|03-09-2008, 12:19 PM||#11|
RCC Senior Contributor
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Not to discorige you but but if you have question you should ask it some of us will give you our oppinion. Now right or wrong but never the less you will get an aswer.
Lawyer are for peaple how have commited crimes or for those who choose to challange current law. Any case it will cost you ton of money. I find some time it is just easer to comply with the minimum standard that is not to say that you have to stop there. If I chose to hire a company to fly small RC heli toting camera above my property I would feel safe if the had to meet some standard and insurance.
To reply to satement"Seems that merely toting a camera aloft and getting a few bucks for the pics after the fact does not fit that description."
read below :definition use of UAV also down furture Confusion may exist.
I have not hired any expensive lawyer just read the document CAR's. I hope you enjoy the light reading that I have complied. All you need to know about UAV in CANADA.
Model Aircraft, Kites and Model Rockets
602.45 No person shall fly a model aircraft or a kite or launch a model rocket or a rocket of a type used in a fireworks display into cloud or in a manner that is or is likely to be hazardous to aviation safety.
Unmanned Air Vehicles
(amended 2003/12/01; previous version)
602.41 No person shall operate an unmanned air vehicle in flight except in accordance with a special flight operations certificate or an air operator certificate.
(amended 2003/12/01; previous version)
623.65(d) Unmanned Air Vehicle
(amended 2003/12/01; previous version)
(1) The following standards apply to the application for and the operation of an unmanned aeroplane, rotorcraft or airship pursuant to CAR 602.41.
(2) An application for a Special Flight Operations Certificate for the purpose of conducting the flight of an unmanned aircraft other than an unmanned free balloon or a model aircraft shall be received by the appropriate Regional Transport Canada General Aviation Office, at least 20 working days prior to the date of the proposed operation or by a date mutually agreed upon between the applicant and Transport Canada.
(3) The following constitutes an application for a Special Flight Operations Certificate for the purpose of operations in paragraph (1) above:
(a) the name, address, and where applicable, the telephone number and facsimile number of the applicant;
(b) the name, address, and where applicable the telephone number and facsimile number of the person designated by the applicant to have operational control over the operation (Operation Manager);
(c) method by which the Operation Manager may be contacted directly during operation;
(d) the type and purpose of the operation;
(e) the dates, alternate dates and times of the proposed operation;
(f) a complete description, including all pertinent flight data on the aircraft to be flown;
(g) the security plan for the area(s) of operation and security plan for the area(s) to be overflown to ensure no hazard is created to persons or property on the surface;
(h) the emergency contingency plan to deal with any disaster resulting from the operation;
(i) the name, address, telephone and facsimile numbers of the person designated to be responsible for supervision of the operation area (Ground Supervisor), if different from the Operation Manager during the operation;
(j) a detailed plan describing how the operation shall be carried out. The plan shall include a clear, legible presentation of the area to be used during the operation. The presentation may be in the form of a scale diagram, aerial photograph or large scale topographical chart and must include at least the following information:
(i) the altitudes and routes to be used on the approach and departure to and from the area where the operation will be carried out;
(ii) the location and height above ground of all obstacles in the approach and departure path to the areas where the operation will be carried out;
(iii) the exact boundaries of the area where the actual operation will be carried out;
(iv) the altitudes and routes to be used while carrying out the operation;
(k) any other information pertinent to the safe conduct of the operation requested by the Minister.
Definition of Unmanned Air Vehicle (UAV)
Section 101.01 of the Canadian Aviation Regulations (CARs) states, "Unmanned Air Vehicle" means a power driven aircraft, other than a model aircraft, that is operated without a flight crew member on board.
Unmanned air vehicles have been given many names, but are most commonly referred to as unmanned aerial vehicles (UAV), unmanned air vehicles, remotely operated aircraft or remotely piloted vehicles. Unmanned air vehicles may take the form of airships, aeroplanes or rotorcraft. Basically, they could be considered to be any unmanned aircraft that performs a useful mission and can be remotely controlled or has autonomous flight capability.
How unmanned air vehicles are different from model aircraft
"Model aircraft" means an aircraft, the total weight of which does not exceed 35 kg (77.2 pounds), that is mechanically driven or launched into flight for recreational purposes and that is not designed to carry persons or other living creatures. Although some micro unmanned air vehicles may weigh less than 35 kg, they are operated by research institutions and other organizations for non-recreational purposes.
Uses for unmanned air vehicles
Unmanned air vehicles operate in diverse environments, in high risk roles, including but not limited to: atmospheric research (including weather and atmospheric gas sampling), scientific research, oceanographic research, geophysical research, mineral exploration, imaging spectrometry, telecommunications relay platforms, police surveillance, border patrol and reconnaissance, survey and inspection of remote power lines and pipelines, traffic and accident surveillance, emergency and disaster monitoring, cartography and mapping, search and rescue, agricultural spraying, aerial photography, promotion and advertising, weather reconnaissance, flight research, and fire fighting monitoring and management.
Advantages of unmanned air vehicles
Unmanned air vehicles are not constrained by human limitations and requirements. They make it possible to gather information in dangerous environments without risk to flight crews. They can be much more cost effective than manned aircraft operations, although recurring costs to repair or replace those damaged during flight can be very high.
Subsection 101.01(1) of the CARs defines unmanned air vehicle.
"unmanned air vehicle" means a power-driven aircraft, other than a model aircraft, that is designed to fly without a human operator on board”.
Section 602.41 states that no person shall operate an unmanned air vehicle in flight except in accordance with the provisions of a special flight operations certificate or an air operator certificate.
Section 623.65(d) specifies the standards that apply to the application for, and the operation of, an unmanned aeroplane, rotorcraft or airship. The following definitions from the CARs apply:
“aeroplane" - means a power-driven heavier-than-air aircraft that derives its lift in flight from aerodynamic reactions on surfaces that remain fixed during flight.
“rotorcraft” - means a gyroplane or a helicopter.
"airship" - means a power-driven, lighter-than-air aircraft.
Section 603.66 of the CARs prohibits the flight operation of an unmanned air vehicle unless the provisions of a special flight operations certificate are complied with.
Section 603.67 states the requirement for an application to be submitted in the form and manner required by the Special Flight Operations Standards. It also states that once the application is received and the applicant demonstrates the ability to conduct the flight operation in accordance with the Special Flight Operations Standards, the Minister shall issue the special flight operations certificate.
Article 8 of the Chicago Convention states that no aircraft capable of being flown without a pilot shall be flown without a pilot over the territory of a Contracting State without special authorization by that State. As a member state of ICAO, Canada undertakes to comply with the provisions of the Convention.
Transport Canada is responsible for the conduct of civil UAVs. As stated in section 102.01 of the CARs, these regulations do not apply in respect of (a) “military aircraft of Her Majesty in right of Canada when they are being manoeuvred under the authority of the Minister of National Defence” or (b) “military aircraft of a country other than Canada, to the extent that the Minister of National Defence has exempted them from the application of these Regulations pursuant to subsection 5.9(2) of the Act” (i.e. foreign military UAVs). In these cases, the operation of UAVs are not subject to the Canadian Aviation Regulations, but are subject to Military Flying Orders. Military operations being conducted in civil airspace will require coordination with Nav Canada, and may require assistance from Transport Canada regarding airspace issues. Where a UAV operator is a civil agency or person, and the operation is being conducted in restricted military airspace, the operation will require a Special Flight Operations Certificate issued by Transport Canada, in cooperation with the Department of National Defence in the administration of that airspace.
The Radiocommunication Act regulates the use of radio frequency spectrum in Canada and requires that all radiocommunication equipment or systems be licensed. Industry Canada is the lead department responsible for radio frequencies, spectrum and telecommunications issues. The Inspector may want to remind the Certificate applicant of the requirement to contact Industry Canada regarding the assignment of radio frequencies, where they are required i.e. for the telecommand and control of the UAV, if the frequencies that are being used are not licence exempt, such as 900 MHz. Certificate holders should also be reminded of the requirement under the Radio Act to hold a Radiotelephone Operations Restricted Certificate, and that it may take up to 30 days to obtain radio frequency clearances, and/or radio licences. Radio communication regulations may be found on the internet at: http://laws.justice.gc.ca/en/R-2/SOR-96-484/index.html
The staff instructions contained in this document applies to all applications to conduct unmanned air vehicle flight operations as required by the definition of "unmanned air vehicle” as contained in section 101.01(1) - Interpretation of the Canadian Aviation Regulations. In cross border operations, where the UAV pilot is in another state (i.e. ground control station is in the United States), the Certificate holder is still responsible for compliance with the regulations of the state in which the UAV is operating (i.e. Canada).
UAVs can be used for experimental, demonstration, developmental or commercial purposes, including aerial surveying, agricultural and fisheries observation, communications relay, railway, pipeline and power line monitoring, minerals and oil surveying, mapping; government roles such as law enforcement, border patrol, fire fighting, disaster relief, traffic and crowd control; weather tracking and atmospheric observation; monitoring of dangerous substances including nuclear, biological and chemical emissions and scientific research (climate, ocean, environment and the earth) ... just to name a few. UAVs are unmanned aircraft that perform a useful mission and can be remotely controlled or has autonomous flight capability. UAVs are systems, and the airframe is only a small part of the whole system. The broader system of UAVs consists of the airframe and payloads, communications architecture, and the command and control system (ground station). Ground stations take the place of flight decks and can be considered to replace the term “on board”. When considering a request for operating approval, the system as a whole will be assessed including an assessment of the operating personnel.
It is important to note that what is often considered a “model aircraft” by an operator is in fact an “unmanned air vehicle” by definition. Section 101.01 defines model aircraft as:
"model aircraft" - means an aircraft, the total weight of which does not exceed 35 kg (77.2 pounds), that is mechanically driven or launched into flight for recreational purposes and that is not designed to carry persons or other living creatures.
Confusion may exist because the unmanned air vehicle weighs less than 35 kg., however, this does not make it a “model aircraft”. To be considered a “model aircraft”, three conditions must be met. Every condition is necessary but none is sufficient. Model aircraft weigh 35 kg. (77.2 lbs) or less, are mechanically driven or launched into flight for recreational purposes, and are not designed to carry persons or other living creatures. While the CARs do not define “recreational purposes” a dictionary definition of recreation is “not for work - done for pleasure or relaxation”. Model aircraft enthusiasts fly their aircraft as a pastime, an unpaid diversion, as an activity that “diverts, amuses, or stimulates”. CAR 602.45 was put in place to allow sporting enthusiasts to operate small radio controlled or static line controlled models (aeromodelling), which are small-scale models of “full-size" aircraft types.
In the case where a UAV Operator is in the business of using an "off the shelf" hobbyist model aircraft as a test bed aircraft for the purpose of research or education to compare technology, designs, operating systems or procedures to be used in future UAV applications, the operation of that aircraft cannot be considered recreational and is subject to UAV regulations.
Also available on the market are small-scale models of full size UAVs. The aircraft are advertised as aerial platforms to be used for aerial surveillance by adding a wireless video system or digital still camera. Equipping the model aircraft with this payload does not, in itself, make the model a UAV, however, once the model aircraft is launched as part of one’s employment or for monetary gain or other form of hire and reward, it is considered an unmanned air vehicle and is subject to UAV regulations.For the purpose of this Staff Instruction, the following definitions apply:
The ability of the UAV to be launched without a single command, once planning and pre-flight checks have been conducted and permission to launch has been granted.
A programmable automated flight profile that does not require UAV system crew intervention for normal operation i.e. flight independent of real time UAV-pilot control input.
Command, control and information links generated within or received by any element of the UAV system. They are the means of connecting one location to another for the purpose of transmitting or receiving data. UAV system communication links cover all communication, both within the system that may comprise of the control station, UAV, remote antenna(e), launcher(s), landing/recovery equipment and operational personnel and communication, to/from equipment and agencies external to the UAV system that require access to data, or control of, the UAV system and/or its associated sub-systems and payload(s). Communication links can be made by one or more of a variety of means such as, but not limited to: audio, visual, video, radio frequency (RF), infra red (IR), ultra-violet (UV), microwave and fibre optic.
A flight deck on the ground used for control of the UAV. Part(s) of the UAV system that includes all equipment that exercise control over the UAV, its payload and associated elements, in all phases of operation, including the monitoring of the UAV during operations outside line-of-sight. The control station includes all elements, from launch preparation to retrieval, that require system intervention and/or acknowledgement of system readiness.
Control stations are also referred to as Ground Control Stations (GCS) or Vehicle Control Stations (VCS). CDL Systems Inc., a Canadian company, is a leader in VCS software development for use in the control of unmanned vehicles. Their VCS has multi-vehicle and multi-operator capability. A single VCS and operator can control multiple vehicles. Alternately, several stations can be networked to shared vehicle and payload information and control. Operators at different workstations can split payload and vehicle control requirements, allowing one operator to interpret sensor information and mark targets, while another monitors vehicle functions and handles communications. You may see an SFOC application that utilizes CDL Systems VCS. Additionally, CDL Systems employees have been members of a Specialist NATO team that has now completed the work of developing a NATO Standardization Agreement (STANAG 4586) that addresses the interoperability of UAVs through the ground control station. The objective was to create a STANAG that would allow countries to use national core software for a UAV GCS that would provide standardization on three important interfaces. To date, SFOCs have been issued to a company that has used an unmanned air vehicle with a STANAG 4586 version of the GCS (CDL Systems VCS 4586 ground station) and it is likely that more UAV companies may utilize these products in the future.
Wireless ground-to-air communications system, which transmits information via digital coded pulses between the UAV and its control station. It may be used to exchange any mix of command and control or payload data. A channel may be single or bi-directional, and more than one may exist at a time between a particular control station and air vehicle pair.
The process by which a prepared air vehicle leaves the ground, with or without assistance, and attains controlled flight.
Visual line-of-sight, not to be confused with data-link line-of-sight.
The device or equipment carried by the UAV, which performs the mission assigned. The payload comprises all elements of the air vehicle that are not necessary for flight but are carried for the purpose of fulfilling specific mission objectives. This may include such sub-systems as intelligence and surveillance assets, communication relay equipment, sensors, and cameras.
A process or activity occurs in real-time if it responds within a short, tightly specified time variant from an external source, typically a small fraction of a second.
The phase of a UAV system that involves the return of an air vehicle to the ground or to base and includes the approach to the landing surface and landing.
The provision of duplicate or additional facilities to increase availability at given levels of reliability and logistic delay.
UAV Payload Operator
The individual trained to operate the sensor payload system and, in some cases, manage the flight profile.
A person who is actively exercising remote control of the UAV during non-autonomous flight segments and/or monitoring the state and progress of the UAV in an autonomous or programmed flight mode from the ground station. The UAV pilot is the person responsible for command and control of a UAV in flight. The UAV pilot may or may not be the UAV Payload Operator and may or may not be the Certificate holder.
To date, there is no “global” agreement on a term to describe the person responsible for the direct input of flight commands to the air vehicle. This person is described in various documents as a UAV Pilot, UAV Commander, UAV Controller, Flight Controller, UAV Operator or Crewmember. The intent is to distinguish between: the person who is actively exercising control of the UAV while in flight; the person who is in overall charge of, and responsible for, a particular UAV flight; the person or organization which operates the UAV and the person who operates the sensor payload system and in some cases, manages the flight profile.
For the purposes of the SFOC conditions, the use of the term UAV operator may be used to capture both the UAV Pilot and the UAV Payload Operator if they are the same person, or if it is appropriate for both individuals to be subject to the same conditions. Conversely, there may be a need to distinguish one from the other, in which case the terms UAV Pilot and UAV Payload Operator may be used. The payload operator may be the same person as the UAV pilot, a different person with the same training and qualifications or a different person with different training etc.
The Standards outline the information that must be submitted to Transport Canada for the conduct of unmanned air vehicle flight operations in Canada. This includes all pertinent flight data on the UAV, a security plan for the area of operation, an emergency contingency plan, etc. Since all of the information required for the application may not be sufficient for Transport Canada to determine whether the operator can conduct a safe operation, the Minister may also ask for any other information pertinent to the safe conduct of the operation, as referenced in 623.65(d)(3)(k).
The requirement for 20 working days advance notice is intended to provide Transport Canada Inspectors with adequate time to review, in sufficient detail, an application and supporting documentation and to carry out any required co-ordination. However, should an application arrive at a Regional office less than 20 days before the intended operation, if it can be processed accurately and completely without straining existing resources and work schedules the service should be provided, with a reminder to the client that 20 working days notice will be required in future.
Using the Canadian Aviation Regulations - Part VI, Subpart 3, Division IV - Miscellaneous Special Flight Operations and the standards found under 623.65(d) and this staff instruction as reference, an Inspector must review an operator's application as outlined below. Initially, a Certificate should be issued for each specific mission. Once a Certificate holder has demonstrated the ability to operate a specific mission safely, Inspectors may consider issuing a Certificate for an extended period of time, providing the operating environment and mission requirements have not changed. If the operating environment and the mission requirements change, the set of safety requirements that the Minister will impose are also likely to change.
Application and Supporting Documentation
Confirm the information contained in the application submission is complete. All the information required by Subsection 623.65(d) (3) of the Standards must be evident.
The name, address, and where applicable, the telephone number and facsimile number of the applicant.
It is vital to establish who has legal custody and control of the unmanned air vehicle. The Special Flight Operations Certificate must be issued to the person or company that has complete responsibility for the operation and safety of the unmanned air vehicle flight operation and responsibility for compliance with the conditions contained in the SFOC. The Certificate holder may be in direct control of the UAV by remote control, co-located with the UAV pilot or monitoring the state and progress of the UAV in the ground station, but in all cases, the Certificate holder must be the person or company who has legal custody and control of the aircraft.
It is essential that the Certificate holder is aware that it is his/her/their responsibility to ensure that the UAV operation is conducted in such a way that the safety of persons and property on the ground and other airspace users is not jeopardized. It could be said that the Certificate holder assumes the same operational and safety responsibilities as the owner of a manned aircraft.
Subsection 101.01(1) definitions:
"owner" - in respect of an aircraft, means the person who has legal custody and control of the aircraft.
"operator" - in respect of an aircraft, means the person that has possession of the aircraft as owner, lessee or otherwise;
b. Operation Manager
The name, address, and where applicable the telephone number and facsimile number of the person designated by the applicant to have operational control over the operation (Operation Manager).
Who will be the UAV operations manager?
Is the person qualified to act as the Operations Manager?
The Operation Manager is typically thought as the person who exercises command of all crew and personnel during UAV operations. The Operation Manager would be tasked with overall responsibility for the operational control of the UAV flight operation, including planning and communications. While the standards do not outline what duties have to be assumed by an Operation Manager, they could include:
providing a sufficient number of capable and informed persons to handle the operation with efficiency and safety;
establishing liaison with airport management, property owners, local agencies;
making application to the appropriate Transport Canada Regional General Aviation office with sufficient advance notice to complete the administrative and coordination duties required to prepare the Special Flight Operations Certificate;
ensuring all persons connected with the operation are properly informed of their duties and are familiar with the contents of the authorization;
making the decision to cancel or postpone the operation in the event of bad weather, or any other circumstances in accordance with the conditions of the authorization;
liaising, where applicable, with local aircraft operators to make them aware of the operation;
where applicable, coordinating with military air traffic services;
coordinating with Nav Canada with regard to the publication of a Notice to Airmen (NOTAM) etc.;
ensuring emergency procedures are developed in concurrence with and approved by the delegated agency appropriate to the site of the operation (i.e. at an airport the airport authority; over water this could be Coast Guard, Harbour Authority or other local authorities).
during the operation, the Operations Manager might
a. station himself/herself so as to have an unrestricted view of line-of-sight flying;
b. terminate the operation if it is being conducted in an unsafe manner;
c. communicate with Air Traffic Control;
d. communicate with the ground supervisor;
e. keep watch for other airspace users; or
f. broadcast to aircraft in the area of operation.
c. Contacting Operation Manager
Method by which the Operation Manager may be contacted directly during the operation.
d. Type and Purpose of Operation
The type and purpose of the operation - i.e. identify the intended role/mission/task/usage of the aircraft.
e. Dates & Times
The dates, alternate dates and times of the proposed operation. Providing it does not adversely affect safety, flexibility is encouraged for listing of specific dates and times.
f. Description of UAV System
A complete description, including all pertinent flight data on the aircraft to be flown.
As mentioned previously, a UAV is a system, consisting of three main components: The airframe (or vehicle, or platform), the ground control station, and the data link that connects the two. Additionally, there may be an external payload (sensors, cameras etc.), which is also operated from a ground station. Therefore, instead of just requiring performance specifications about the physical aircraft, information will be required about the entire UAV system. Examples of the type of information required are:
Air Vehicle - Normal Operations
UAVs can range in size from micro UAVs with six inch wing spans weighing 11 oz. to high altitude long range endurance UAVs with over 100 foot wingspans weighing 25,000 pounds.
Who is the UAV manufacturer?
General description of UAV
Category - aeroplane, vertical take-off and landing (VTOL), airship
Materials - graphite, composites
Dimensions - wingspan, length, wing aspect ratio, rotor diameter
Landing gear - retractable, tricycle
Propulsion system - battery powered electric propulsion, turboprop, turbofan; rear or forward mount
Fuel system - capacity, number of tanks, type of fuel
Weights - payload weight, maximum gross take-off weight
Performance - taxi speed, operating speeds, climb and descent rates, maximum altitude, maximum range, maximum endurance (time on station)
Operating limitations - day, night, visibility, temperatures, wind, crosswind, turbulence, icing, altitudes
Weather capability - ability to detect icing with airframe icing sensors. Does the response to icing require ground intervention? i.e. altitude change, backtracking
Carburettor icing - ground control response?
Flight instruments on board
Guidance and navigation equipment on board
Functions of onboard computer system - control flight control surfaces? Engine? Navigation system?
Redundant systems - i.e. flight controls, avionics system?
How does the UAV "see" and how is it "seen" by other airspace users, by ATC and by the operator? How does it sense other airborne objects? Equipped with radar, a TCAS system, transponder, optical infrared, an automatic dependant surveillance broadcast system (ADS-B)? Bright colour scheme, anti-collision lights and/or position lights?
How is the UAV transported to the launch site?
How is the UAV maintained? Is there a maintenance schedule? Who performs the maintenance?
What is the demonstrated reliability of the UAV?
How is the UAV system designed to minimize the potential for failure of any component to prevent continued safe flight and recovery of the UAV?
In order to integrate with other airspace users, the Certificate holder must ensure that their operation show an equivalent level of compliance with the rules and procedures that apply to manned aircraft. Special equipment (i.e. transponder) mandated for aircraft in certain classifications of airspace should also be fitted to UAVs intended for use in such airspace. Where it is deemed appropriate for the UAV not to be fitted with the equipment mandated by regulation, a condition exempting the use of the equipment will appear in the Certificate. Support for the removal of the requirement must be justified in the risk assessment.
Air Vehicle - Abnormal Events and Emergency Operations
How is the aircraft going to safely land on the surface without a hazard to persons or property in the event of an emergency descent?
Actions in the event of a communications failure
Failure of onboard sense and avoid equipment
Is the air vehicle equipped with a flight termination system in the event of a malfunction? At the very least, the UAV should have a fail-safe flight termination system that is automatically activated in the event of a critical system failure or loss of radio frequency link.
What happens when the engine quits or the system degrades due to a malfunction?
What if control of the airframe is lost because it sustains damage (bird strike, encounter with another aircraft, structure etc.)?
What if there is a failure of the navigation system?
What happens if the uplink is lost? Loss of voice link?
What happens if line-of-sight is lost?
What security measures are in place to prevent interference with someone taking control or jamming the radio control links?
If flight is autonomous, how does the UAV operator override the programming if the aircraft is behaving erratically? How reliable, fast and easy is this for the UAV operator to do?
Abort procedures following critical systems failure
If autonomous: does the UAV transit to a pre-designated recovery area, followed by an autonomous recovery or does it transit to a pre-designated recovery area followed by activation of a flight termination system?
Does the operator have a pre-programmed loss-of-link flight profile including termination actions should the control link not be re-established?
Is there a real time warning to the pilot in the case of a data-link failure (loss of signal)?
What happens if the aircraft encounters severe weather that is outside its limits or the conditions of the Certificate?
What happens if an aborted take-off becomes necessary? What about a “botched” recovery/landing?
What information is provided to the pilot in the event of a problem and how? Visual/audio warnings?
What happens in the event of loss of battery voltage, command link loss or electronics failure - does an auto land function kick in?
Ground control stations can range from a single person with a laptop computer to mobile or fixed stations housing several people. Control stations can be located near the site of the operation or remotely located hundreds of miles away.
Control method - how is it controlled, level of manoeuvrability. Remote control line-of-sight, autonomous, programmed flight?
Data on the UAV ground station i.e. what is the nature of the data- links? i.e. UHF or VHF links for radios, line-of-sight links, “over-the-horizon satellite links? What is the range?
How will the UAV pilot communicate with ATC? Is the ground station equipped to allow the pilot to communicate with the ATC facilities controlling the UAV regardless of the location of the UAV?
What instrumentation is there in the ground station? i.e. what instrumentation does the UAV operator have for reference -- how will they know the aircraft will stay within the altitude and distance limitations? Is the UAV system capable of displaying to the pilot all aircraft system and attitude information necessary for safe operation, control and navigation?
What are the launch, take-off, landing and recovery methods?
Redundant systems in the ground station?
How is precise position of the UAV reported to ground control? (i.e. onboard GPS). How often is this information relayed?
What are the communications procedures and associated links with the control station?
Can the pilot in the ground control station communicate directly with ATC real-time in both line-of-sight (LOS) and beyond line-of-sight environments? How are communications with ATC established? Does the operator have a direct telephone number with ATC for contingency use should radio communications fail? VHF radios, UHF radios?
What is the payload? - i.e. daylight colour video camera infra-red sensor (I.R. sensors), electro-optical infra-red cameras (EO-IR), synthetic aperture radar (SAR).
Nature of payload? - i.e. to provide real-time day video imagery of terrain being overflown, to determine real-time meteorological conditions
Payload limitations? - i.e. what if the UAV pilot and Payload operator require different operational limits, such as altitudes? What measures are in place to address these potential conflicts?
Firms involved in the UAV payload market are beginning to evaluate how to package multiple sensors, data links, navigation and mission-planning capabilities into a single UAV payload. For example, one product already on the market combines a third-generation night camera with continuous zoom capabilities, a colour or black-and-while daytime camera, a laser rangefinder and a laser illuminator or dual-band target designator, as well as video data links. Future versions of this product are expected to incorporate multispectral or hyperspectral cameras, laser radars and possible ultraviolet detectors, as well as a menu of smart imaging options that provide panoramic pictures or allow users to see through haze and other conditions. Still yet another company sells a 14-inch turret and four-gimbal payload which features day and night cameras, a wide angular field of regard, automatic video tracker, laser range finder and laser designator, as well as options for image enhancement, area scanning, movement detection and simultaneous transmission of TV images. Yet another example is the approach taken by the designers of the Global Hawk UAV. Instead of a ball turret, it uses an integrated suite of EO-IR and radar sensors and processor housed in six units in various spots at the front of the air vehicle. And rather than video imagery, Global Hawk’s sensors produce high-resolution still-frame images of large geographic areas, which are down linked in near real time. These product developments suggest that as sensor features such as auto-focusing, co-aligned cameras and automatic target tracking become more common, we can expect to see a reduction in the payload operator’s workload.
g. Security Plan
The security plan for the area(s) of operation and security plan for the area(s) to be overflown to ensure no hazard is created to persons or property on the surface.
What safe altitudes and distances are proposed for the operation - from members of the public, structures, vehicles, vessels etc?
Are spectators isolated from the UAV during take-off, recovery and during the flight operation? Fences? Barriers?
How will the Certificate applicant ensure that adequate separation between the spectators and the UAV is maintained during the flight operation?
Is it necessary to obtain permission of the property owners?
Is it necessary to obtain permission from the airport/aerodrome authority?
Will the UAV be operating in places where it will be necessary for any other people to be made aware of the proposed operation to ensure that they have no objections?
Will the UAV be operating in areas where the public will have to be removed from areas affected by the operation?
Are access routes available for emergency vehicles?
h. Emergency Contingency Plan
The emergency contingency plan to deal with any disaster resulting from the operation.
This would include a list of all the emergency situations that have been considered by the Certificate applicant. How are the risks to other airspace users and persons and property on the ground going to be mitigated?
The Certificate applicant needs to:
a. develop an emergency plan describing the personnel and equipment available to respond to anticipated emergencies, including incidents and accidents, or a medical emergency involving a spectator in the case where potential clients (or whomever) have been invited to watch the aerial demonstration.
b. communicate the plan, where applicable to the property owner, airport/aerodrome manager or air traffic service provider; and
c. have the equipment and personnel described in the emergency plan in place during flight operations.
It is not our responsibility to determine minimum requirements or standards for emergency equipment and procedures nor do Inspectors have the necessary expertise to assess the effectiveness or efficiency of a proposed emergency plan.
Airports have emergency plans and procedures in place. A Certificate holder should coordinate with the airport manager or authority. Generally speaking, UAV operations that depart, operate or land at an airport would adopt the emergency plans and procedures in place. In the event that the UAV mission requires inviting members of the public, the Certificate applicant should be made aware that the airport manager/authority and provincial or local governments set the requirements for medical facilities and personnel at public gatherings. There may be a need to contact local police depending on the size of the gathering.
When reviewing an application for an operation that is departing, landing or operating at a small airport or at an off-airport site, the plan submitted should be reviewed for obvious omissions, i.e. no first-aid or fire equipment on site. Deficiencies should be brought to the attention of the Certificate applicant.
At minimum we would want the Certificate holder to:
1. Be aware of what emergency response service is available in the area of operation.
2. Where warranted, establish advance contact with the applicable emergency agencies and authorities.
3. Know how to access emergency services and have the means to do so (i.e. cell phone).
4. Ensure that all persons associated with the operation who may be required to respond to an emergency situation are briefed in advance of the operation.
5. Have in place operational control measures necessary to ensure the safety and orderly conduct of persons attending the flight demonstration.
6. In the event of an aircraft emergency, the Certificate holder will want to establish that there is no immediate risk to life then implement procedures for flight termination i.e. transit to a safe recovery area.
i. Ground Supervisor
The name, address, telephone and facsimile numbers of the person designated to be responsible for supervision of the operation area (Ground Supervisor), if different from the Operation Manager during the operation.
In small operations, the Operations Manager and the Ground Supervisor could be the same person. Some of the additional duties that a Ground Supervisor might be responsible for include:
crowd control where spectators would be viewing an operation i.e. ensure crowd remains separated from ground station at distances as specified in authorization as well as take-off and landing distances and ground manoeuvring of UAV;
nsuring minimum safety distances are met in terms of occupied buildings, vehicles etc.;
communicating with the Operation Manager during the operation (portable radio, cell phone etc.);
arranging for the use of special radio frequencies as required;
security of the site.
j. Area Used for the operation - Scale Diagram/Photograph/ Chart
A detailed plan describing how the operation shall be carried out. The plan shall include a clear, legible presentation of the area to be used during the operation. The presentation may be in the form of a scale diagram, aerial photograph or large scale topographical chart and must include at least the following information:
i. the altitudes and routes to be used on the approach and departure to and from the area where the operation will be carried out;
ii. the location and height above ground of all obstacles in the approach and departure path to the areas where the operation will be carried out;
iii. the exact boundaries of the area where the actual operation will be carried out;
iv. the altitudes and routes to be used while carrying out the operation.
This should include a description of the classification of airspace in which the flight is planned.
Verify the area diagram/photograph is current and contains the information listed in paragraph 623.65(d)(3)(j) (i)-(iii) of the Standards. Any omission of information or details shall be brought to the applicant’s attention and corrected as soon as possible.
k. Additional Information
Any other information pertinent to the safe conduct of the operation requested by the Minister.
It is likely that an initial application may not contain sufficient information, therefore, there may be a need to request a considerable amount of information about the operation under this section. This could include requesting information such as:
(i) UAV Pilot Qualifications
There are currently no regulations governing the qualifications required to operate a UAV in Canadian airspace. To date, it has been found that most UAV manufacturers have their own requirements. However, the following questions can guide you in establishing minimum qualifications for the operation:
Who will be the UAV pilot? - i.e. the person who operates the UAV remote control or monitors autonomous flights from take-off to landing?
Does the UAV pilot hold a civilian pilot licence that would be relevant to the UAV being flown? i.e. if the UAV is an aeroplane, does the UAV pilot hold an aeroplane pilot licence?
Is the UAV pilot qualified for the type of operating environment? - i.e. if the aircraft is being operated IFR, does the UAV pilot have an IFR rating?
If the UAV pilot does not hold a licence, what equivalent experience, knowledge and skills do they have in order to operate the UAV in the desired environment? - i.e. do they have air traffic services knowledge in air traffic control rules and procedures, communications, radiotelephony? Do they have knowledge of aviation law, meteorology, navigation, airmanship, flight planning? How much experience do they have operating the specific UAV or other types of UAVs? How and where did they receive the training and how do they maintain currency? Manufacturer training? Company training?
Do they hold a flight crew licence, an ATC licence? What ratings are held?
Have they written and passed aviation theory exams?
Do they hold a radiotelephony licence?
Total experience on UAVs? On type?
What training courses have they undertaken?
What practical training have they had in the control of the UAV in flight? The UAV pilot should be able to control a specific UAV throughout its design parameters and potential operating conditions, including dealing correctly with emergencies and system malfunctions.
Is the UAV Pilot and payload operator the same person? If so, how does the UAV pilot ensure adequate control of the air vehicle?
The amount of interaction between the human operator and the unmanned vehicle ranges across a broad spectrum from a direct control-type system to an autonomous vehicle. As with manned aircraft, greater automation of the vehicle system will allow the UAV pilot to focus attention on the mission rather than on tasks associated with vehicle flight.
In the case of the Global Hawk, the pilot has no direct control over pitch, bank or power settings. The Global Hawk pilot tells the vehicle the performance he/she desires and the vehicle’s onboard computer translates that into control inputs. The performance of the vehicle is relayed back to the UAV pilot through the human computer interface in the ground station. With other UAVs, human intervention is required to control the air vehicle. For example, with the Pioneer, the pilot manually controls the flight surfaces of the vehicle during take-off and landing. And, with still with other UAVs, like the Predator, rudder pedals, throttle and joystick are all housed in the ground station. Clearly the psychomotor (eye-hand-foot coordination) skills and cognitive skills required to fly UAVs vary drastically from vehicle to vehicle. It is not fair to assume, however, that because one UAV is larger and more complex than another UAV that the workload for the UAV pilot is proportional. In fact, the workload associated with the Global Hawk (25,000 lbs UAV) is reported by the UAV pilots to be relatively low because of automation. Mental work overload may cause loss of situational awareness but not cause loss of control - which may not necessarily be the case with a small UAV.
Since there are no presently no standards governing the qualifications required to operate a UAV in Canada, the bottom line is that you need to satisfy yourself that the UAV pilot is adequately trained, qualified, proficient and current to operate the UAV in the operating environment.
(ii) Aircraft Airworthiness and Continuing Airworthiness
We do not require a UAV to hold a flight authority, nor do we define the matters to be taken into account for the design of the aircraft or their systems. Some of the following questions may help to establish system airworthiness.
Does the aircraft hold a type of airworthiness certification document, or has the aircraft been through an airworthiness assessment by another authority (Canadian or foreign military, foreign civil aviation authority)? Assessed to what standard?
How does the Certificate applicant know the aircraft is airworthy?
Does the air vehicle design facilitate control of the UAV by the UAV pilot and provide clear indications of UAV flight status?
Are real time, direct communications and continuous data transmission capabilities provided? Is it adequately protected from hazard of electromagnetic interference?
Does the UAV system incorporate a fail-safe flight termination system or autonomous recovery system?
Standard operating procedures should be in place for:
Take-off and landing procedures
Loss of control data link
Abort procedures following critical system failure.
Is there a Flight Operations Manual or Operating Instructions?
Are there maintenance and inspection manuals, schedules and records?
Are there UAV pilot training manuals?
Are there Standard Operating Procedures (SOPs)?
Has a Risk Assessment been conducted?
Is there a Flight Authority issued by another civilian authority or by a Military authority, or any type of authority (operational)?
Is the aircraft registered - civilian or military?
It is incumbent on the Certificate holder to be able to demonstrate to the Minister that they are adequately equipped to safely operate the UAV in the desired environment. The Certificate applicant will need to address:
Integrity of the airframe
Reliability of the engine
Reliability of the control systems
Reliability of the control communications system
Ability of the UAV pilot
(iv) Weather Limitations
Weather minimas will generally be established on the basis of class of airspace in which the flight is to be conducted, taking into consideration the equipment and capabilities of each specific UAV system. The Certificate will specify minimum distances from cloud, ground, visibility etc.
UAVs should not be flown into known icing conditions without proper anti-icing/de-icing equipment.
It is important to distinguish between the types of visibility that the Certificate holder will have to abide by. In some cases there may be a need to establish a condition that is based on visibility at a specific aerodrome.
Ground visibility is defined in subsection 101.01(1) as - “in respect of an aerodrome, means the visibility at that aerodrome as contained in a weather observation reported by
a. an air traffic control unit,
b. a flight service station,
c. a community aerodrome radio station,
d. an AWOS used by the Department of Transport, the Department of National Defence or the Atmospheric Environment Service for the purpose of making aviation weather observations, or
e. a radio station that is ground-based and operated by an air operator.”
Flight visibility is defined in subsection 101.01(1) as - “means the visibility forward from the cockpit of an aircraft in flight”.
(v) Control Station
In its simplest form, the UAV control station may consist of a hand held transmitter incorporating basic flight controls and rudimentary displays similar to those of a model aircraft. Control stations for UAVs beyond line-of-sight should include controls and displays for aircraft attitude and performance, propulsion, navigation, aircraft systems and sensor operation as well flight system and voice recording equipment.
Some of the restrictions that are being considered by other aviation authorities with respect to control stations include:
UAV pilots (and payload operators) cannot leave the control station unless another qualified person is in the station
nstrumentation in the control station must be the same as that required in the cockpit of a manned aircraft except a magnetic compass or DI is not required
In the absence of engineering evaluations on individual UAV systems, no portable electronic devices (cell phones, lap tops, calculators, hand-held GPS) are permitted in control station aside from what is required operationally.
No endangering safety in the control station
UAV pilots and payload operators operating in control stations above 10,000 ft MSL shall use supplemental oxygen for the duration of each flight while at their duty stations.
Lights are required in the control station - i.e. a flashlight for night ops
Fire fighting equipment must be available in the control station
The control station must be secure - i.e. capable of being locked
UAV operations should have 2-way radio communication as primary communication. When VHF communication is not available, a telephone may be used
There must be an independent means of backup communication between the ground station and the ATC agency
The UAV ground station should include complete fault indications to indicate lost communication links (i.e. off flags or equivalent)
Unlawful interference is a concern since it may be more difficult to protect a control station against unlawful interference than the cockpit of an aircraft. Ground-based screening would have to be continuous unlike one-time screening where passengers are screened before boarding a manned aircraft.
In general, when operating in controlled airspace, UAVs should be operated in accordance with the rules governing the flights of manned aircraft. UAVs should be able to comply with ATC regulations and equipment requirements applicable to the class of airspace within which they intend to operate.
TP 13391E (ANS&A Policies and Procedures Manual), Section 4, outlines UAV operations and the policy statement says, "until UAV operations are integrated into the national airspace system, restricted airspace may be established or designated for UAV operations". Therefore, in the case where integration of the UAV into the airspace is particularly problematic (i.e. heavy general aviation traffic within Class G airspace), restricted airspace may be established or designated for UAV operations using Section 5.1 of the Aeronautics Act or using Class “F” Restricted or Advisory Airspace. Regional Aerodromes and Air Navigation inspectors will assist proponents of UAV operations in coordinating airspace and NOTAM requirements with Nav Canada. If necessary, coordination of restricted airspace may also be required in support of the operation.
When the airspace being operated in is under military authority, the applicant will need permission from the authority.
UAVs are often slower than most aircraft that routinely fly in the same operational stratum. This raises the question of whether UAVs will need to have increased separation minima where a UAV is unable to operate at performance levels consistent with ATC control clearances. Additionally, specific UAV SIDS/STARS may be required and they may need specific designation. However, these are not issues that will be addressed in this staff instruction. The ultimate goal of the UAV community is to have UAV operations that are transparent to ATC.
(vii) Air Traffic Control Agency
In terms of the use of airspace, the Certificate applicant is responsible for coordination with the air traffic control agency responsible for supplying air traffic services for the airspace affected by the operation. Validity of the Certificate should be contingent upon the Certificate holder doing this coordination. As with manned aircraft, UAV operations require deconfliction with, coordination with, and notification to other airspace users.
Certificate holders will need to comply with air traffic control agency instructions, maintain radio contact between the UAV operations personnel and the air traffic control agency, and ensure that other (manned) airspace users are notified of the UAV activities, i.e NOTAM. The times entered in the NOTAM obviously cannot exceed the valid-to-date of the SFOC. The operator will have to contact the airspace service provider responsible for the airspace in the location where they will be operating. Depending on the environment the UAVs are operated in, there may be additional operating conditions in the Certificate with respect to advising airport authorities, etc.
All communications with ATC must be continuously monitored by the UAV pilot. The UAV pilot must be capable of taking immediate active control of the UAV at all times, and must be capable of complying with ATC instructions.
When a UAV is operated in an autonomous or programmed flight mode, UAV performance and designated ATC communication circuits must be continuously monitored by the UAV pilot and the UAV system and pilot must be capable of immediately taking active control of the UAV. UAV system status should be monitored and ATC clearances complied with, making flight path corrections as required and/or directed by ATC.
(viii) Other CAR Requirements
The Inspector will need to draw to the Certificate applicant’s attention the fact that the CARs have additional requirements that apply to UAVs, which are often, but certainly not always, addressed specifically in the Certificate conditions as shown in the examples below:
Section 606.02 - Liability insurance - No aircraft owner shall operate an aircraft unless, in respect of every incident related to the operation of the aircraft, the owner has subscribed for liability insurance covering risks of public liability in an amount that is not less than...
Certificate holders must subscribe for adequate liability insurance covering risks of public liability as outlined in section 606.02. This requirement should appear as a condition in the SFOC.
Section 202.13 - Registration and marking - No person shall operate an aircraft in Canada unless it is registered in Canada, in a contracting state or in a foreign state that has an agreement in force with Canada that allows an aircraft that is registered in that foreign state to be operated in Canada...
To date, SFOCs have permitted operation of UAVs without registration or marking by way of a statement in the SFOC. Where an application is made for UAV operations that involve multiple aircraft flying simultaneously, the Inspector should contact Special Flight Operations staff in HQ who will coordinate with the Aircraft Registration division.
Section 605.03 - Flight Authority - No person shall operate an aircraft in flight unless a flight authority is in effect in respect of the aircraft.
To date, SFOCs have permitted the operation of UAVs without a flight authority by way of a statement in the SFOC. It is difficult to estimate when or if Transport Canada may begin issuing flight authorities for UAVs.
Section 605.35 - Transponder Requirements - No person shall operate an aircraft, other than a balloon or a glider, in airspace referred to in Section 601.03, unless the aircraft is equipped with a transponder and automatic pressure-altitude reporting equipment.
As mentioned previously, the Certificate holder will need to provide adequate justification for why the UAV is not equipped with a transponder if it is being operated in airspace that requires the aircraft to be equipped with a transponder.
Section 605.17 - Use of Position and Anti-collision Lights - No person shall operate an aircraft in the air or on the ground at night, or on water between sunset and sunrise, unless the aircraft position lights and anti-collision lights are turned on. Anti-collision lights may be turned off where the pilot-in-command determines that, because of operating conditions, doing so would be in the interests of aviation safety.
Aerial Demonstrations before Invited Assemblies of Persons
In cases where the mission of the UAV is to demonstrate system capabilities to potential customers, Special Flight Operations Standards - Special Aviation Events - Air Show Standards will need to be considered in matters of crowd control, flight lines, distances from spectators etc. Appropriate conditions will have to be spelled out in detail in the SFOC.
Safety Management System
By 2007, an SMS system will be required for all certificate holders. Until that time, a condition should be added to the SFOC, such as:
“The Certificate holder shall maintain an adequate management organization that is capable of exercising supervision and operational control over persons participating in the (enter name/model of UAV) operations”.
The management of a UAV operation will vary according to scope and complexity of the mission. A small UAV operating in the Arctic may not require the support of a large number of persons; rather the expertise in a variety of areas could come from one or two key personnel. It is most important that the Certificate holder is aware that since the Minister issues the Special Flight Operations Certificate to him/her, it is his/her responsibility to ensure that the operation is managed and conducted in such a way that the safety of persons and property on the ground and other airspace users is not jeopardized.
The Transportation Safety Board, established under the Canadian Transportation Accident Investigation and Safety Board Act, is responsible for investigating all transportation occurrences in Canada. Since many UAVs have a take-off weight less than 5 700 kg, they do not fall within the criteria of a “reportable aviation incident”.
The Certificate holder should be aware of the legislation regarding incidents and accidents and that the release of names in fatal accidents is at the discretion of the Coroner.
Depending on the scope of the operation, a condition may be added to the Certificate that requires the Certificate holder to report:
Any persons injured during operations.
Any unintended contact between the UAV and persons, livestock, vehicles, vessels or other structures.
Any damage incurred to the airframe, ground control station, payload or communications links.
All information, documentation, correspondence and records of telephone conversations received and used to issue the Certificate for the conduct an unmanned air vehicle flight operation should be kept together and placed on the appropriate regional files and in RDIMS.
The Inspector should ask the Certificate holder in a covering letter that accompanies the Certificate to submit flying statistics to their office. Since Transport Canada does not currently register UAVs, flying hours are not captured. In the case of a Certificate that authorizes multiple flights, you could ask the Certificate holder at the end of the operation to provide you with the following information:
How many flights were conducted?
Total hours accumulated in flight, and Total number of UAVs flown.
Hard job competing with gravity.
|03-14-2008, 08:32 PM||#12|
Join Date: Feb 2008
Total Props: 0
Thankyou Eyeinsky for posting that long extract from TransCans website.
Please do not take my tone here as confrontational, I am merely trying to determine what is the truth.
Here is the gist of what I have learned. Merely having a camera on your aircraft and taking all the pics you want does does not make your aircraft a UAV. Do it "for fun" and you are a model aircraft. Transport Canada will agree with this if you call them. There are no Transport Canada restrictions on where you can fly other than what is stated in 602.45. Here is an exact quote of that reg :
There are restrictive "UAV" regs in place that require TransCans express approval (SFOC).
So now the question is when does a "model aircraft" become a "UAV"?
Here is a quote from TransCans webpage :
Policy is not Law. Cars are Law. Laws must be clear and specific or they will be thrown out of court. Time and again we have seen this in the news as every miscreant gets his charge thrown out on some little detail.
Particularly relevant to this discussion is how Transport Canada defines "commercial" for full-size aviation. It is considered "carriage of people or goods for hire or reward".
Tansport Canada will allow you, if you have a full-size private pilots license (NOT commercially rated) to go up alone in a plane and point your camera out the window and shoot pics all day for profit. You do not need a comm pilots license. The plane you use does not need a comm rating either. So taking pics for sale from the air does not make you "commercial" in TransCans eyes. Full-size anyways.
Also, you can equip your full-size aircraft with a fixed camera, say downward-looking through a window in the belly of the plane. The mounting will have to be certified, but if it has the proper paperwork it will pass. Then you can go up, again with only a private pilots license, and shoot ortho pics all day for profit. No commercial rating needed on the plane or you.
So when I say merely selling a few pics taken from your model after the flight is legal, you can See this fits TransCans own definition of "commercial" as they apply it to full-size. Surely they have to be consistent when things get down to the Day In Court.
|03-22-2008, 02:50 PM||#13|
RCC Senior Contributor
Sorry not trying to be smart, just meant to get across that there are some people that try to skirt the issues and operate in the gray area of the system and it ends up cost the same in the end. There lawyers end up take there money in the end.
Please if you have some more data please share. That sound very interesting I would love to operate my AP heli under private operation.
All that info that I posted was pulled together from Transport Canada web site. I just assemble it to make it in one easy read. Some of the data can be hard to find. I have passed this data on to many persons. Just remember this was current the day copied it. UAV's are a hot topic with the boy's at Transport Canada and new regulation are being wrote currently.
My discussion with Transport Canada have been quite well received and helpful and they do understand there is difference between UAV operation below 500 AGL line of site heli toting a camera compared to Predator or Global Hawk.
Hard job competing with gravity.
|04-19-2008, 12:22 AM||#14|
Join Date: Apr 2008
Total Props: 0
Re: By-Law / License Required
The above TC regs clearly state several times that the difference between a model aircraft (recreation) and a UAV is whether the aircraft is operated for "monetary gain or other form of hire and reward, it is considered an unmanned air vehicle and is subject to UAV regulations"
|04-19-2008, 12:34 AM||#15|
Join Date: Apr 2008
Total Props: 0
Re: By-Law / License Required
I agree that it seems ludicrous that the regulations make this distinction between recreational and commercial use where clearly no such distintion exists in the full sized aviation world.
One would think that they would recognize the fact that persons involved in a commercial AP venture would actually have better, more fully refined equipment as well as a generally safer operation (in most cases).
Currently, as a result of an overeaction by the FAA, the US situation is a mess. The new FAA proclamation also prohibits ANY commercial AP without very involved and specific COAs.
|04-20-2008, 05:21 PM||#16|
I am: Conway V
Join Date: Mar 2008
Feedback: 5 / 100%
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Re: By-Law / License Required
I have been operating for the past year in full cooperation with TC Winnipeg office and I can say from personal experience that they are great people to deal with. Yes you do need to have their approval if you are taking pictures on a commercial basis. They can fine you and more if you don't follow their regs. They are as new to this as most of us and if you give them a chance and treat them as normal human beings they will most definately be there to help you out. I hate paperwork as much as anyone and it is an extra hassle to fill out applications and stuff but there is peace of mind knowing that should anything happen you are covered.
I did a job at our full size airport terminal last summer and our airport manager commented to a couple people that he was very impressed with how organized I was (little did he know, LOL) because I had all my paperwork in order. When it came time to do the job I had a permission slip typed up for him to sign and I had a copy of my SFOC from TC for him to review and keep for his records. When he first heard about me flying a model during the day's events he was very skeptical and was ready to put a stop to it. He did not realize it was more than just a hobby for me and that is how most people think.
Getting a recomendation from a place like that is worth more than all the extra effort to work with Transport Canada.
I recently was asked about doing some work for a major oil company in the area. This AP work will be at a large facility and they don't take safety lightly. There is no chance I will even get in the front gate without some sort of formal authority behind me.
My recomendations are to dot the I's and cross the T's and do it right. In the long run you will be much better off. Also helps the overall image of Model AP'ers.
Sorry for all the ramblings but thought some of it might be useful.
I would be happy to help out if anyone has any other questions reguarding AP in Canada but I don't have time to check out these forums that often.
Here is my email firstname.lastname@example.org
|04-21-2008, 07:55 PM||#17|
Join Date: Feb 2008
Total Props: 0
Re: By-Law / License Required
Well, It seems some of you have had success dealing with TransCan, and that is good to hear.
My point, and the point of legal counsel, is that there is no specific regulation being referenced here.
Several posts here talk about "regs". Point out the specific "reg" in the Canadian Aviation Regulations that makes a UAV out of an otherwise hobby aircraft if a photo or other is sold at after the flight ?.
Transport Canadas' "interpretation" is what I see being referenced here. Not CAR regs.
This is very specific legal language; Regs are what are used to charge you.
Also, what is the 'fine' for doing this ? The Civil Aviation Tribunal is the flying worlds version of traffic court. It can be searched online, but there is not one case of someguy with a slowstick or otherwise being charged with anything.
The downside of the SFOC process is that it requires a TransCan officials explicit approval of your operation in its minutae; this means should something ever go wrong on flight day and there are damages or worse, TransCan can most likely will be added to any ensuing lawsuit. By giving you approval to do your flight at a certain location, timing and with that specific aircraft, they are sharing liability with you. The officials know this and thus will most likely only give you approval to fly where they figure there is no way you can hurt anyone. Thus it is very hard to get SFOC's in locations where all the commerce is. Duh !.
Also, you may get a very different result depending on whcih TransCan office you are dealing with. Some of the officials will be not be knowledgable about the current state of model aircraft, Still others may be modelers themselves. No uniform standard of what will pass or not exists, very unlike full-size aviation which is by the book.
Consider this in contrast to the typical full-size private pilot who, once he has his license, is essentially free to go where and how he wants. Transport Canadas enforcement of full size aircraft infractions operates almost exclusively on a reactionary basis. They show up after you land your cessna in the lake.
Last edited by RebelYell; 04-21-2008 at 08:01 PM.
|04-25-2008, 11:44 PM||#18|
I am: Conway V
Join Date: Mar 2008
Feedback: 5 / 100%
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Re: By-Law / License Required
Very good and interesting points. And I don't disagree at all with your viewpoint, just wanted to add some more food for thought. I can't say I have had any bad dealings with TC but haven't done any work in commercial or "built up" areas yet either. I plan on doing some this summer and will be going through the neccessary red tape to do so. I kind of like the idea that they will take some of the responsibility as well as the fact that my insurance policy is probably useless if I am not following TC guidelines. Again, valid point, it may be somewhat restrictive. One other point that was made by the TC officer who I deal with is that there is no maintenance requirements for our models. Full size must go through regular inspections and overhauls. Our models, although may be in better condition at all times because of our mantenance, have no legal requirements of what condition they must be kept in. This is why they are so skeptical when allowing flights over things. The part about the cessna in the lake may be completely true but the first thing that will be checked is who did the last inspection on the airframe, engine, linkages, instruments, etc. depending what went wrong. With our models it doesn't matter, it is still going to be the fault of the person controlling it because there is nobody else to point a finger at or blame.
To be completely honest about this, I would rather just do good mantenance and be able to use my own judgement for jobs, but as it is I want to do it the right way and not have to worry if something does go wrong.
Not trying to take sides here, just offering opinions and experiences.
|04-27-2008, 08:40 AM||#19|
RCC Senior Contributor
Re: By-Law / License Required
TC to date will allow or do not concern them selves with private AC under 1200lb TOW. No pilot licence required or maintenance standards, Ultra light Aircraft operate in this realm. Sound pretty scary to me.
As far as maintenance on our machine I have developed a log book and a process of controlling squawk and inspection; Pre-flight, post-flight inspection, but have left all components on condition. For me an Aircraft Maintenance Engineer they can accept some what, what I conclude. That said we also operate equipment that does not conform to any type certificate approve in this country. I am not sure if I want to bring it up with TC but some day it may be require. TC would have to come up with standards and all equipment would measured to this scale.
We as group must pull together RCAPA.CA and get organize, so we can control our destinies.
PM me if you are interest. I can fwd the link.
Hard job competing with gravity.
|05-22-2008, 09:38 PM||#20|
RCC Master Contributor
I am: Patrick G
Join Date: Apr 2008
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Re: By-Law / License Required
wow i was thinking of getting into AP but would have never thought TC would have issues with it. Anyone that does AP for a living what kind of expenses do you have, insurance, licence if needed permits anything. I'd love to know what im in for if i decide to
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