• RPAS - A Primer on Remotely Piloting the Canadian Skies with a Drone

    What is an RPAS?

    RPAS is an acronym which stands for Remotely Piloted Aircraft System. It refers to an unmanned aircraft system where the flight is controlled remotely by a human operator rather than being onboard the aircraft.  RPAS can vary in size and complexity, ranging from small drones used for recreational purposes to large-scale systems used for military reconnaissance, surveillance, and commercial applications such as aerial photography, mapping, agriculture, and infrastructure inspection.  RPAS have gained significant attention in recent years due to advancements in technology and their increasing utilization across various industries.

    How about UAS?

    UAS stands for Uncrewed Aircraft System (the previous usage was Unmanned Aircraft System). It is a broader term that encompasses all types of unmanned aircraft, including remotely piloted aircraft (RPAs) or drones, along with their associated ground control stations, communication links, and other support equipment.  The term UAS is often used interchangeably with UAV (Unmanned Aerial Vehicle) or RPAS (Remotely Piloted Aircraft System).  UAS can be used for a wide range of applications, including military reconnaissance, surveillance, civilian aerial photography, mapping, agriculture, environmental monitoring, and more.  Some countries, including the U.S.A., use this terminology when referring to drones.

    Transport Canada

    Transport Canada is the federal department responsible for transportation policies and programs in Canada.  It oversees various modes of transportation, including air, marine, rail, and road. Its responsibilities include regulating and ensuring the safety and security of transportation systems, developing transportation policies and regulations, and promoting efficient and sustainable transportation practices.

    Within the realm of aviation, Transport Canada is responsible for regulating civil aviation activities, including aircraft operations, airworthiness standards, airport regulations, and licensing of pilots and air traffic controllers.  It also oversees the implementation of regulations related to remotely piloted aircraft systems (RPAS) or drones.

    Transport Canada plays a crucial role in facilitating safe and efficient transportation across Canada, contributing to the country's economic growth and connectivity.

    The Relationship Between Transport Canada and the Canadian Aviation Regulations

    Transport Canada is the government department responsible for developing and implementing policies, regulations, and programs related to transportation in Canada.  The Canadian Aviation Regulations (CARs) are a set of regulations administered by Transport Canada that govern civil aviation in Canada.

    The relationship between Transport Canada and the Canadian Aviation Regulations is one of regulatory authority and enforcement.  Transport Canada develops, updates, and maintains the Canadian Aviation Regulations to ensure the safety, security, and efficiency of aviation operations within Canada.  These regulations cover a wide range of topics, including aircraft certification, flight operations, airworthiness standards, pilot licensing, air traffic control, and airport operations.

    Transport Canada is responsible for enforcing compliance with the Canadian Aviation Regulations through various means, including inspections, audits, and investigations.  It works closely with industry stakeholders, such as airlines, aircraft operators, pilots, and maintenance organizations, to ensure compliance with the regulations and promote a culture of safety within the aviation community.

    Overall, Transport Canada's relationship with the Canadian Aviation Regulations is one of oversight, regulation, and enforcement to ensure the safe and efficient operation of civil aviation in Canada.

    Classes of RPAS

    Transport Canada categorizes Remotely Piloted Aircraft Systems (RPAS) into different classes based on their characteristics and intended use.  These classes include:

    Very Small RPAS (VS-RPAS):

    These drones are also known as micro drones or sub-250 drones.  This class typically includes drones weighing less than 250 grams.

    VS-RPAS are often used for recreational or hobby purposes, as well as for some commercial applications such as aerial photography and videography.  A typical example is the DJI Mavic Mini, which weighs 249 g in its barest form.  One point worth noting is that, once it is equipped with any equipment or accessories, the DJI Mavic Mini exceeds 250 g, which then qualifies it for the heavier small RPAS type.

    Small RPAS (S-RPAS):

    S-RPAS typically weigh between 250 grams and 25 kilograms.

    These drones are commonly used for a wide range of applications, including aerial photography, videography, surveying, mapping, inspection, and agriculture.  Typical drones in this weight class include DJI models as the Phantom, Mavic, Inspire, and Matrice series of drones.

    Large RPAS (L-RPAS):

    L-RPAS generally weigh over 25 kilograms.

    These drones are capable of carrying heavier payloads and are often used for more specialized and industrial applications, such as heavy lifting, long-endurance missions, and specialized aerial surveying or monitoring tasks.  Drone aircraft such as the DJI Agras series of agricultural drones and the new DJI FlyCart 30 aerial delivery/transport drone fall under this category.

    It's important to note that these classifications are based primarily on weight and intended use, and regulatory requirements may vary depending on the class of RPAS. Additionally, Transport Canada has specific regulations and guidelines for each class of RPAS regarding pilot qualifications, operational limitations, and airspace restrictions.

    Regulations Governing RPAS – Part IX of the Canadian Aviation Regulations

    The rules governing Remotely Piloted Aircraft Systems (RPAS) in Canada are outlined in Part IX of the Canadian Aviation Regulations (CARs), specifically Subpart 9 of Part IX.  These regulations are designed to ensure the safe and responsible operation of drones in Canadian airspace.  Some key aspects of the RPAS rules in the Canadian Aviation Regulations:

    1. Registration:  All drones weighing between 250 grams and 25 kilograms must be registered with Transport Canada. This registration process helps authorities identify the owner of the drone in case of incidents or violations.
    2. Pilot Certification:  Pilots operating small RPAS must obtain a Pilot Certificate - Remotely Piloted Aircraft Systems (PC-RPAS), regardless of the intended use of the drone. To obtain this certificate, pilots must pass a written exam administered by Transport Canada as well as possibly an in-person flight review.
    3. Visual-Line-of-Sight (VLOS) Operations:  Unless granted specific exemptions, drone operators must maintain visual contact with their aircraft at all times during flight. This means the drone must be operated within the pilot's line of sight without the use of visual aids such as binoculars or first-person view (FPV) goggles.
    4. Flight Restrictions:  There are several restrictions on where drones can be flown, including airspace restrictions around airports, heliports, and other sensitive locations. Drones are also prohibited from flying over crowds, in controlled airspace without authorization, and at night unless they have appropriate equipment and permission.
    5. Safety and Privacy:  Drone operators must adhere to safety guidelines and respect the privacy of individuals when operating their aircraft. This includes avoiding flying over people, private property, and sensitive areas without permission.
    6. Airworthiness Requirements:  Drones must be in a safe and airworthy condition before flight. Operators are responsible for ensuring their aircraft are properly maintained and inspected according to manufacturer recommendations.
    7. Emergency Procedures:  Operators must have procedures in place to deal with emergencies or malfunctions during flight, including loss of control, battery failure, or GPS signal loss.

    Key Takeaways Regarding the RPAS Regulations:

    1. Very small RPAS (the so-called micro drones) are largely exempt from the registration, pilot licensing, and operational requirements/constraints of the small RPAS class.  However, subsection 900.06 of the CARs, which deals with Reckless or Negligent RPAS Operation, still applies to the operation of Very Small RPAS: “no person shall operate a remotely piloted aircraft system in such a reckless or negligent manner as to endanger or be likely to endanger aviation safety or the safety of any person”.
    2. Small RPAS are restricted to Visual-Line-of-Sight (VLOS) flight operations.
    3. The RPAS regulations prescribe the general operational requirements and limitations of small RPAS drone flights.  In order to conduct drone flights outside of the scope of the Part IX RPAS regulations, drone operators are required to obtain a Special Flight Operations Certificate (SFOC-RPAS) which is issued by Transport Canada.

    What is a Transport Canada Special Flight Operations Certificate (SFOC-RPAS)?

    A Transport Canada Special Flight Operations Certificate (SFOC) for Remotely Piloted Aircraft Systems (RPAS), often referred to as an SFOC-RPAS, is a document issued by Transport Canada that grants permission to operate drones for commercial or work purposes in Canadian airspace.

    Before conducting commercial or work-related drone operations in Canada, operators must obtain an SFOC-RPAS unless they qualify for certain exemptions under the regulations. The SFOC outlines the conditions and restrictions under which the drone operations are permitted, ensuring compliance with safety and regulatory requirements.

    To obtain an SFOC-RPAS, operators must submit an application to Transport Canada that includes details about the proposed drone operations, such as the type of aircraft, intended flight area, safety procedures, and risk mitigation measures. Transport Canada evaluates the application to ensure that the proposed operations meet safety standards and regulatory requirements.

    Once approved, the SFOC-RPAS specifies the terms and conditions under which the drone operations are permitted, including any airspace restrictions, operational limitations, and safety precautions. Operators must adhere to these conditions while conducting their drone operations.

    The SFOC-RPAS is an essential document for commercial drone operators in Canada, as it demonstrates compliance with regulatory requirements and ensures safe and responsible drone operations in Canadian airspace.  The Transport Canada SFOC is analogous to the US FAA Part 107 waiver process.

    Under Part IX of the Canadian Aviation Regulations (SOR/96-433), a SFOC-RPAS is required if:

    • you are a foreign operator (that is, not a Canadian citizen, permanent resident of Canada or a corporation incorporated by or under the laws of Canada or a province);
    • you want to fly at a special aviation event or an advertised event;
    • you want to fly closer to a military airport;
    • you want to fly your drone beyond visual line-of-sight. Drone equipment such as the DJI Dock falls under this category.
    • your drone weighs over 25 kilograms (kg). Drone aircraft such as the DJI Agras series of agricultural drones and the new DJI FlyCart 30 aerial delivery/transport drone fall under this category. 
    • you want to fly your drone at higher altitudes;
    • you want to fly your drone carrying dangerous or hazardous payloads (e.g., chemicals).  Drone aircraft such as the DJI Agras series of agricultural drones can fall under this category.  
    •  you want to fly more than five drones at the same time.

    Complex drone operations may require multiple SFOCs in order to be compliant with Transport Canada RPAS requirements.  In general, SFOCs are issued on a time-limited basis and are site-specific.

    How We Can Help – The DCS Difference

     As the fourth sRPAS operator in Canada and the first in Ontario to be rated for BVLOS flight by Transport Canada, which is the most stringent and arduous drone flight operation allowed by Transport Canada, DCS has the expertise to assist clients in establishing flight operations and CONOPS (Concept of Operations) which meet complex Transport Canada regulations and requirements.



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