Canadian Drone Rules: Time to Fix Them!! Recommendations to improve the current regulations
People have to obey the laws. So when i criticize the drone regulations in this video or say some of the current rules are dumb, that doesnt mean you should stop obeying them. If you do youre breaking the law, instead follow the rules to the best of your ability and work to change and improve them. Hi, im dawn from dawn drones on yeah its been two years since the current canadian drone regulations were introduced so theyre due for an overhaul, lets roll up our sleeves and assess their effectiveness on a scale of good to dumb, and i have some very strong recommendations Towards the end of this video, the regulations introduced in 2019 break down into five main areas and a total of 81 individual rules. The first four areas are are mainly administrative in nature, drone, registration, basic and advanced pilot certification, flight reviewer, certification, stuff for drone manufacturers and the operations that require an sfoc ill spin through this stuff, first and fairly quickly. So we can spend more time on the operating and flight rules, of which there are 46 individual regulations, ive grouped these ones into five sub areas. I call basic safety, pre flight checks, procedures where you can fly and special cases, these arent official groupings, but they work to bring rules together in logical bunches and by the way, criticism number one way too many rules anyways in evaluating these rules, ive used a similar Scale to what i used for the exam knowledge area, evaluation dawns magic scale of sanity.
Good means the rule, makes sense and focuses on the right stuff. Okay means its all right, but has some room for improvement and ill spell? Those improvement areas out no need means. The rule should be eliminated either because its covered adequately by other rules or is overly prescriptive. By overly prescriptive, i mean it dives too deeply into exactly how we need to do something. A lot of these rules could simply be guidelines and, finally, dumb these rules are absolute nonsense. Now there are only a few of these, but they really should be eliminated, so i didnt just arbitrarily cast judgment on the rules one by one. Instead, i came up with some principles. First of what the regulations should focus on. I feel that drone registration and pilot certification are good things to have, but the operating rules should focus only on safety and where you can fly and cannot fly and the regulations should not be attempting to equate drones with manned aircraft and their regulations and drone. Pilots should not be required to operate like manned aircraft, pilots, and i see this in far too many of the rules. Finally, we should not have best practices and guidelines built into the regulations, just because using a checklist is a really good idea does not mean that someone should be considered to be breaking the law if they dont use one okay, with these principles in mind and my Magic scale of sanity at the ready lets dive into this drone registration is easy im all for it and gave the whole section an okay rating, but only okay, because it should be possible and fairly easy for foreign drone owners to register their drones in canada.
Next pilot and flight reviewer certification, there are 20 rules covering these areas im not going to dive into each one. You already know what i think about the exams so lets just put that aside for for now, for these areas, the certifications i give them all again, an okay rating with two areas for improvement. First again, it should be possible for foreign pilots to certify at least for the basic, without going through the sfoc process, thats ridiculous and, secondly, the advanced level certification should require, in addition to an exam and a flight review, a certain number of flight hours. Now, given that advanced pilots are permitted to fly and control the airspace, i think actual stick time is important before getting anywhere near aircraft or close to people for that matter. How much flight time well im not sure id like to hear your input on that. The next area is the manufacturers requirements for declaring drone models fit for advanced operations to me. Well, these seemed pretty good, so i simply declared good on my magic scale. There are three rules dedicated to special flight operations, certificates or sfocs in general. I think these are okay, but as weve discussed in yet another video transport, canada is proposing changes in this area, including charging fees for processing. Sfocs. Two improvement areas simply reduce or eliminate cases where an sfoc is currently required, like flying in controlled airspace around dnd airports. Come on nav canada should be able to front this kind of request like like any other controlled airspace, coordinating with dnd themselves.
Also, these proposed sfoc fees need serious reconsideration and adjustment check out my video on that for details, okay onwards and upwards, as we droners like to say, and into the general operating and flight rules, sections one sub area at a time, but heres a sneak preview of How ive scored them and you can see theres a lot of red now? Fortunately, the first sub area, which is basic safety, looks pretty green lets. Look at the exceptions, 901.19 talks about the fitness of crew members and, in my mind, is totally dumb. This is a classic case of copy and pasting from manned aircraft rules. No alcohol consumption within 12 hours of flying and no cannabis use within 28 days now, dont get me wrong: im, not encouraging, drunk or stoned flying, but making a drone rule. That is so much more strict than driving a car makes absolutely no sense and just leads people to well throw out all the rules just because of this one. So just a line with sensible and realistic automotive based restrictions, and i dont think well see any complaints. I want to focus on two of the rules i declared merely. Okay. 901.11 is the visual line of sight to your drone rule? In my opinion, this should be replaced with a visual line of sight to the area of operation. Only you should should not need to see your actual drone just the piece of sky its flying in this is more practical, and what many of us already do and do safely.
This should apply to both basic and advanced pilots and will fit in nicely with a recommendation. Ill share with you. A little later on, the other one to discuss is 901.32 called control of our pass, saying you must be able to take immediate control of your drone at all times. This basically renders many autonomous flight modes like even like selfies and follow me. Certainly, that kind of stuff is absolutely illegal, regardless of the environment. Youre. Using them in this should be changed to allow these functions to be applied when theyre used safely, dont use them in controlled airspace or near crowds of people, for example, but in an open field. Fill your boots lets move on to the next sub area. Pre flight checks. These seven rules cover a myriad of sensible ideas, unfortunately cast as legal obligations doing site survey checks. Hey did i just hear somebody mutter the air ground weather people song well good for you. This is the kind of simple mental check that covers most of these rules. I think the rules themselves are far too prescriptive and would be better positioned as guidelines and recommendations rather than regulations. Do we really need a rule, a legal statement that says we should check our battery level before flying or only fly within the manufacturers recommended temperature range come on were expected to drive a car at a speed suitable for the weather conditions, shouldnt the same kind of Principle apply to drone rules and were in canada every once in a while, its actually above zero, the rest of the time.
We need to adjust our flight times downwards and keep a close eye on the battery levels. Cant we, as responsible drone pilots, be permitted to make sensible judgment, calls on issues like this anyways. You will see later on that i propose a new rule called situational awareness that simplifies a lot of this stuff down to ensure your drone is in good condition, and your flight area is safe and legal. Next sub area procedures. These rules require us to have procedures and checklists for normal and emergency situations. We have to carry our instruction manual around with us, keep flight logs and maintenance records. It was all this nonsense that inspired me to create drone pilot canada. To begin with, there was no way i was going to lug around a binder with all this crap, and i hope you didnt think you would be too to me. This is just a ridiculous attempt to make drone pilots follow manned aircraft rules now theres. No doubt these are best practices and terrific recommendations, but absolutely dumb as legal requirements lets move on to the where you can fly sub area and lets start with the dumb one advertised events. This rule requires drone pilots to secure an sfoc to fly within 30 meters of any publicly advertised event, such as a concert or sporting event. This seems like overkill, particularly since were already restricted in terms of proximity to people 30 meters for basic operations and 5 meters.
If you have your advanced arent these sufficient and if an event, organizer really wants to restrict the airspace for whatever reason, even if its for copyright protection. In the case of some outdoor sporting events, they should be allowed to request a no tam based flight restriction for the duration of the event. Of course, that would require nav canada as keeper of the no tams to actually make it straightforward to raise such a restriction. Yeah that might be asking too much speaking of proximity to people. I think the current limitation of 30 meters for basic pilots is needlessly restrictive. I think 15 meters is a more reasonable, keep back distance from bystanders theres, no particular science. Here, just my opinion. What do you think, then? There are the various rules around operating in the vicinity of aerodromes, airports and heliports. I dont really mind these rules, which is why i rated them. Okay, but surely this stuff can be simplified after all, all aerodrums in that are inside controlled airspace are already covered by the controlled airspace rules and and procedures and aerodromes that are outside of controlled airspace are the smaller airports airfields and heliports if theres a plane in The air the risk is the same regardless of the class of the airport certified or registered, so why this extra complication? This can be simplified and by the way, if nav canada stopped hoarding their airport data and made it public, then the dji fly safe geo zones.
Could be properly aligned? Everyone would be happier with that and a lot safer. Oh and one last comment: 901.25, the maximum altitude rule. For some reason i labeled it as good which it is, but can someone please reword this, so it is actually comprehensible. The inside out logic of the regulations wording its actually shocking and certainly baffling to newbie drone pilots lets talk about special cases. Now this is a mixed bag of weird rules, some good, some not, and there are five rules i flagged as no need carrying living creatures. Formation flight handover restrictions, flight termination systems and the weirdest trans, the the transponder rule, these just seem like extra baggage covered by other rules, regulations, procedures or or basic laws like like cruelty to animals, lets clean house and get rid of these its just clutter, then theres. The famous fpv rule 901.38, this rule states that you must have a visual observer if you are flying a drone and wearing fbv goggles. Now this same rule is present in virtually every country in the world, and i get the reason if youre wearing goggles, you cant see whats going on around you and especially you cant see a manned aircraft that might be approaching outside of your cameras line of sight. The problem is that it doesnt reflect the reality that most fpv flyers fly at low altitudes, around trees and buildings and in racing environments. You should not need a visual observer in situations like that, and yet there are no provisions or exceptions.
Thats, dumb, all right im not going to go into detail for every rule, i think, is lousy or could be improved or wed be here into next week. So feel free to go back and review the other comments that ive made on these slides before. I finish, though, lets have a look at the numbers and my key recommendations. Out of all of this analysis from my review of the rules, 64 of them are pretty good with minor improvements possible. The remaining 36 percent need some serious revision in order to have a solid set of drone regulations that most people could actually buy into. I recommend first that they eliminate regulations that should be exclusively for manned aircraft. The alcohol and cannabis timelines are the best example just align these with driving regulations. Second eliminate regulations that can be downgraded to simply useful guidelines. Things like the use of checklists and procedures. These are good things like ive said, but should not be laws again. Is there a legal requirement for running through checklists before driving your car or truck no three eliminate the advertised event rule. This would be better served by no tam based temporary flight restrictions. Finally, introduce a situational awareness rule to replace a myriad of overly restrictive rules like those related to fpv devices, visual line of sight, site surveys, weather conditions all that stuff. So lets look at how such a rule could be formulated. The pilot must have full situational awareness by taking appropriate measures to both prepare for and execute a safe flight.
The pilot must first have sufficient knowledge of the airspace and physical environment for a safe flight. He or she doesnt need to read. Vfr charts just understand the airspace, any restrictions and obstacles or bystanders to avoid. Second, the pilot must take into account weather conditions in the area if its really cold take appropriate precautions and wear a hat third ensure the drone is in safe operating condition. Simple: four maintain a clear line of sight to the area of operation. Again, this means being able to clearly see where the drone is operating and not necessarily being required to see the drone itself. Seeing the area of operation is sufficient to enable the pilot to take the correct action if a manned aircraft approaches. And finally, the pilot must be prepared for abnormal and emergency situations. I think this combination of simple rules does a much better job at driving home safety than dozens of overly strict regulations that are largely based on manned aircraft operations. Well, there you have it my assessment of the canadian rpas regulations, as defined in 2019 and specific recommendations that, in my opinion, would greatly improve them. Id love to hear your feedback on this stuff. But, more importantly, if you wish to provide transport canada with your opinion, ive put the email address of the head of the rpas task force in the description below the video. These guys are looking for feedback and may appreciate your perspective.