In late May of this year, Transport Canada held two days of talks with RPAS stakeholders from across the country in Ottawa. Many USC-STC members attended the session, entitled Drone Talks: Planning for Success.
The event drew roughly 125 participants and included workshops on the following topics:
- Beyond Visual Line of Sight (BVLOS) operations
- Airspace and RPAS Traffic Management (RTM)
- RPAS airworthiness and certification
- RPAS pilot licensing and training
Now, TC has released a report summarizing the event in both official languages. We are pasting both versions of the report below. If you have any questions or feedback, please contact the RPAS Task Force at the following email address: [email protected].
With that, here’s the summary:
Remotely Piloted Aircraft Systems (RPAS) is an emerging technology that is changing the composition of the aviation sector, introducing new challenges, risks and opportunities. Transport Canada (TC) received funding through Budget 2017 to develop regulations for the safe adoption and integration of RPAS. Following the announcement, an RPAS Task Force was created within TC with a mandate to develop a regulatory framework and program to support the safe integration of the technology into the airspace. Regulations for Visual-Line-of-Sight (VLOS) operations were drafted and came into force June 1, 2019. TC is now shifting its focus to longer term strategic planning, which includes planning for Beyond-Visual-Line-of-Sight (BVLOS) operations, as well as the emergence of “next generation” RPAS.
To this end, on May 29-30th, 2019, TC held Drone Talks: Planning for Success, which was a two-day facilitated workshop event in Ottawa that focused on tackling key RPAS issues and challenges and planning for future success in Canada and abroad through early, meaningful discussion with stakeholders. Approximately 125 stakeholders participated, which included representatives cross-cutting different segments of the industry. See Appendix A for a breakdown of participation. The event featured workshops on the following topics:
- Airspace and RPAS Traffic Management (RTM)
- Beyond Visual Line of Sight (BVLOS) operations
- RPAS Airworthiness and certification
- RPAS pilot licensing and training
For each of these topics, TC officials presented a proposed approach and sought input through a series of discussion questions. Working in groups, stakeholders provided their feedback in-real time through the use of a digital tool. The results were then synthesized, and there was an opportunity for subsequent reaction. A summary of what was heard is included below.
Workshop #1 – Airspace and RTM
Stakeholders recognized the importance of developing and implementing a RTM framework to enable the safe and efficient commercial operation of RPAS in Canadian airspace and were supportive of the joint-working group created by TC and NAV CANADA in winter 2019.
Overall, the consensus amongst stakeholders appeared to be that a two-system approach would need to be taken, whereby a separate system of traffic management for RPAS is established from traditional aviation before eventual integration would take place. There was also widespread acknowledgement that the RTM technology was not ready for application in more complex, high risk environments such as densely populated urban areas; however, TC should not hold off on testing and enabling all operations just because a RTM technology wasn’t ready for the more complex environments. Rather, there was an opportunity to move forward with supporting operations in areas and/or instances where there is less risk, while RTM technologies develop in parallel. As stated by stakeholders: “Do not force technology on people if they don’t actually need it. Real time traffic management isn’t necessary needed in all situations.”
Critical factors to consider in developing Canada’s RTM framework, as identified by stakeholders, are outlined below under the following broad categories:
- Geography – there are large remote and unpopulated areas in Canada. Solutions need to reflect the realities of this geography (e.g., feasibility/necessity of 100% coverage).
- Technology requirements – to be successful, technology solutions must be put in place to support greater situational awareness, enable communication with traditional aircraft, address non-cooperative aircraft, and include sense and avoid capabilities.
- Different RTM levels – the scope of RTM needs to be clearly defined and then tiered based on the associated risk level of the operation and environment where operating.
- Communications/telecommunications – infrastructure is limited in some areas.
- Standardization – there should be harmonization and international transferability.
- System of certification & licensing – need to ensure there is a complementary system.
As cited by stakeholders, some key advantages that Canada holds include: low population density; lots of airspace for demonstrations and testing; less lobbyist control; world class centers of excellence for emerging technologies; a mature aviation community, and existing safety culture. On the other hand, some of the disadvantages cited included: limited financial investment; the size and geography (vast and harsh weather limits testing and commercial applications); limited ground infrastructure and satellite coverage in some areas; and the fact that three governing authorities are involved (TC, NAV CANADA, and National Defence).
In terms of priority aspects under a phased-in approach to implementing RTM in Canada, there was widespread agreement that key priorities should be the continued development and testing of technology, and establishment of infrastructure and procedures that will ensure safety and security by enabling greater situational awareness, remote ID and tracking, and detect and avoid capabilities. In particular, we heard: “Communication with crewed aircraft at low levels is key”, and “We need to ensure that operators cannot disguise themselves as friendlies in their reporting and transmissions”. Finally, we also heard that educational awareness and training for pilots should be prioritized since this is a means of ensuring safety and greater public confidence.
Workshop #2- BVLOS Operations
Stakeholders welcomed Transport Canada’s development of a high-level roadmap for a regulatory framework that would permit commercial BVLOS operations in Canada, including the approval of lower-risk commercial operations as early as fall 2019.
When asked what risk environments [or Aircraft Encounter Categories (AECs)] access was needed to in order to enable BVLOS commercial operations in the next 3 years, stakeholders cited a variety of different risk environments, which reflects the diversity in the Canadian industry and breadth of potential use cases. Stakeholders were particularly interested in operating in more densely populated areas (primarily cities), northern areas with low population (to support mineral exploration and/or infrastructure development), and remote areas (to support medical supply delivery). Further, stakeholders expressed interest in operating within uncontrolled airspace – both under 400 feet above ground level (AGL), and between 400-600 ft. AGL, as well as operating in controlled airspace, but under 400 ft. AGL; the corresponding AECs were AEC 4 through 10.
In terms of factors limiting industry’s ability to conduct BVLOS operations (excluding the regulatory framework), stakeholders identified the following:
- Financial limitations – as stated by stakeholders: “The technology might exist, but reliable systems are cost prohibitive, and potential revenues / end use ability are also still unknown”
- Technology – systems still need to mature and increase in reliability
- Lack of guidance from TC and detailed information on obstacles and terrain
- Public perceptions, acceptance and privacy considerations. We heard: “This is an important element of the business case. We need the framework to work towards this, otherwise we can’t afford to stay in business without it”.
In terms of strengths that the Canadian RPAS industry holds currently, many stakeholders spoke about Canadian academic institutions and the great collaboration that exists between industry and academia. They also spoke of the sizeable aerospace industry, and the many business opportunities that exist (many strong and economically viable applications/verticals). Stakeholders mentioned the fact that Canada has a good technology base, skilled and experienced professionals, an established industry association, testing and development facilities, and a supportive regulator in place. Finally, some stakeholders mentioned that there were advantages from a geographical perspective, with Canada spanning a large territory and having low population density, which means there is a lot of open space, and diverse weather environments for testing.
In adopting the Specific Operations Risk Assessment (SORA) model, stakeholders suggested that the following be considered in order to authorize BVLOS operations in Canada:
- Adaptations to the methodology to reflect a more granular level detail on population information, environmental areas, the transportation corridors and structural risks, and/or the supporting technology in place (i.e., communications network and availability).
- Additional data collection and information sharing in the Canadian context.
- The degree of standardization with other countries.
Finally, it was suggested that TC also look at approaches used in Australia, USA, France, Finland and Norway in order to learn from other states’ experiences.
Workshop #3 – Airworthiness and Certification
TC presented a risk-based approach to the certification and airworthiness approvals of RPAS, where there would be scaled airworthiness requirements for Category B and C RPAS, for feedback from stakeholders. Overall stakeholders were supportive, as they felt an airworthiness concept was required for these RPAS due to the associated size and kinetic energy. They also appreciated the flexibility of the proposed approach and indicated it could be mutually beneficial for both manufacturers and operators. It was felt that the alternative – a one-size fits all approach to airworthiness and certification would be inflexible and ineffective. However, support for the approach was not unanimous: some disagreed, indicating that it might limit the scope of the operations and it did not account for computational system capabilities (flight controller + software). Other considerations noted included:
- Need for further guidance, training, and procedures (e.g., maintenance of RPAS).
- Importance of communication and information sharing.
- Resource limitations could impact TC’s capacity to effectively manage the process.
- A caution against giving industry too much freedom or delegating too much authority for determining airworthiness (continued role for government in this area).
- Potential negative impacts on small businesses.
- Need to consider the operating environment as part of the risk assessment.
With respect to the proposed RPAS manufacturer authorization process for Category B RPAS, the majority agreed that it was a reasonable process, indicating: “Accountability has to be with the manufacturer. There is no other solution”. However, stakeholders again indicated that further guidance would be necessary (i.e., maintenance requirements, the safety rating / test, and roles and responsibilities of the operator versus manufacturer) and that strong communication, and a process to assess third-party after-market configuration modifications and/or products manufactured outside of Canada would be necessary. Of those that disagreed with the proposed Category B process, they felt that a “light” certification process was needed instead (e.g., supplemental type certificate process, which could be audited).
In terms of the proposed use of a traditional type certification process for Category C RPAS, most stakeholders agreed: indicating that the higher risk inherently associated with this RPAS category meant that a type certificate process should be applied. There was a responsibility to ensure safety of the public and that the standard should therefore be the most stringent. However, while some indicated they felt many of the current aeronautical standards were suitable for Category C RPAS (with there being “no requirement to re-invent the wheel”), others stipulated that: “It cannot just be a copy-paste from traditional aviation. The details need to be different as the safety aspects and failures are different. Further, while they were supportive in general, they indicated there may be a need for added flexibility – i.e. further delineation based on the specific type of aircraft and/or utilization. Others disagreed with the whole notion of a type certification process being applied based on it likely leading to longer lead times, higher costs being passed from manufacturers to operators, and that it would stifle innovation.
With respect to the thresholds for delineating between Category B and C RPAS, stakeholders had varying ideas. One stakeholder table indicated that the main difference between the two should be the amount of kinetic energy: “At a certain amount of kinetic energy it becomes unnecessary to delineate as the effects of an accident may be catastrophic regardless”. However, many felt that it should not be just energy or size based, and other factors should be considered, such as whether it is fully autonomous with people on board, operating over a crowd, BVLOS at very high altitude, and/or the possibility of damaging critical infrastructure.
Workshop #4 – Pilot licensing and training:
In the context of rapid advancement in RPAS automation and increasing levels of autonomy, stakeholders were asked to consider the future role of RPAS pilots and the relationship between the pilot and the aircraft. Stakeholders indicated they felt the role of RPAS pilots and the specific tasks they perform would change quite drastically in the next 5-10 years, with there being a de-emphasis of traditional pilot skills as the operations become increasingly automated. In the future, many indicated that they felt RPAS pilots would act as more of a “mission manager or fleet operator” than a pilot. In this case, physical flying skills were not required; individuals would instead need skills in the area of mission management, situational awareness, and critical thinking in order to respond to unforeseen circumstances. Further, they would need to start focusing on the interpretation of the data collected, while also fitting into multiple roles (acting as a “jack of all trades”), and needing to learn multiple systems. It was suggested, however, that regardless of the level of automation, having a “pilot in the loop” would remain a necessity (for emergency situations), a base of knowledge about aviation would continue to be a necessity, and there would need to be a focus on safety culture similar to traditional aviation.
Stakeholders were also asked to consider what skills and knowledge would be required to fly BVLOS compared to VLOS. In this regard, stakeholders felt that there was a notable departure. In flying BVLOS, an operator would require more knowledge on situational awareness, aviation knowledge, training on how to use ATC communication, and understanding of technology and automation system features. Some indicated that in order to fly BVLOS, a commercial pilot license / IFR rating should be required with a minimum number of flight hours on a specific platform and recency requirements. Others stressed the importance of telemetry, advanced meteorology, flight planning/site survey, the operating environment, and/or maintenance.
Stakeholder opinions varied with respect to the threshold at which machine-specific training for each RPA should be required: with some indicating the threshold should be based on the RPAS machine type, system complexity level, and overall risk level, while others suggesting it should be mission specific. Some indicated they felt that machine-specific training should be required for all RPA in BVLOS operations; however, others felt that it was more important for those specifically operating in Category C. Generally though, people felt that it might be helpful to use broad basic categories given the breadth of types and manufacturers. Pilots could then conduct flight reviews under each category to add to their certificates.
OVERALL FEEDBACK AND NEXT STEPS:
Drone Talks: Planning for Success was received very positively. Stakeholders indicated they appreciated being consulted and the opportunity to share their insights. They indicated they were generally pleased with what they had heard over the two days – both in terms of the work underway and the direction being taken by TC. However, all parties acknowledged that while much progress was being made, there were still considerable challenges that need to be addressed which impact upon the efficiency of operations and future growth. To this end, there was a commitment to continued dialogue and to raising and tackling key issues with industry.
TC will be using the stakeholder feedback to guide work in a number of areas. This includes future regulatory work in the BVLOS sphere, establishment of a RTM framework, adaptation of airworthiness and certification processes, pilot certification and training requirements, and creating a whole-of-government strategy for RPAS. As the work progresses, TC commits to further engaging with industry. To this end, TC intends to establish – in the next year – a RPAS advisory committee, which would serve as a dedicated forum to tackle key issues and challenges facing the sector. Separate from the advisory committee, TC will also look to establish a Canadian Aviation Regulation Advisory Council (CARAC) working group for the lower-risk BVLOS regulations.
APPENDIX A: Participant Breakdown
- A total of approximately 125 stakeholders attended Drone Talks: Planning for Success, with them indicating expertise in the following sectors:
- Across the four workshops, stakeholder attendance was as follows: