Professional RPAS Drone Pilot Certification

RPA-Remotely Piloted Aircraft

3.2.3.2 Controlled Airspace

RPA pilots are required to keep their RPA clear of controlled airspace unless:

• the pilot holds a pilot certificate—RPA (VLOS)—advanced operations as described in section 3.4.1 of this chapter;
• 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
• 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.

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 Designated Airspace Handbook (DAH) (TP 1820) 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>.

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.

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.

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.

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.

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.

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. Class F airspace is identified on all VNCs and VTAs as well as in the DAH, using NAV Drone Viewer and the NRC Drone Site Selection Tool. The DAH is updated every 56 days and is available on the NAV CANADA Web site at <https://www.navcanada.ca/en/aeronautical- information/operational-guides.aspx/#093dcf9f312e43df922d ec86e7f295d7>.

Class F Restricted Airspace

Class F restricted airspace is denoted as CYR followed by three numbers (e.g. CYR123) and should be avoided by all aircraft, including all RPAs, except by those approved by the user agency identified in the DAH. The letter D for danger area will be used if the restricted area is established over international waters. CYRs can be found over prisons and some military training areas, for example. Additional information about restricted airspace can be found in RAC 2.8.6 and 2.9.2. 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.

Class F Advisory Airspace

Class F advisory airspace is denoted as CYA followed by three numbers (e.g. CYA123). 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 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.

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 f light 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 Defense, 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.

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.

3.2.3 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

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 the RPA pilot sees a traditional aircraft approaching the area of RPAS operation, they shall take immediate action to avoid any risk of conflict. If a conflict 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 a conflict or 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 practice “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 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

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:

(a)  Bright illumination: reflected off of clouds, water, snow, and desert terrain; produces glare resulting in eye strain.

(b)  Dark Adaptation: Eyes must have at least 20 to 30 minutes to adjust to reduced light conditions.

(i)  Red light helps night vision; however, it distorts colour and makes details hard to perceive;

(ii) 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.

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 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.

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

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 pharmaceuticals 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 pharmaceuticals 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, pharmaceuticals, or a combination of both. All aircraft pilots and crew members must remain fit to fly.

If an RPA pilot takes prescription pharmaceuticals, 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 RPAS.

Fatigue is as dangerous as pharmaceuticals 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 pharmaceuticals 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.

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

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 pharmaceuticals 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 when they are crew members of a small RPA (VLOS) carrying out basic or advanced operations.

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.

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 small RPAs. 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 Aeronautics Act and CARs do not explicitly define what a living creature constitutes. However, TCCA’s interpretation is that the word “creature” refers to and is synonymous with Kingdom Animalia (insects, mammals, birds, etc.), as per the biological definition. Bacteria are not animals; therefore, it is our interpretation that they do not qualify as living creatures under CAR 901.22.

The operation of a small RPA 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.

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.

3.2.11 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 f light 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 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.

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.

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.

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.

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.

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.

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.

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 f light 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.

Station Height

Station height is the altitude measured at a weather reporting station, often an aerodrome, relative to sea level.

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.

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

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.

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.

(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 6 076.1 ft, 1 852 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.

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 1:250000. 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 (CWAS).

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 area of operation, it is recommended that you use resources such as the Drone Site Selection Tool, the NAV Drone Viewer (at <https://www. navcanada.ca/en/flight-planning/drone-flight-planning.aspx>), 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 subsection 3.2.3.2 of this chapter. Additional information can be found in the DAH and in RAC 2.8.

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;

(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 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 small RPA pilots are different from those of more traditional aircraft pilots and even large RPAs. For small RPAs, 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

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 f lights. 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 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.

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 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 f light 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 Urban Airflow

Figure 1.1—Urban Airflow Characteristics, SDSTV

TC would like to remind you of the potential environmental challenges of flying an RPA in urban areas. Provided you are authorized to fly an RPA in urban areas, exercise caution when flying due to unforeseen changes in wind characteristics caused by tall buildings and structures. These changes can include increased wind gusts exceeding the RPA limits, as well as shifts in direction which can blow the RPA off course.

TC worked with National Research Council Canada (NRC) on a video to help you understand some of the impacts: <https:// tc.canada.ca/en/aviation/drone-safety/tips-best-practices-drone- pilots/urban-airflow-what-drone-pilots-need-know>.

3.2.22.10 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 f light 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.

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

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.

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.

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 affixed to the sides of the aircraft. Unlike strobe lights, they do not flash and generally point in the direction of f light 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 an SFOC—RPAS (see subpart 3.6).

3.2.18 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 specifications. 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.

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 the Transportation of Dangerous Goods Regulations (TDG Regulations) and the Canadian Transportation Agency’s (CTA’s) Air Transportation Regulations (ATR), as applicable.

More information on the TDG Regulations can be found in RAC Annex 12.3 and at <https://tc.canada.ca/en/dangerous-goods/ transportation-dangerous-goods-canada>.

More information on the CTA’s ATR can be found at <https:// www.canada.ca/en/transportation-agency.html> and <https:// laws-lois.justice.gc.ca/eng/regulations/SOR-88-58/index.html>.

RPA are considered aircraft according to the CARs. The Transportation of Dangerous Goods Act (TDG Act) (by air) and the CTA detail various requirements for when products or people are transported by aircraft. As the Act and the Agency do not separate RPA and simply use the term “aircraft,” this also includes remotely piloted aircraft.

Before transporting items of any kind from one location to the next, the CTA’s ATR must be considered. This is outside of the scope of Part IX of the CARs but is applicable if you are operating an RPA under Subpart 1 of Part IX of the CARs (901.xx), or with an SFOC—RPAS issued under section 903.03. There are exceptions within the CTA’s ATR that may be applicable in some cases, which is why the CTA’s ATR need to be considered for all operations.

Before transporting goods that may be considered dangerous, the TDG Act must be consulted. If the goods are in fact dangerous, the TDG Act explains what is required. CAR 901.43 explains when an SFOC—RPAS is needed to transport payloads that are also considered dangerous. This includes explosive, corrosive, flammable, or biohazardous material, and weapons, ammunition, or other equipment designed for use in war. An effort was made to link the TDG Act with section 901.43, but this has not been finalized. In other words, there may be situations that require an SFOC—RPAS under CAR 903.01(g) but are outside of the TDG Act for some reason. There may be other situations that do not require an SFOC—RPAS under CAR 901.43 but do require operation under the TDG Act.

It is the responsibility of the RPA pilot to ensure compliance with all regulations before an RPAS operation.

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 f light 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, water 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) and are reserved for RPA pilots holding an advanced certificate.

RPA pilots shall always keep the RPA in VLOS, shall give way at all times to traditional aircraft, and shall not interfere with an aircraft operating in the established traffic pattern (CARs 901.11, 901.17, 901.18, and 901.47).

When operating an RPA at or in the vicinity of an aerodrome, water aerodrome, airport, or heliport, the RPA pilot should contact the aerodrome operator to inform them of the RPAS operation, regardless of whether the RPA is operated in controlled or uncontrolled airspace.

Although aerodrome operators can prohibit someone from using their premises, they cannot forbid the use of the airspace surrounding an aerodrome, airport, or heliport. Airspace access is regulated through the CARs, and any aircraft or pilot meeting the requirements therein could use the airspace.

Please note that aerodrome, water aerodrome, airport, and heliport operators don’t have access to NAV Drone RPA flight authorization information. If you choose to operate your RPA in one of these areas and see traditional aircraft operating, it is recommended to land the RPA and reassess the situation. If you notice regular aircraft activities at a location, it is recommended to contact the aerodrome operator to better understand the local traffic circuit procedures and to coordinate your RPA operations.

The RPA pilot should also maintain a listening watch of the applicable aerodrome traffic frequency found in the CFS or on VNCs. Any person operating a VHF radio must hold a Restricted Operator Certificate with Aeronautical Qualification (ROC-A). TC AIM COM 1.0, NAV CANADA’s VFR Phraseology Guide, and ISED’s study guide RIC-21 for the ROC-A provide additional information on radiotelephony procedures.

If an aerodrome, water aerodrome, airport, or heliport is located inside controlled airspace, the RPA pilot needs an advanced small RPA (VLOS) pilot certificate being in an advanced environment and shall receive an authorization from the appropriate ANSP. This is described in section 3.4.4 of this chapter and requires a manufacturer declaration that the RPAS meets the appropriate safety assurance profile for controlled airspace as described in section 3.4.3 of this chapter. See subsection 3.2.3.2 and section 3.4.4 for information about RPA operation in controlled airspace. See also section 3.4.5 of this chapter for information on how to conduct an RPAS operation in accordance with the established procedure when at or in the vicinity of an airport or heliport (as per CAR 901.73).

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 military aerodrome is in controlled airspace, the pilot needs an advanced small RPA (VLOS) 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—RPAS.

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:

• injuries to any person requiring medical attention;
• unintended contact between the aircraft and persons;
• unanticipated damage incurred to the airframe, control station, payload, or command and control links that adversely affects the performance or f light characteristics of the aircraft;
• any time the aircraft is not kept within horizontal boundaries or altitude limits;
• any collision with or risk of collision with another aircraft;
• any time the aircraft becomes uncontrollable, experiences a flyaway, or is missing; and
• 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:

• an RPA weighing more than 25 kg is involved in an accident, as defined by paragraph 2(1)(a) of the TSB Regulations; or
• 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
• 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.

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 Remotely Piloted Aircraft (RPA)

CAR 101.01(1) 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 an RPA 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 RPAs that are prevented from being navigated along a path pose a different set of hazards from RPAs that are free-flying. If the RPA is being manoeuvred or the navigation is controlled while the RPA is on the tether, it is navigable and it once again meets the definition of an RPA, and Part IX of the CARs will apply. Control-line flying models are not designed to be navigated and do not meet the definition of an RPA.

A tether can be used to extend the flight time of the RPA by supplying power from the ground. A tether can also be used as a means to mitigate the risk of the flyaway by physically restricting the RPA 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:

• An RPA 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.
• An RPA attached to a line while it is being maneuvered or navigated by a pilot does meet the definition of an RPA, and CARs Part IX provisions governing small RPAs
• 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 to an RPA is considered a modification to an RPAS. Therefore, if an RPAS safety assurance declaration has been made under CAR section 901.76 for advanced operations, the installation of a tether on the RPA will invalidate this RPAS safety assurance declaration unless:

• 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)); and
• the pilot installing the tether on the RPA 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 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.

3.4.4 Operations in Controlled Airspace

Operations in controlled airspace are advanced operations. Pilots must have an advanced RPA pilot certificate (CAR 901.64) and must use an RPAS that has been declared for the relevant operation (CAR 901.69). The declaration states that the RPA has the required positional accuracy of at least +/- 10 m laterally and +/- 16 m altitude. The required accuracy for operations within controlled airspace is identified for purposes of communication 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 is stipulated in 922.04.

This CAR Standard 922.04 eligibility is written on the RPA certificate of registration. RPAS operated outside of the manufacturer’s operational limitations (including but not limited to wind, temperature or other operational limits and minimums) are not considered to be within the declared capabilities of the RPAS and are not safe for flight (CAR 901.31).

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)).

3.4.5 Operations at or in the Vicinity of an Airport or Heliport—Established Procedure

This section is for advanced RPA pilots operating in advanced environments, when the RPA is within 3 NM from the centre of an airport or water airport and within 1 NM from the centre of a heliport, regardless of whether the RPA is in controlled or uncontrolled airspace. Advanced RPA pilots in this situation are required by CAR 901.73 to conduct their RPAS operations in accordance with the established procedure. Please refer to the NRC Drone Site Selection Tool, the NAV Drone Viewer, the CFS, the CWAS, or VNCs for more information and the location of an airport, heliport, or water airport at or in the vicinity of an RPAS operation. If a procedure is established for an airport, heliport, or water aerodrome, it is published in the PRO section of the current CFS for airports or heliports, or in the current CWAS for water airports. Procedures may also be provided in an ANSP RPA flight authorization notice for controlled airspace.

Below is the TC generic established procedure that should be followed if there is none published or provided and when the RPA pilot is operating in an advanced environment at or in the vicinity of an airport, heliport, or water airport.

• Always give way to traditional aircraft and keep the RPA within VLOS (CARs 11, 901.17, and 901.18). See

subsection 3.2.1.1 of this chapter for information about visual line-of-site (VLOS) and section 3.2.5 about right of way.

• Ensure that you have a pilot certificate—RPA (VLOS)— advanced operations.
• Adhere to the CARs and respect the limits of the privileges granted by the TC advanced RPA pilot certificate with regards to Part IX.
• Prior to an advanced RPAS operation and as part of the site survey required by CAR 27, consult the CFS, CWAS, VFR charts, Drone Site Selection Tool or NAV Drone Viewer to research the airport, heliport or water airport where operations are to be conducted so that you understand the relevant information.
• When operating an RPA at or in the vicinity of an aerodrome, water aerodrome, airport, or heliport, the RPA pilot should contact the aerodrome operator to inform them of the RPAS operation, regardless of whether the RPA is operated in controlled or uncontrolled airspace. Please note that aerodrome, water aerodrome, airport, and heliport operators don’t have access to NAV Drone RPA flight authorization
• The RPA pilot should maintain a listening watch of the applicable aerodrome traffic frequency found in the CFS or on Any person operating a VHF radio must hold an ROC-A. TC AIM COM 1.0, NAV CANADA’s VFR

Phraseology Guide, and ISED’s study guide RIC-21 for the ROC-A provide additional information on radiotelephony procedures.

Please note that aerodrome, water aerodrome, airport, and heliport operators don’t have access to NAV Drone RPA flight authorization information. If you choose to operate your RPA in one of these areas and see traditional aircraft operating, it is recommended to land the RPA and reassess the situation. If you notice regular aircraft activities at a location, it is recommended to contact the airport operator to better understand the local traffic circuit procedures and to coordinate your RPA operations.

Although aerodrome operators can prohibit someone from using their premises, they cannot forbid the use of the airspace surrounding an aerodrome, airport, or heliport. 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 another person, except for the crew or people involved in the RPAS operation. For these operations, the pilot must have an advanced RPA pilot certificate (CAR 901.64) and must use an RPAS that has been declared for the relevant operation (CAR 901.69).

This CAR Standard 922.05 eligibility is written on the RPA certificate of registration. RPAS operated outside of 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 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).

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

3.6.2 Application for a Special Flight Operations Certificate (SFOC)—Remotely Piloted Aircraft System (RPAS)

Guidance to complete the application form for the issuance of an SFOC—RPAS (Form 26-0835E) <https://wwwapps.tc.gc. ca/Corp-Serv-Gen/5/forms-formulaires/download/26-0835_ BO_PX> is available on TC’s drone safety Web site (<https:// tc.canada.ca/en/aviation/drone-safety>), as well as in

AC 903-002—Application Guidelines for a Special Flight Operations Certificate for a Remotely Piloted Aircraft System (SFOC—RPAS).

For reference:

(a) Legal name—For an individual: your full name. For a registered business, the business name or number;

(b) Trade name—What your business is known as. Enter your own name if you do not have a trade name;

(c) Address—Address of the individual or the headquarters of the registered business;

(d) Principal place of business—Province information only;

(e) Telephone—Phone number of the individual or the headquarters of the registered business;

(f) Is this the applicant’s first SFOC request under CAR Part IX?— If not, the previous SFOC—RPAS number will be a six-digit number starting with “9”;

(g) Purpose of the operation—Provide detailed descriptions of the operation in the supporting documentation: for example, the concept of operations (CONOPS) or site survey or the Specific Operational Risk Assessment (SORA). Where an RPAS will be used for multiple purposes, these purposes and the associated risk assessments (as applicable) must all be detailed in the SFOC—RPAS supporting documentation;

• Proposed period of operations—Start and end dates;
• Location of the proposed operations—For applications under CAR 903.01:
  • For CAR 01(c) foreign operators and (h) MND aerodrome, write in this field: the region(s) of operation(s).
  • For CAR 01(e) more than 5 RPAs at one time and

(f) special aviation/advertised events, the SFOC— RPAS will be site-specific: enter city address or latitude/longitude.

• For CAR 01(a) above 25 kg, (b) BVLOS, (d) above 400 ft, and (g) dangerous payload, enter either the city address or latitude/longitude, or the region(s) of operation(s).
• More complex SFOC—RPAS issued for a wider region are more complicated to process than site-specific ones, will have additional requirements and longer reviewing times, and are not generally supported for initial applications;

• Person responsible for the RPAS operation—Who is responsible? This may be a different person than the one who is applying or the company. Effective contact information is required for when the RPA is in operation.

NOTE:

The SFOC—RPAS application is signed by the individual applicant or a representative from the company. For a company, this may or may not be the responsible person. All simple SFOC— RPAS applicants will be required to complete a “simple” risk assessment.

For more complex SFOC—RPAS applications, including those under CAR 903.01(a) above 25 kg, (b) BVLOS, (d) above 400 ft,

(e) more than 5 RPAs at one time and (g) dangerous payload, applicants are to complete an RPAS Operational Risk Assessment (ORA) as specified in AC 903-001.

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.

AC 903-001 and AC 903-002 are available at <https://tc.canada. ca/en/aviation/reference-centre/advisory-circulars#900-series>.

Applicants shall submit the required information listed in CAR 903.02 along with a duly completed copy of Form 26-0835E at least 30 working days before the date of the proposed operation.

Processing times can be longer depending on the complexity of the RPAS operation and completeness of the application, like for operations under CAR 903.01(a), (b), (d), and (g). For any application under CAR 903.01(a) above 25 kg and (b) BLVOS, a manufacturer safety assurance declaration shall be submitted for all operations requiring an RPAS ORA which yielded a SAIL level of 3 or higher, or for any other application if required to address containment objectives. SFOC—RPAS applications for CAR 903.01(a) above 25 kg without a manufacturer safety assurance declaration, will not be accepted.

Additionally, BVLOS applications shall include an acceptable means to detect and avoid (DAA) other traditional aircrafts, based on performance objectives specified in AC 903-001—RPAS ORA. SFOC—RPAS applications for CAR 903.01(b) BVLOS without an acceptable means of DAA will not be accepted.

All the above-mentioned documents and requested information shall be provided at the time the application is submitted for review. The application will only be deemed accepted once all the information has been received by the TCCA RPAS Centre of Expertise (RCE) office. Once a complete SFOC—RPAS application is accepted, the applicant will be informed by a TCCA RCE office e-mail. SFOC—RPAS applications with an end date of less than 30 working days in the future will not be accepted.