What Canada’s new drone regulations mean for you

What Canada’s new drone regulations mean for you

By Kate Klassen, Training and Regulatory Specialist

 

It’s not every day I get excited to see an email before 0600. But yesterday, March 26, was one of those days! 

Unexpectedly, Transport Canada announced the publication of the highly anticipated Canada Gazette II which included new regulations for RPAS Operations Beyond Visual Line-of-Sight and Other Operations.  

It’s a hefty publication with lots of cross-references and makes for a bit of a dense read. But after a day of reading, re-reading, digesting and consulting with other colleagues who share my nerdiness about this area, I’m pleased to provide this overview – which we’ll continue to update as new information becomes available.  

All-in-all, it’s what we were expecting and hoping to see: Common-sense amendments to existing regulations, noticeable inclusions from feedback on the Canada Gazette I draft, and formalization of the next phase of routine RPAS operations in Canada.  

If you were one of the many who took the time to provide comments to Transport Canada following CG1, well done. What we saw today is proof they listen and that those efforts matter. Thank you, TC! 

Some regulations come into effect on April 1 2025, with others commencing November 4, 2025. This phased approach enables the mechanisms for compliance to be in place prior to requiring compliance with them. In other words, it gives you time to get prepared before it’s required by law. So don’t panic. There are no major changes required before this flying season. You can’t even fly BVLOS under these rules until November.

Now, let’s dive in. 

Below: Low-risk BVLOS flights will be permitted starting November 4, 2025. These operations will require a new Level 1 Complex RPAS Certificate

 

PRACTICALLY SPEAKING

 

As mentioned, the document published yesterday is complex. Our goal here is explain what it actually means in the real world. So we’re going to break this down into implications for different scenarios. Here’s what the new rules mean for RPAS pilots with: 

 

…a sub-250 gram drone
  • On April 1, there are more regulations than just the CAR 900.06 ‘don’t be an idiot’ rule that come into force. These specifically spell out steps to follow if you inadvertently enter restricted airspace (CAR 900.07) and include prohibitions around emergency security perimeters (CAR 900.08) 
…a Basic RPAS Certificate
  • Not many changes aside from general tidying of rules to ensure intent aligns with application 
  • You can allow a non-certified individual to fly under your supervision (CAR 901.54) 
  • You are qualified as a visual observer for BVLOS operations 
…an Advanced RPAS Certificate
  • You get new capabilities as of November 4th – and you don’t have to do any additional testing to take advantage of them! 
  • You’ll be able to carry out EVLOS – Extended Visual Line Of Sight operations. This allows you to fly up to 2NM from the pilot, control station and Visual Observer at any time during the flight, provided the pilot and control station are at the take-off and launch location (CAR 901.74) 
  • Sheltered Operation – This allows the drone to be flown around a building or structure without the use of a visual observer, in accordance with certain conditions  
  • Medium Drones: You’ll be permitted to fly drones with an operating weight of up to 150kg  
  • With an Advanced Certificate already in hand, you meet the prerequisite to begin your Level 1 Complex ground school (more in a moment). If you’ve passed the Advanced Certificate but only hold your Basic because you haven’t yet done your Flight Review, you can pursue the Level 1 Complex
5G Drones

AND ROUTINE, LOW-RISK BVLOS?

 

This was an area the industry had really been pushing for in the new regulations. Specifically, to be able to carry out such flights without the need for a Special Flight Operations Certificate. Here, too, there’s good news:

  • After November 4 2025, you’ll be able to fly low-risk BVLOS if you hold a Level 1 Complex RPAS pilot certification (CAR 901.89). This means BVLOS in uncontrolled airspace and away from people
  • Permits the operation of a 250g – 150kg RPAS to conduct a BVLOS operation in uncontrolled airspace and one kilometre or more from a populated area 
  • In addition to holding a Level 1 Complex pilot certificate, you also need to be an RPAS Operator (RPOC) or an employee/agent of one and comply with the conditions of your certificate (CAR 901.88) 

    

INTERESTING NUGGETS: 

 

  • RPAS Operating Certificate uses the acronym RPOC rather than ROC (as was drafted previously). This is likely in response to anticipated confusion with the ROC-A or Radio Operator Certificate with Aeronautical qualification issued by ISED
  • The new regs contain detailed guidance for visual observers and their requirements in various scenarios
  • You can’t “daisy chain” Visual Observers for EVLOS over greater distances. The pilot/control station needs to be at the take-off and landing area and the RPA can’t go further than 2 NM from the pilot, control station AND VO. 
  • Despite previous suggestions, there is no medical requirement! Just fit-to-fly rules like previously

 

There are also some changes to SFOC requirements. Police operations at events won’t require an SFOC. Department of National Defence operations won’t require them, just adequate coordination. In addition, you’ll be able to drop lifesaving gear without an SFOC, providing you don’t create a hazard. 

Declarations, maintenance and servicing will take on a more prevalent role (not surprising, given the EVLOS, low-risk BVLOS, and the ease of restrictions on flying heavier drones). It’s also worth noting that the already-useful Drone Site Selection Tool (DSST) will get upgraded to include new situational data layers for lower-risk BVLOS. These layers will include population density, aerodromes, controlled airspace, and Detect and Avoid requirements. 

DJI Dock

KATE’S TAKE

 

Canada Gazette II is a massive document. I actually tried to do a word count and the computer simply froze in fear. But, in conjunction with all of the above, here are some final key takeaways:

  • Don’t freak out: There’s plenty of time to process and time to act. There are no major changes happening before November 4th, though you’ll probably want to get your ducks in a row before then if you anticipate your flying season extending beyond that date
  • For maybe the first time ever, regulations have outpaced technology. We still (desperately) need technical detect solutions that are reliable, capable and affordable
  • We’ve had a few folks reach out about ground school for Level 1 Complex and yes – we absolutely will be offering this. At FLYY, we have things well underway as we were anticipating this announcement.

Unlike previous ground schools, there are some instructor requirements that need to be in place before we can even make the declaration to TC that we’re offering TP15530 compliant training. We’re on top of it!

We plan to start offering live, TC-compliant courses prior to the end of April. Over a series of weeks, these courses will run every Wednesday at 0930 PDT for 2.5 hours. These sessions will be recorded and made available to all course participants to review or watch at their leisure. We’ll keep you posted as we get closer to launch.

You can take advantage of our presale here to make sure you’re first in line.

Get ready: New RPAS regulations are coming in Canada

Get ready: New RPAS regulations are coming in Canada

By Scott Simmie

 

New Transport Canada RPAS regulations are coming. Precisely how soon is a question of some debate, particularly since the country just swapped Prime Ministers and is in the midst of a pretty unpleasant trade dispute with its largest trading partner.

Nonetheless, the work of government marches on. And in the near future we can expect Canada Gazette 2 to announce significant forthcoming changes to RPAS regulations which will be phased in likely by the fall of 2025.

That means this summer’s flying season, in some respects, will be business as usual. Beyond Visual Line of Sight flights will still require a Special Flight Operations Certificate through Transport Canada. But once the regulations come into force, low-risk BVLOS over sparsely populated areas will no longer require an SFOC, providing the pilot, organization and drone (up to 150 kg) all meet new requirements.

This will open up the door for the industry to carry out long-range BVLOS data acquisition and deliveries in low-risk scenarios without all the paperwork. But there will be some additional barriers to ensure these missions – and the pilots and organizations carrying them out – meet new TC requirements.

With the help of InDro’s Training and Regulatory Specialist Kate Klassen – who’s also a traditional aircraft instructor with multiple ratings – we’ll recap what’s coming, along with how to start preparing for the transition.

 A BALANCING ACT

 

Transport Canada, as regulator, has a delicate task: It needs to ensure airspace safety as much as possible while also allowing the industry to advance and grow economically. That’s what led to the first set of RPAS rules – Part IX of the Canadian Aviation Regulations (CARs) – announced in 2019. Those rules included the requirements for Basic or Advanced RPAS Certificates to operate drones weighing between 250 grams and 25 kilograms. It also laid out the regulations for where VLOS flight could (and couldn’t) take place and made it clear what type of missions would require an SFOC. Prior to Part IX of CARs, every commercial drone flight – including VLOS flight – required an SFOC. So that was a big step forward.

As the industry and its requirements continued to grow, TC started planning for the future. In mid-2023, this issue of Canada Gazette outlined proposed amendments that would ease the path to broader use-cases of drones while adding additional requirements on the safety and planning side of things. It’s a lengthy document, but its broad goals are boiled down to a single paragraph:

“This regulatory proposal would allow operations with a remotely piloted aircraft (RPA) up to 150 kg to be flown within visual line-of-sight and introduce rules for routine beyond visual line-of-sight operations with an RPA up to 150 kg over sparsely populated areas, at low altitudes, and in uncontrolled airspace. The proposal would remove the requirement for a Special Flight Operations Certificate (SFOC) for these operations…”

So the amendments will – in far greater detail – cover two new categories of operation: VLOS operation of drones weighing above 25kg and up to 150 kg (in both controlled and uncontrolled airspace) and BVLOS flights that meet low-risk criteria.

And the flip side of the coin? The paragraph continues: “The amendments include proposed requirements for a new pilot certification, new technical standards for the aircraft and supporting systems, new operational procedures, such as increased distances from airports, heliports, and people, as well as new requirements for individuals and organizations to operate BVLOS…”

It will be a significant step forward for operators, as part of TC’s measured approach to balancing safety and growth.

“This isn’t going to be the set of regulations that opens Canada up to delivering your pizza by drone,” explains Klassen. “But it will allow routine, low-risk BVLOS flights without the need for an SFOC. Detailed planning will still be required, but long-range data acquisition and deliveries in low-risk scenarios will become a lot more common.”

As noted, however, this isn’t a free pass.

“Operators wanting to carry out those low-risk BVLOS missions will need to demonstrate they have the knowledge and skills to do so. Pilots will need to obtain a new Level 1 Complex Pilot Certificate. And while it still covers the same eight knowledge areas as an Advanced RPAS Certificate, it’s to a whole new depth.” says Klassen.

Those with an existing or new Advanced Certificate will be able to carry out:

  • VLOS operations with a medium-sized drone (above 25 kg up to and including 150 kg);
  • Extended VLOS operations (EVLOS), using a visual observer; and
  • Sheltered operations, which would allow the drone to be flown around an obstruction (e.g. a building) without the use of a visual observer.

“You can temporarily put the drone out of your line of sight,” explains Klassen. “Say, fly behind a building or descend below the tree line if you’re comfortable with the safety and managing the risk of those scenarios. A cool example might be firefighters that need to duck the drone behind a plume of smoke so they don’t have to go the long way around.”

 

WHAT CONSTITUTES LOW-RISK BVLOS?

 

This is an important question – particularly when it comes to operating drones up to 150 kg. You wouldn’t want these flying in places that could put people, or traditional air traffic, at undue risk.

The proposed regulations (and we still have to wait to see the final language) indicate that TC will require operators to ensure their missions meet acceptable risk management criteria under SORA, an international guideline which stands for Specific Operations Risk Assessment. This combines calculating the ground risk (people, property, infrastructure) of a specific planned mission (where BVLOS obviously carries a higher risk than VLOS) as well as the air risk – the probability of encountering crewed aircraft in the airspace. The latter is calculated based on the density of traditional aircraft in the proposed operational airspace (higher density equals greater risk), plus any mitigating factors such as detect and avoid systems, robust operating procedures, etc..

The final language isn’t out yet, but the paragraph cited earlier contains the high points. Low-risk BVLOS flights that take place over sparsely populated areas in uncontrolled airspace and at altitudes not exceeding 400′ AGL will not require an SFOC.

There is, obviously, a big difference between VLOS and BVLOS, particularly when we’re talking about larger drones. BVLOS missions will involve more complex planning akin to traditional aviation. If it’s a long-range mission, what’s the anticipated weather on the route 100 km away in two hours? Pilots with their Level 1 Complex Certificate will need to take into account multiple risk factors that don’t generally apply to VLOS flight.

“The knowledge requirements will be a step above Advanced, for sure,” says Klassen. “You’ll be expected to to know about antennas and variables that can impact your C2 link reception, and how to apply that knowledge operationally. You’ll have to be able to look at a proposed route and understand how the environment and terrain features are going to impact your reception range – and even whether or not the proposed mission is even possible.

“We can also expect a lot more as well on crew communications and operating procedures for if things don’t go as planned.”

Below: These graphics, pulled together by Kate Klassen and InDro, cover key aspects of the anticipated new RPAS regulations

new RPAS regs
RPAS regs

WAIT, THERE’S MORE

 

The new Level 1 Complex Certificate comes with a mandatory ground school requirement (you won’t be able to write the online exam without it), as well as a medical sign-off from your doctor to ensure you don’t have any untreated condition that could impact the safety of operations. That declaration from the doctor will be need to be presented at the more extensive in-person Flight Review the new certification will require. TC is also aligning the rules for company ownership to more closely align with existing regs for traditional aviation. These will be more favourable to Canadian citizens and companies with at least 75 per cent Canadian ownership.

Oh, the regs will also permit Extended Visual Line of Sight (EVLOS) flights with additional visual observers, and also allow for brief BVLOS flight if necessary within missions that might have been planned as VLOS only.

There will be much more, including the need for organizations to have an Accountable Executive responsible as the point person for overall ops – what Klassen jokingly refers to as the “one throat to choke” if things go wrong.

The fine print of the final regs, as noted, is yet to be released. But it will be a significant advance for the industry – coming with additional responsibilities and knowledge requirements for those involved. InDro will be ready, with updated courses on its FLYY online drone instruction portal run by Klassen. In fact, there’s already a free prep quiz for the new regs here.

Stay tuned.

 

 

InDro’s Kate Klassen: Aircraft instructor, regs expert – and Canada’s most famous drone instructor

InDro’s Kate Klassen: Aircraft instructor, regs expert – and Canada’s most famous drone instructor

By Scott Simmie

 

From time to time, we like to profile InDro employees. In these pieces, we try to not only highlight their skill sets but also give you a sense of the person. So we’re particularly pleased to be writing about Kate Klassen – who is both a total pro and a stellar human being.

Klassen has been in the drone space pretty much since it started to become a thing in Canada, though she was going by her maiden name – Kienapple – in those early days. She’s widely acknowledged as a regulatory expert, has trained more than 10,000 RPAS pilots online and in person, and is also a traditional aviation flight instructor with multi-engine and IFR ratings. Oh, and she’ll hit carrying out 200 in-person RPAS Flight Reviews before long.

Of course, she didn’t just start there. She worked for it.

Below: Happy Kate (which is pretty much the norm)

 

THE BACK STORY

 

Kate didn’t initially plan on a career in the world of aerospace. Growing up in a small Nova Scotia town, she and brother Alexander would often see jets flying to and from Halifax Stanfield International Airport. Her father was a university professor; her mother an accomplished audiologist and COO/Vice-President of a prominent audiology firm she founded. The family traveled frequently, so even as a child Kate grew up being familiar with flying – at least from the passenger perspective. She also had two very successful parents as role models.

But aviation was not on her young radar as a career path. She planned, as a child, to pursue a career in audiology and join her mother’s business. That changed, abruptly and tragically, when Jean Ann Kienapple passed away suddenly in 2001. Kate was just 11. It’s an event that is still difficult, nearly 24 years later, for her to discuss.

Life would push on, and so would Kate. But, on graduating high school, she was still a bit adrift when it came to a career.

“Because my dad was working at a university when I graduated, it wasn’t: ‘Are you going to post-secondary?’ It was ‘Where are you going?'”

She wasn’t really sure. The only thing that truly appealed was to one day go to space.

“And my Dad said: ‘Most astronauts are pilots first. Why don’t you start there?'”

Kate had once been up in a small plane with a family friend. She spoke with him, and others, and learned there was a program at the University of New Brunswick that combined a business degree with aviation. Kate (short for Katelin) signed up.

“So it ticked that box for post-secondary for my dad,” she recalls.

 

 

KATE TAKES FLIGHT

 

It was a unique program, combining becoming a pilot with business chops. Kate dove in, moreso on the aviation side than the business end of things. She loved flying – and it was counting toward her degree.

“Instead of doing regular electives, you did flying hours,” she says. “So your hours in the plane and in ground school counted towards your degree.”

It was a four-year program, but Kate wanted to maximise her flying time during summers – so she completed it in three. In addition to her degree, she graduated with a Commercial Multi-Engine IFR rating and 200 hours of flight time. But the end of school was the beginning of the next phase – trying to find work.

“Guess who couldn’t get a job anywhere? Because no one wants to hire you when you have 200 hours of flying. It was either go up north and throw bags for a bit or become a flight instructor,” she says.

After some encouragement from her friends, Kate opted for the latter, packing her suitcase and heading to the west coast. She moved into her aunt’s loft in West Van and made the one-hour daily commute to Pitt Meadows airport (YPK) where she worked on getting her Flight Instructor rating. Living in Vancouver meant Kate picked up whatever work she could find to make ends meet. She did airport maintenance, including cleaning the lights on the runway and mowing the lawn. She taught yoga. She worked at Golf Town, “Even though I’ve never golfed a game in my life.”

Whatever it took, she did it.

Below: Kate Kienapple gets soaked – part of a tradition after completing a successful first solo. Second image: Kate in the cockpit with Chief Flight Instructor, and now friend, Alex Denham over Vancouver (just zoom in!)

 

 

Kate Klassen
Kate Klassen Flight Training

KATE SLIDES TO DRONES

 

Many people in traditional aviation have made the transition to the RPAS world. Kate was one of the first, but there wasn’t exactly a flight plan for this destination. While working as a flight instructor in 2014, she wound up teaching a couple of guys who had started a drone company late the previous year. Around that time, Transport Canada had just released its first iteration of knowledge requirements – which aligned somewhat with requirements for private pilots. That drone company (Aerobotika), tapped on Kate to create its ground school course.

“And then they said: ‘Since you helped us build the ground school, do you want to help us teach it?'”

She did. And it quickly turned into a frequent gig, with Kate travelling across Canada to offer ground school courses on behalf of Aerobotika twice every month. Those ground school courses required full-on brainpower for both students and instructors, and the air travel and hotel life didn’t help. It was especially gruelling since Kate had also gone back to school to pursue a Management of Technology MBA at the Beedie School of Business at Simon Fraser University.

“That got really exhausting when I was trying to also do an MBA. It turns out I hadn’t paid much attention doing my earlier business degree because I was just so determined to be an airline pilot that I was like: ‘I’ll never use this marketing class,'” she says with a smile.

In the midst of all this, Kate (being Kate) took on more. She left Aerobotika and signed on with a new drone company that she pivoted from being strictly a service provider, to an online platform for courses she developed.  She was a natural, throwing in just enough humour and personality to keep students watching and learning. With some fortunate timing of things coming online just prior to the 2019 drone certification regulations, it was a highly successful course, with thousands of students obtaining their Basic or Advanced RPAS Certificates.

But that wasn’t all. In 2018 (and while doing that MBA), Kate signed on with what was then Unmanned Systems Canada (now the Aerial Evolution Association of Canada) as a board member. She became a regular at its annual conference and trade exhibit, often presenting on the latest regulations or holding recency sessions for those RPAS pilots who want to remain current. She also developed a reputation as someone truly devoted to helping others in this sector, especially when trying to understand the implications of the latest regulations.

That’s probably why her peers on the Canada Drone Advisory Committee, or CanaDAC, elected her to be Industry Co-Chair, working directly with Transport Canada’s Ryan Coates and Jeannie Stewart-Smith in a key role bridging the gap between the industry and regulators.

 

INDRO AND FLYY

 

When it came time for InDro to seek a Training and Regulatory Specialist, it’s easy to see why Founder and CEO Philip Reece tapped on Kate’s shoulder. Her reputation in the RPAS world in Canada was already – sorry, Kate, but it’s true – legendary. .

And of course, her tremendous skills as an instructor and entrepreneur have also been put to use. Kate runs FLYY, Canada’s most comprehensive online drone instruction and resource portal. In addition to courses for Basic and Advanced RPAS Certificates (including practice quizzes), Kate has expanded FLYY’s offerings with the Compass Series. It’s a collection of separate or bundled courses that take pilots well beyond TC requirements. Topics in the series include LiDAR, Photogrammetry, Forestry, Advanced Air Mobility – even instruction on how to expand an existing drone business. Kate has pulled in top experts to instruct each of these specialties – including our own Head of Flight Operations Dr. Eric Saczuk (Photogrammetry).

As a result of all this hard work – including at the two previous drone companies – Kate has the unique distinction of having instructed more than 10,000 (and counting!) RPAS pilots in Canada and abroad.

But while she loves all things aviation-related, Kate has her priorities. She’s a mother first, to two young daughters (currently aged two and four). Her husband, Travis, is a commercial airline pilot who – not surprisingly – travels often. The four like to get outdoors when they can, camping and hiking. Kate is an avid reader, so don’t be surprised if she asks you for a book recommendation.

Kate Arctic Air

INDRO’S TAKE

 

Fun fact: That last image above was taken on the set of a CBC Television drama series called “Arctic Air.” Kate had the privilege of being a highly skilled extra – taxiing the aircraft in the photo.

“My three seconds of fame!” she laughs. “Spent all day in a blonde wig so I could taxi that plane forward 15 feet and shut it down.” 

Kate has moved something a lot larger forward during her years with InDro: The company itself. Whether it’s with FLYY, her constant input on regulatory issues and complex missions or her business acumen, she has elevated the company – and the industry. In 2023, her contributions were acknowledged with the Aerial Evolution Association of Canada’s Ellevatus award “for her outstanding dedication in uplifting, empowering, and inspiring women in the Canadian RPAS sector.” It was absolutely well-deserved.

“Kate is exceptional in so many ways – as an aviator, a mentor, and a visionary thinker who truly gets the big picture of industry, regulations, and the coming world of Advanced Air Mobility,” says InDro Founder and CEO Philip Reece. “She’s a keeper, and InDro is far better for her contributions.”

If you’d like to send Kate a book recommendation, or – better yet – inquire about group discounts on FLYY, you can reach her here.

New TC Advisory Circular contains guidance for night BVLOS flight – and much more

New TC Advisory Circular contains guidance for night BVLOS flight – and much more

By Scott Simmie

 

A new Advisory Circular from Transport Canada is generating a lot of buzz in Canada’s RPAS world.

Although an Advisory Circular is not legislation, they offer guidance and a glimpse of what the regulator is planning for the future.

“Advisory circulars are one of the methods that Transport Canada can use to provide guidance on complying with regulations,” explains Kate Klassen, Training and Regulatory Specialist at InDro Robotics. Klassen is an instructor and pilot of traditional aircraft as well as drones. Her online courses have trained more than 10,000 RPAS pilots in Canada. She has also served as Co-Chair of the Canadian Drone Advisory Committee, or CanaDAC.

“It kind of acts like a preview, foreshadowing in a way the regulations we know are coming later this fall. This one in particular is exciting because of the depth of guidance that they’ve provided,” she says.

Here’s how Transport Canada describes the purpose of the Advisory Circular – entitled Remotely Piloted Aircraft Systems Operational Risk Assessment – in its introduction:

“This Advisory Circular (AC) is provided for information and guidance purposes. It describes an example of an acceptable means, but not the only means, of demonstrating compliance with regulations and standards. This AC on its own does not change, create, amend or permit deviations from regulatory requirements, nor does it establish minimum standards.

“This AC provides information and guidance to manufacturers and operators intending to develop or operate a Remotely Piloted Aircraft System (RPAS) for operations in accordance with the requirements of Part IX, Subpart 3 of the Canadian Aviation Regulations (CARs).”

The document itself is 131 pages, and a lot of it is dense and laden with acronyms. But for operators planning complex operations down the road – including the potential of flying BVLOS at night – the highly detailed guidance offered in the document is a gold mine. It goes into extraordinarily fine detail about carrying out Risk Assessment in a variety of scenarios.

Below: Screengrab from InDro research into urban wind tunnels being carried out for the National Research Council. This was a highly complex operation involving a heavier drone in a dense urban setting and required a Special Flight Operations Certificate. The new Advisory Circular helps spell out precisely what TC is looking for from operators to ensure safe operations in multiple scenarios

 

 

NRC Urban Wind Tunnel Eric

RISK ASSESSMENT AND SFOCs

 

Back in the early days of drones, pretty much every flight required special permission – an SFOC – from Transport Canada. As drone technology and reliability/robustness improved and the regulator collaborated with the industry, detailed regulations for RPAS were first issued in 2019.

That change meant what we could generally term as routine, low-risk flights with drones weighing up to 25 kilograms could be carried out without an SFOC, providing the operator met all criteria laid out in the Canadian Aviation Regulations, Part IX. That included requirements that the operator have a Basic or Advanced RPAS Certificate to operate small RPAS. TC also established its drone portal, where compliant drones weighing more than 250 grams are registered and assigned a number by the regulator. All of this was, in general, very good news for the RPAS industry.

But for those more complicated operations – generally meaning operations with greater risk – an SFOC was still required to satisfy Transport Canada that the operation could be carried out safely. Specifically, as the AC points out, SFOCs were (and are) still required in these circumstances:

“No person shall conduct any of the following operations using a remotely piloted aircraft system that includes a remotely piloted aircraft having a maximum take-off weight of 250 g (0.55 pounds) or more unless the person complies with the provisions of a special flight operations certificate — RPAS issued by the Minister under section 903.03:

(a)  the operation of a system that includes a remotely piloted aircraft having a maximum take-off weight of more than 25 kg (55 pounds);

(b)  the operation of a system beyond visual line-of sight, as referred to in subsection 901.11(2);

(c)  the operation of a system by a foreign operator or pilot who has been authorized to operate remotely piloted aircraft systems by the foreign state;

(d)  the operation of a remotely piloted aircraft at an altitude greater than those referred to in subsection 901.25(1), unless the operation at a greater altitude is authorized under subsection 901.71(2);

(e)  the operation of more than five remotely piloted aircraft at a time from a single control station, as referred to in subsection 901.40(2);

(f)  the operation of a system at a special aviation event or at an advertised event, as referred to in section 901.41;

(g)  the operation of a system when the aircraft is transporting any of the payloads referred to in subsection 901.43(1);

(h)  the operation of a remotely piloted aircraft within three nautical miles of an aerodrome operated under the authority of the Minister of National Defence, as referred to in subsection 901.47(3); and

(i)  any other operation of a system for which the Minister determines that a special flight operations certificate — RPAS is necessary to ensure aviation safety or the safety of any person.”

“In order to be issued an SFOC – RPAS, an operator must submit an application to the Minister as detailed in CAR 903.02. In particular, CAR 903.02 (p) indicates that in addition to the specific information required by 903.02 (a) through (o), the operator must submit “any other information requested by the Minister pertinent to the safe conduct of the operation”. For certain complex operations, as determined during the application process, an Operational Risk Assessment (ORA), acceptable to the Minister, is one of the items of ‘other information’ required in support of an application for an SFOC – RPAS.”

It’s that last paragraph that’s particularly relevant to this Advisory Circular.

 

COMPLEX PROCESS

 

The issue, as many operators discovered, was that applying for an SFOC wasn’t a slam-dunk. It’s not uncommon for TC to come back – sometimes more than once – asking for more details or requesting additional steps or precautions. This slowed the approval process, which was frustrating for operators. Some conveyed to regulators that there wasn’t enough clear guidance to ensure operators were meeting TC’s detailed expectations.

“So it made the SFOC application process for those more complex operations challenging as both parties were trying to sort out what the requirements needed to be to keep things safe,” explains Klassen.

The new Advisory Circular spells out, in detail, precisely what Transport Canada is looking for from operators. It contains multiple protocols, including the fine details of carrying out standardized risk assessments, that will be of benefit to all operators – even in cases where an SFOC is not required. Klassen believes the new document is the direct result of discussions between operators and TC. In addition to making complex operations safer, it provides all the fine print to assist operators in getting everything right the first time with SFOC applications.

“This Advisory Circular, I think, is a result of all of the back-and-forths between those RPAS operators who have been pursuing the boundary-pushing applications, and Transport Canada. TC has been able to accumulate all of that guidance in one location so that the process is streamlined.”

We’ll hit on a few highlights – including BVLOS at night – but the document is so thorough and dense that we’ll link so that operators can download and study it themselves. The Advisory Circular is so detailed that it’s not easy to synopsise, as you’ll gather from the following table of contents. (Don’t worry if some of the acronyms are unfamiliar; there’s an extensive glossary):

TC Advisory Circular
TC Advisory Circular
TC Advisory Circular

WHAT’S NEW

 

This is actually a revision to a previously published Advisory Circular. Because it contains so much information, TC thoughtfully provided a round-up of what’s new – and there’s quite a bit that is.

It contains the following changes to definitions:

  1. Airport / Heliport Environment was renamed Aerodrome Environment and a 3000 ft (915 m) AGL maximum altitude provision was added.
  2. (ii)  The Atypical Airspace infrastructure masking provision was clarified, and a low altitude night provision was added. (We’ve bolded this because it’s kind of a big deal, and we’ll get to it.)
  3. (iii)  Operating Weight definition was added to support changes to ground risk assessment.

In addition, ground risk assessment now relies on the weight of the drone rather than a kinetic energy calculation. Thresholds are now based on the most recently available population density numbers, rather than just a description of the area.

All ground risk scores now assume BVLOS operations; if you are carrying out a VLOS operation that is included as a mitigating factor.

There’s more, of course. But the most attention-grabbing line from above is the provision for low-altitude BVLOS at night. This will obviously require a risk assessment and SFOC, but it’s expected this will be included in legislation anticipated this fall (Canada Gazette 2). And that opens a lot of doors for operators.

“You could fly BVLOS along power lines, transmission lines because there’s not going to be an aircraft within 100 feet vertically of that. You could also carry out deliveries at night, pending airspace,” says Klassen.

It’s also worth noting that Transport Canada had previously indicated that routine, low-risk BVLOS flights will be permitted in the forthcoming regulatory amendments. An additional level of Transport Canada pilot certification will be required for such flights.

Below: With a satisfactory risk assessment and an SFOC, drones like this might be flying BVLOS missions at night when updated regulations are released sometime in the fall of 2024

 

HIGHLIGHTS

 

When Kate Klassen went through the AC, she was impressed with the extraordinary level of detail. Every step of risk assessment and mitigation is thoroughly described, with examples in the appendices.

Many operators will be familiar with risk assessment tools. But there will also be many, particularly those who currently carry out very basic, non-complex operations, who might know the acronyms but little beyond them. This is very much a “how-to” document.

An Operational Risk Assessment (ORA) is a very methodical process – once you know the method. And here, TC outlines the specific steps laid out by the JARUS (Joint Authorities for Rulemaking on Unmanned Systems) SORA (Specific Operations Risk Assessment) process. (There are some minor tweaks here, which are explained, to optimize this for the Canadian environment.)

The AC walks you through every step of the process, and includes graphics. The document takes a much deeper dive than this overview, with each phase of risk assessment explored in detail. This, however, gives you a glimpse:

TC Advisory Circular JARUS SORA

OPERATIONAL VOLUME

 

The document also defines something critical for any risk assessment – what it calls the “Operational Volume.” This involves calculating boundaries beyond the planned flight operations for safety/mitigation/contingency purposes.

Here’s how the Circular defines it:

TC Advisory Circular Operational Volume

“ATYPICAL AIRSPACE”

 

One of the things that caught Klassen’s keen eye was the definition of Atypical Airspace. Here’s the wording from the Advisory Circular:

  1. (i)  Restricted Airspace, with authorization from the person specified in the Designated Airspace Handbook TP1820 or in a NOTAM.
  2. (ii)  Northern Domestic Airspace as defined in the Designated Airspace Handbook, outside an Aerodrome Environment, at a maximum altitude of 400 ft (122 m) AGL.
  3. (iii)  Within 100 feet (30 m) above and within 200 feet (61 m) horizontally from any building or structure which stands out vertically beyond the adjacent surface of surrounding terrain with sufficient size and shape to be noticeable to the pilot of a traditional aircraft in flight.
  4. (iv)  Within the hours of legal night, in uncontrolled airspace outside of an Aerodrome Environment, at a maximum altitude of 400 ft (122 m) AGL.

Why is this extension to the definition of Atypical Airspace (AA) exciting? When an operation takes place in AA, the Air Risk Class is automatically assigned as “a” (ARC-a). This lowers the relative SAIL, depending on your Ground Risk Class, and therefore the requirements to meet the operational safety objectives are simpler. It will give you a much easier time applying for and obtaining your SFOC due in major part to the Detect and Avoid options available to you to use.

Below: With adequate lighting (and more safety precautions), operating at night provides some interesting BVLOS opportunities!

 

INDRO’S TAKE

 

Transport Canada’s new Advisory Circular is an important, detailed, and well thought-out document. Yet again, TC is attempting to make things easier for professional operators while striking that critical balance of safety – both in the air and on the ground.

“The past decade has seen both tremendous advances in the reliability and safety of drones, and – after some initial resistance in the early days – tremendous willingness on the part of Transport Canada to safely open up new opportunities for the industry at large,” says InDro Robotics CEO Philip Reece.

“The level of detail in the Advisory’s extensive sections on Risk Assessment will be of great benefit to operators – and to the safe expansion of the industry into other use-cases, including BVLOS flights at night. We commend those at Transport Canada for both the vision and thought put into this document, and look forward to the new regulatory changes.”

You can download the Advisory Circular here.

FLYY releases “how to” guide for building, expanding a drone program

FLYY releases “how to” guide for building, expanding a drone program

By Scott Simmie

 

Thinking of starting a drone program? Perhaps you have one already, and are thinking of expanding. Or maybe your existing program grew organically on an ad-hoc basis and you’d like to ensure you’re following Best Practices.

There’s a solution for that.

Kate Klassen, InDro’s Training and Regulatory Specialist (who’s also a flight instructor for crewed aircraft),  has written a comprehensive manual specifically for this purpose.

Klassen is widely respected in Canadian RPAS and traditional aviation circles. In addition to her extensive experience as a pilot (multi-engine rating, IFR, night), she was an early adopter in the drone world. Her regulatory expertise is top-notch, and her online RPAS instruction courses have trained more than 10,000 pilots in Canada (you can find her current courses here). She’s been on the board of the Aerial Evolution Association of Canada for years, and was co-chair of Transport Canada’s CanaDAC Drone Advisory Committee. So she knows her stuff.

Now, she’s pulled together that knowledge (in addition to what she’s learned working with InDro Robotics and consulting with other companies with RPAS programs) into a single, comprehensive document that covers everything you need to know to build out a safe, compliant, cost-effective drone program.

“The goal with the book was to put in one spot all of the information that you should know,” she says.

She certainly achieved that.

Below: Kate Klassen, in one of her many elements.

 

Drone Training

SOLID KNOWLEDGE BASE

 

The e-book is entitled Remotely Piloted Aircraft Program Development Guide for VLOS and BVLOS Operations. And it covers pretty much every aspect of running a drone program – including maintenance, staffing, recency, risk assessment – and much more (we’ll give you a peek at the table of contents shortly).

There’s also, of course, a meaty section on the regulations – including the anticipated Transport Canada changes on the horizon that will permit routine, low-risk Beyond Visual Line of Sight flights (which will require obtaining an additional TC RPAS Certificate). And while the book covers high-level operations suitable for companies with mature drone programs, it also covers the basic meat and potatoes.

“This book could be used by individuals looking to use their drone in a professional capacity or as a really serious hobby – but it’s geared more for someone who is either starting, expanding or improving a drone program within their organisation,” says Klassen.

 

DECISIONS, DECISIONS, DECISIONS

 

A well thought-out drone program involves a lot of decisions. How do you choose your crew, including flight lead? When is it time to replace an aircraft? What’s a good maintenance schedule – and how do you track that? What’s the best way to manage data? And what about insurance?

You’ll find all that and more. Klassen has packed a lot (including links to references and resources) into the 55 pages of this manual. And she’s taken special care to pore through the finer details of dense Transport Canada regulatory language and write the key takeaways in clear, concise terms.

“There was a lot of digging through Transport Canada documents to gain insights into where the drone industry is going from a regulatory perspective – and put that into plain English,” she says.

Below: The cover page

FLYY Kate Klassen drone program manual

LOGICAL, ORGANIZED

 

Whether you’re a seasoned pro or someone just starting a drone program, Klassen has constructed the manual in a highly organised fashion. The progression of sections builds logically from the basics, through to complex areas such as Specific Operational Risk Assessment (SORA).

Here are the sections:

  1. Regulation Roadmap
  2. Certification
  3. Operational Considerations
  4. Budgeting
  5. Program Structure and Operation
  6. Training
  7. Equipment
  8. SORA Process

And within each of those sections? Let’s just say Klassen has it all covered. Take a look:

Kate Klassen Drone Program Manual
Kate Klassen Drone Program Manual
Kate Klassen Drone Program Manual

EXCERPT

 

It’s one thing to tell you this manual is clear and concise. It’s another to let you see for yourself. So we’re going to paste from the very top of Section One – Regulation Roadmap – to give you a better idea:

The Canadian Remotely Piloted Aircraft System (RPAS) industry took a major leap forward in June of 2019 with the publication of drone-specific regulation in the Canadian Aviation Regulations (CARs). These regulations enable route visual line of sight (VLOS) operations for small RPAS (250g – 25kg), with additional guidance for aircraft above that weight range, through a Special Flight Operation Certificate (SFOC) process, and below, with reduced prescriptive microdrone regulation.

With the release of a Canada Gazette draft of lower risk BVLOS regulation in the summer of 2023, we have an idea of the direction Transport Canada is heading and had an opportunity to raise concerns and encourage positive direction with the drafted version.

While formal regulation, once in place, will provide a clearer path to certification for BVLOS, there will still be many of the similar requirements to what’s currently in place, through the SFOC process, including training, mission planning, procedure development and technology.

  • NOTE: While BVLOS with a microdrone is not explicitly prohibited by the regulations, the onus would be on the operator to prove it was done without being reckless, negligent, risking or being likely to risk the safety of a person or aviation safety. (CAR 900.06) Throughout this document, the aircraft and operations we’ll be referring to are those with small RPAS, that is those between 250g and 25kgs, unless otherwise specified.
  • As it stands as of the time of publication, flying an RPA heavier than 25kgs or BVLOS is not permitted in Canada except if specifically authorized in a Special Flight Operation Certificate. (CAR 901.11) This document will address considerations for a BVLOS program in anticipation of BVLOS-specific regulation being introduced in 2025 and the structure, operational considerations, components of an SFOC and training.

This is a rapidly changing space. As the industry continues to develop new technology and applications, and new regulation is announced to accompany these advancements we’re going to see a lot of refinement to the processes described within this document. It’s what’s so exciting about working in this area! The information here should help you in that pursuit.

As you can see, it’s really clearly written. It’s also filled with helpful graphics like these:

Kate Klassen Drone Program Manual
Kate Klassen Drone Program Manual

INDRO’S TAKE

 

Kate Klassen is widely acknowledged as both a regulatory expert and a phenomenal communicator/instructor. She combines those skills well in the production of this manual, which we believe is a “must-have” for anyone serious about their drone program.

“Kate has tremendous expertise in this field – including personally overseeing some 150 RPAS flight reviews,” says InDro Robotics CEO Philip Reece. “This manual ticks all the right boxes, and includes material that will benefit even the most mature drone program. We’re pleased to see this published, and believe it will truly help those running serious programs make the most effective and efficient decisions.”

And the cost? You can download the manual here for $49.

That’s less than a dollar per page. And, in our opinion, a bargain.

Blue Books offer crucial guides for First Responder RPAS programs

Blue Books offer crucial guides for First Responder RPAS programs

By Scott Simmie

 

There are two important tools available for First Responders who use RPAS in their work.

No, they’re not drones. Instead, they are guides for developing safe and effective RPAS programs – and for carrying out low-risk BVLOS flight in the near future. These “Blue Books” are intended for fire departments, Search and Rescue organisations – and more.

These guides came about because the Canadian Association of Fire Chiefs, the Civil Air Search and Rescue Association and the Search and Rescue Volunteer Association of Canada identified a need for clear and credible reference documents. InDro Robotics received the contract to pull these books together, under the expertise of Kate Klassen and with a generous grant from the Government of Canada’s Search and Rescue New Initiatives Fund.

Kate was an early adopter in the drone world and already had a solid background in traditional aviation. She’s a flight instructor with multi-engine and Instrument Flight Rules ratings, as well as ratings for flying at night. She loves nothing more (with the exception of her two young daughters) than poring through regulations and working with bodies like Transport Canada to help safely advance the use of drones in Canadian airspace.

In other words, she was perfect for the job.

That’s Kate, in her element, below:

 

DRONES AND FIRST RESPONDERS 

These days, you’d be hard-pressed to find a First Responder organization that doesn’t have some kind of drone program. RPAS have been particularly helpful in Search and Rescue operations, including night searches using thermal sensors. Many people have been rescued quickly and safely as a result. The use of drones has also helped keep First Responders out of harm’s way. For example, it’s much safer to locate a person lost on a frozen lake with a drone and then dispatch a rescue team to precise coordinates rather than having that crew roaming around on potentially hazardous conditions.

They’re also a tremendous tool for firefighting operations. Not only do they supply immediate situational awareness that can be securely shared with decision makers down the line, but thermal sensors can also detect hot spots invisible to the naked eye. Police departments and even paramedics routinely use drones in operations. (In one example from Renfrew County, a drone was put up immediately following a tornado for damage assessment and to search for any injured people.) So drones are here to stay.

 

A REVOLUTION 

It’s not an exaggeration to say that drones have truly revolutionised the work carried out by these organizations. But it’s easy to forget that this has been a recent development.

DJI released its original Phantom drone back in 2013. At the time, it didn’t come with a camera and you had to attach a GoPro. Smart tinkerers figured out how to modify those GoPros so that the pilot could stream real-time video. Another company, Draganfly, was producing basic drones even earlier and selling them to law enforcement and other First Responders.

But drones weren’t widely known, and many of the use-cases now so common had not even yet been conceived.

A few early adopters began purchasing drones for First Responder work. It was largely trial and error, as people experimented with using drones for SAR, strategic monitoring of fires, photographing accident scenes – and more. Results started to be shared by word of mouth and at conferences. Drones were gaining traction.

Yet it wasn’t so easy to just pop up a drone in those early days. Transport Canada at the time was rightly cautious about these new devices, and pretty much any flight back then required a Special Flight Operations Certificate, even if you were flying within line of sight. Unless you managed to get a blanket SFOC, it was against the regulations to simply put a drone without that long SFOC process.

 

AN EVOLUTION

As the technology improved and the utility and safety was recognised, things began to shift. More and more First Responders started adding drones to their tool kit. And Transport Canada eventually modified (and continues to modify) its regulations to safely integrate drone operations into the national air space.

If that sounds like progress, it was. But still, there was a hitch. Organizations were creating their own ad-hoc drone operations. They were doing their best, but there was really no Best Practices guide to help inform First Responders on how to create an effective program. Yes, there was piecemeal information if you wanted to endlessly surf the internet, but there wasn’t a single repository of knowledge that could be used as a guide. What qualifications are required? What type of drone is best for the job? What scheduled maintenance is necessary and why?

And that’s how the idea for the Blue Book series came about.

Below: One of the early DJI Phantoms, with an integrated camera and gimbal system.

Canada Drone Companies

THE BLUE BOOKS

The first Blue Book was released in November of 2022 and is available for members of First Responder, Search and Rescue and Fire Departments here. Kate Klassen worked extensively with the various interested parties to ensure that the book was specifically tailored to the needs of these organizations. It quickly became the reference guide for those implementing or improving their drone operations.

“I think it prevents a lot of trial and error so that folks don’t have to learn all the lessons the hard way,” explains Klassen.

“A lot of fire departments are poorly funded, and I’m sure that goes for SAR as well. So you want to be smart with the dollars that you put towards tools like this. The guide supports making sure you’re not wasting money on poor aircraft decisions or poor personnel decisions.”

That initial Blue Book is entitled “Remotely Piloted Aircraft Program Development Guide, First Edition.” It’s a comprehensive blueprint for starting an operation from scratch, or improving an existing operation. Sections in the book include:

  • Training and certification regulations and resources
  • Airspace operations
  • Aircraft budget considerations, maintenance, payload and staffing
  • First Responder deployment

There’s much more, but you get the idea. And while it’s called the Blue Book, it’s really the gold standard of guides for First Responder operations.

 

BLUE BOOK II

The newest edition was launched last week, with Kate Klassen conducting a webinar to go over the highlights. This edition is geared toward routine, low-risk Beyond Visual Line of Sight flight. Obviously, particularly in Search and Rescue operations, being able to dispatch a drone over long distances can be critical in locating missing parties. And while Transport Canada does offer some leeway for First Responders in this regard, BVLOS is going to become more routine.

Transport Canada plans to deploy new BVLOS regulations. While SFOCs were previously required, the new rules (anticipated in 2025) will permit BVLOS flights in lower risk scenarios. Specifically, within uncontrolled airspace and outside of populated areas.

But even lower risk BVLOS is higher risk than Visual Line of Sight flights. And so Blue Book II takes a deep dive into the coming regulations. These regs include a new type of RPAS certificate required for low-risk BVLOS operations called a Level One Complex Certificate. Obtaining this certificate will require obtaining additional ground school education, as well as a more complex in-person Flight Review. Operators will have to maintain specific skillsets and recency in order to take on these BVLOS flights.

Among the contents of Blue Book II:

  • Defining BVLOS
  • Policy developments, procedures and checklists
  • Detect and Avoid, Mission Planning, Human Factors

There’s also an entire section on Specific Operational Risk Assessment (SORA), including Ground Risk Class Assessment (GRC), Air Risk Class Assessment (ARC), Tactical Mitigation Performance Requirements (TMPR) and Specific Assurance and Integrity Level (SAIL).

“This manual is a guide for preparing your RPAS program in fire or search and rescue organizations for Beyond Visual Line of Sight (BVLOS) operations,” states its introduction, co-written by CAFC President Chief Ken McMullen, SARVAC President Janelle Coultes and CASARA President Dale Krisch.

“The book is designed to be relevant to both fire departments and search and rescue (SAR) organizations, all hazard, emergency operations or fire suppression. Whether your fire department or SAR organization is expanding their use of RPAS into beyond visual line of sight (BVLOS) operations or whether it is advanced in the domain, we hope will find useful information in this manual.”

“We would like to take this opportunity to thank every member of the committee that worked on this manual and its predecessor Blue Book I which addresses the development of an RPAS program. We would also like to thank Kate Klassen at InDro Robotics who managed the process and held the pen to get the committee to their overall goal. This manual is in great part due to her substantive and process expertise.”

Although the Blue Books are specifically intended for those who are members of Search and Rescue organisations and Fire Departments, some exceptions are made for those in related First Responder fields. You can request a copy of the Blue Books at the bottom of the page here.

Below: A paramedic deploys a drone

Paramedics Use Drones

INDRO’S TAKE 

Kate Klassen has been a tremendous asset to the Canadian drone space for a decade. Her regulatory expertise and willingness to assist in shaping sound practices and policies are widely known. Her online RPAS courses have trained more than 10,000 drone pilots in Canada, and her online portal FLYY continues to help new pilots obtain their Basic and Advanced RPAS Certificates (including Flight Reviews). Kate has served as the co-chair of Transport Canada’s Drone Advisory Committee (CanaDAC), is on the board of the Aerial Evolution Association of Canada, and has previously served on the board of COPA – the Canadian Owners and Pilots Association.

“These guides were pretty labour-intensive, but I’m pleased to have worked closely with these various associations and individuals to pull together what we believe to be a Best Practices manual that truly reflects the needs of these specific organizations and use-cases,” says Klassen.

“We are also always willing to work with any company that has a drone program to produce a guide tailored specifically for their operations, ensuring consistency and safety across all operations. We are also building out specific Micro-Credential courses in areas like thermal/hyperspectral imaging, surveying, precision agriculture and more. These are highly-focused, hands-on courses that quickly bring operators up to speed on new and complex skill sets.”

In addition, InDro Robotics manages the Drone and Advanced Robot Training and Testing (DARTT) facility at Area X.O in Ottawa, which includes both classroom space and a netted drone enclosure.

If you’re interested in discussing your RPAS program needs, whether for training or a company/industry-specific manual, you can get in touch with Kate right here.