USC-STC Submission on AC922 – RPAS Safety Assurance

TL:DR

Transport Canada (TC) Released Advisory Circular 922 on RPAS Safety Assurance to outline RPA requirements for Advanced Operations.

USC-STC met with TC to better understand the AC, and has prepared a white paper on suggestions for changes and improvements. You can get a copy at the bottom of this post.

AC922 Submission

Transport Canada recently released an Advisory Circular to provide guidance on the implementation of Standard 922. The Standard outlines the Safety Assurance (“SAFE”) RPAS equipment requirements for Advanced Operations in Controlled Airspace, Near People (> 5m) and Over People for Canadian RPAS operations.

You can get a copy of the Advisory Circular 922 here

USC-STC’s Regulatory Committee (RC) is tasked to work with Transport Canada, soliciting Industry input and providing feedback in the aggregate from the Unmanned Industry to TC.

In January, members of the RC attended a session with TC to better understand the Standard and get a full briefing on the AC contents.

Once the AC922 was released, we helped to distribute it to the Unmanned Community via the post above.

Our Regulatory committee has revieved the AC, commissioned a poll to better understand the impact to the Unmanned Sector of the SAFE requirements. The Committee then prepared and submitted a white paper to TC summarizing our findings, comments and suggestions.

In the white paper, we offered a number of suggestions on how to make the AC and the SAFE Regulations work better. Among the recommendations:

  • Provide clearly defined requirements for each of the SAFE declarations and move supporting documentation to Appendices.
  • Consider one time, up to 12 month, exemptions for operations in Controlled Airspace for National and Complex SFOC holders; The intent is to provide the time to acquire new RPAs and update their systems, training and procedures.
  • Consider a NavCan procedure to cover Controlled Airspace versus having a RPA equipment declaration.

You can read our submission here.

As always, comments and feedback are welcome.

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