In the new RPAS 900 CARs, the intent of the “SAFE” rating for aircraft (A/C) under 25 kg was to provide manufacturers and operators with a path to be able to fly their RPAS in three higher risk situations that had previously been covered by either SFOC or with Compliant A/C.
The new categories of advanced flight operations from the 900 CARs are:
- Flights in controlled airspace under 400 ft AGL
- Flights less than 30m but more than 5m from people not involved in RPAS operation
- Flights less than 5M and over people not involved in the operation.
These operations are described in the CARS at section 901.69, but until recently, there was no documentation to explain what a manufacturer needed to do to specify which of their A/C were designated to fly in each of these categories.
Previously Compliant A/C are grandfathered for the first two categories.
The declarations need to be done by June 1st to allow flight in these categories when the new regulations come into force.
TC is now releasing a draft Advisory Circular, AC922, that provides the detail behind the standard mentioned in the CARs.
USC has obtained a copy for download and you can download it from this link.
Here at USC, we were happy to see the 900 series RPAS regulations roll out, as that helps provide some stability to our members and other businesses in the RPAS industry, and glad to see the AC come out as well to get the SAFE process started. We attended a session in Ottawa next week to review and provide comments to the Advisory.
USC expressed a number of concerns and questions to the Transport RPAS team, to summarize what we’ve ben hearing from our members and other participants in the RPAS Canadian industry:
- What happens to existing Complex SFOC Operators if their current A/C are not declared in any category of “SAFE”? Will they be forced to purchase new A/C?
- What happens if the larger manufacturers don’t declare for an operators A/C even if the published specifications would allow operation in uncontrolled airspace, for example?
- Is there a plan “B” to allow operators to continue business in the case that their A/C are not declared “SAFE”?
- Was the cost of the Safety Assurance work effort and timeframes considered with respect to smaller manufacturers?
- How would a manufacturer utilize historical operational experience for their A/C to provide the information required for declaring in each of the operational parts?
- How will owners of current A/C be notified if the status of their registered RPAS declarations changes?
The good news is that this is a draft document and TC is looking for comments and input from interested parties to comment on the impact of the Advisory Circular.
You should send your comments BY FEBRUARY 22. USC encourages everyone with valid concerns and comments to send in their feedback.
You can send comments to: [email protected]