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EAA Canada's Response to TC's Notice of Proposed Amendment on Drones

By Jeff Seaborn, EAA Canadian Council Chair

July 2020 – First, I'd like to apologize for the late release of last month's Bits and Pieces. We recognize that the release date of last month's drone regulation article provided little time to respond to Transport Canada's Notice of Proposed Amendment to Remotely Piloted Aircraft Systems. We intended to get the newsletter out earlier but, in the end, it was released the same day as the comments were due. A week earlier we realized that this timing would be close, so we sent an email to the Canadian chapter executives. We asked the chapters to encourage their members to read Transport Canada's proposal, giving them time to respond. I saw some notices going out from your local executives to their members, so there is strength in the chapter network and value in being a member. Thank you to the local leadership for sharing that info and thank you to everyone who made time to get in a response to TC.


One of those larger drones.

I received a few responses to that email and was copied on a few of the messages to TC. These inputs provided perspectives as broad and as varied as our country. All opinions are valid and all are important to pass on. Again, thank you for sharing them.

EAA has been supportive of drones and the advancements in technology and services that these devices have provided. That industry has experienced rapid growth and development and will continue to do so. Drones continue to provide solutions that weren't considered possible only months earlier. If you've been to EAA AirVenture Oshkosh in recent years, you would have seen the encouragement and opportunities that EAA provides to development companies to demonstrate their capabilities, and how EAA is promoting discussions to integrate traditional aviation with the new traffic in our skies in a safe and practical manner.


EAA's No. 1 priority is the safety of pilots, air crew, and people on the ground. Of course, the physical consequences due to a midair collision weigh most heavily on those in the air.

While EAA and its members can provide input, it's important to recognize that FAA and TC are the governing bodies that make the rulings. EAA, just like the drone industry, can provide these bodies with fair and possibly differing perspectives that help the FAA and TC make informed and, hopefully, intelligent decisions.

The privilege to fly should be shared by all, but there needs to be an understanding of what's achievable, both practically and economically. EAA and your EAA Canadian Council are working to be part of the solution.

One important concern here is that the Beyond Visual Line of Sight proposed regulation change would allow drones as heavy as a Cessna 152 to be flown in airspace that could include farm strips. The exam for a drone operator's license, basic or advanced, appears to be done online with no flight test component, and no monitoring whether the candidate has someone sitting next to them answering the questions. The advanced license does require a verbal interview with a flight reviewer. The flight reviewer exam is online, too. As far as one can tell, the Special Flight Operating Certificate (including those heavier drones) requires no more licensing certification on behalf of the pilot, just the SFOC, although there is a proposal for an Operational Level Rating for BVLOS flights and a proposed recency requirement. In contrast, the person with a PPL in the manned aircraft has a minimum of 45 hours of in-flight training and practice and the same amount of time in ground school. If you'd like to read the full text of TC's discussion document, click here. — Ed.

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