the Minister of National Defence;
(i) any other operation determined by the Minister to require
an SFOC.
3.6.2 Application for a Special Flight Operations
Certificate (SFOC)—RPAS
Guidance to complete an application for the issuance of an
SF O C — R PA S on Transport Canada’s Web site
(<https://tc.canada.ca/en/aviation/drone-safety?utm_
campaign=tc-drone-safety-ongoing&utm_medium=vurl&utm_
source=canada-ca-drone-safety>) as well as
Advisory Circular (AC) 903-002—
Application Guidelines for
a Special Flight Operations Certificate for a Remotely Piloted
Aircraft System (SFOC—RPAS)
, available at <https://tc.canada.
ca/en/aviation/reference-centre/advisory-circulars>.
The applicant should be able to demonstrate an operational need
for the type of certificate requested as well as a robust risk
management plan that not only identifies any possible hazards
associated with the proposed operation and their corresponding
risks, but also proposes a plan to mitigate them. AC 903-001—
Remotely Piloted Aircraft Systems Operational Risk Assessment
(RPAS ORA) provides information and guidance to manufacturers
and operators intending to develop or operate an RPAS for
operations in accordance with the requirements of Part IX,
Subpart 3 of the CARs.
Applicants should anticipate at least 30 working days of lead
time to receive an SFOC but should be aware that, depending
on the complexity of the operation and the completeness of the
application, it could be longer.
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