How mandatory electronic conspicuity could accelerate Canada’s drone industry

How mandatory electronic conspicuity could accelerate Canada’s drone industry

By Scott Simmie

 

New Transport Canada RPAS regulations go into effect November 4, 2025.

Among many coming changes, the industry is most excited about the prospect of enabling routine, low-risk BVLOS flight for those with the new Pilot Certificate: Level 1 Complex Operations (plus an organization or point person – an Accountable Executive – holding an RPAS Operator Certificate). The RPOC holder accepts overall responsibility for safe operations, including maintenance, training etc. In addition, the drone must meet TC’s safety requirements for Level 1 Complex Operations.

But to fly BVLOS, the regulations require some sort of Detect and Avoid (DAA) system to avoid conflict with traditional low-flying aircraft. TC has provided a standard for vision-based DAA, but it has limitations including a max distance of 4 NM. For longer range BVLOS missions (and there are many applications) or other scenarios that don’t align with the standard, the operation must use a technology-based DAA solution.

For an industry scrambling to take on routine, low-risk BVLOS operations, that’s a bit of a stumbling block. The cost of DAA systems (including ground-based radar) is prohibitive. And that’s why a recent LinkedIn post by Brian Fentiman, CEO of BlueForce UAV Consulting (and InDro’s Law Enforcement Division Consultant) recently caught our attention.

“Canada’s drone industry is ready for BVLOS, but one major barrier remains: affordable Detect and Avoid (DAA) solutions,” he wrote. “Most DAA systems cost over $100k and can run into the millions. That’s not scalable.”

InDro’s Training and Regulatory Specialist, Kate Klassen, agrees, saying “It might be the first time the regulations have been ahead of the technology.”

Below: A look at the issue

DAA ADS-B Petition

ELECTRONIC CONSPICUITY

 

A far simpler and more cost-effective solution, argue many, would be a mandatory requirement for all crewed aircraft flying at lower altitudes to be equipped with an electronic system that constantly broadcasts information about its position and altitude. This generally means Automatic Dependent Surveillance – Broadcast Out, or ADS-B Out. It’s a vastly more affordable path to avoiding conflict between RPAS and low-flying aircraft, and the cost for RPAS operators for technology to detect these signals is inexpensive, accessible, and available.

“The answer lies in Electronic Conspicuity (EC), low-cost ADS-B Out broadcast by crewed aircraft that lets RPAS operators safely detect and avoid traffic,” writes Fentiman. “The US, Australia, the UK, and New Zealand are already doing this. Canada must catch up.”

Fentiman argues such a mandate would quickly open the skies to much-needed RPAS services, including:

  • Search and Rescue
  • Energy Corridor Inspection
  • Emergency Response
  • Infrastructure Monitoring

NAV CANADA mandated the use of this technology by traditional aviation flying in Class A Domestic Airspace in 2019, expanding it to include Class B in August of 2023. ADS-B is currently not required in uncontrolled airspace. There will be no further changes for some time to come.

“The implementation of any subsequent Canadian ADS-B mandate in Class C, Class D or Class E airspace will occur no sooner than 2028, pending further assessment and engagement with stakeholders,” says NAV CANADA.

That’s part of the reason why the RPAS industry believes it’s critical to address this issue as soon as possible.

“We don’t have a good RPAS-based solution for Detect And Avoid,” explains Klassen. “And size, weight and power restrictions are a challenging problem, which makes it hard to execute BVLOS missions under these regulations. That’s where Electronic Conspicuity comes in. If we expand the NAV CANADA mandate for ADS-B Out…then the only thing we need on the drone is a system to detect those signals.”

 

PETITION

 

With the lack of an approved and affordable DAA system for drones themselves, many in the RPAS industry believe the simplest and most expedient solution is a broader mandate for ADS-B Out on all aircraft that fly below 500′. And so multiple industry partners (including the Aerial Evolution Association of Canada) have come together to create a petition to Transport Canada “to implement a nation-wide requirement for Electronic Conspicuity systems on all low-flying crewed aircraft that share airspace below 500 feet AGL with drones.”

“It’s time to unlock safe and economical BVLOS drone operations in Canada,” writes Fentiman. “A national EC (Electronic Conspicuity) mandate would make Canada safer for both drones and general aviation.”

You’ll find Brian’s full LinkedIn post below – feel free to repost – and you can find a link to the petition here.

DAA ADS-B

INDRO’S TAKE

Like many in the industry, InDro embraces the coming regulations. But we share the belief that the lack of an affordable and approved DAA system will impinge RPAS operators during what should be a period of rapid expansion into routine, low-risk BVLOS flight. That’s why InDro is one of the partners pushing forward this petition.

“Mandating Electronic Conspicuity for all crewed aircraft that share airspace with drones is a logical, practical and cost-effective solution that has the benefit of enhancing safety for traditional aviation, too” says InDro’s Kate Klassen.

Once again, you can sign the petition here. And please spread the word.

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.