JTSand
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Canada
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Hi - VERY important:
Just found out Transport Canada wants to SEVERELY restrict your ability to use drones, and make it VERY EXPENSIVE for you to use, UNLESS you send them an e-mail *this* week (this friday is the deadline, but the sooner it is sent in, i.e., today, the better, because otherwise it might not get through in time). Please take 5 minutes right now to read this, then send them off an e-mail. It is important it is done NOW - because otherwise you will NOT be able to contact them later. The e-mail address is carrac@tc.gc.ca. I've included a counter proposal below, which you are welcome to add/amend to below. Just cut & paste. The proposed regulations were developed from only about 100 people suggestions, many of whom are not aware of how safe drones are to fly, and some who are fearful of them. So we need more than 100 people to reply. If you can share this with people you know to take action and send in an e-mail, retweet/facebook/etc that would be great too.
In summary - with the proposed restrictions - you CANNOT fly in a city unless you pay a bunch of extra money in the form of tests, licensing, insurance, and so forth. (So you COULD not fly in your own backyard, a park, etc, etc). You could get fined up to $1,000-$5,000 (i.e., $25,000 for a set) from a set of about of 50-60 new rules. (That's like buying a $30,000 car, and then getting a $30,000 speeding ticket. Out of proportion, and unfair - like buying several new drones). Mandatory insurance - which apparently would be about $500/year for $100k coverage for ANY in-city flying (even in your own backyard). This will turn what used to be a fun hobby into an expensive and burdensome activity. So PLEASE send off an e-mail saying you want to KEEP THE INTERIM ORDER here with several amendments (reference: www.tc.gc.ca/eng/mediaroom/inter ... model-aircraft.html).
Also - they want to limit your maximum distance to 0.5km, and maximum height to 300 feet. (Right now you could fly 2-3km, and fly up to 1500 feet). I believe if you fly safe & take certain safety precautions, you should be able to fly farther and higher, and that these are unfair restrictions. And then - this would apply to drones that were 250g (i.e., like a toy), or the phantoms (because the current weight class has been set to 1kg).
The reasons listed for the new proposed regulations are for safety, and reducing "SFOC" costs (special permission to fly in certain areas). I don't believe these new regulations accomplish that, and are rather simply a new type of unnecessary tax to make it more expensive for you to fly and enjoy flying. Because of rapid advances in technology (through no drone zones, redudant GPS, obstacle sensing technology, fly to home, etc), drones are incredibly safe to fly. I believe these regulations would stifle that innovation, and are overly restrictive - and make it very expensive for you to enjoy the hobby you enjoy.
Of course - I believe 100% in safety and safe flying. And I believe that can be accomplished with a good, and appropriate balance of rules to keep it safe, but fun at the same time.
The interim order for flying in Canada (March 2017) is actually fairly good, and should be kept with a few small amendments, as opposed to the new, highly restrictive proposed regulations.
a) Details for the current regulations are here:
www.tc.gc.ca/eng/civilaviation/o ... ly.html#regulations
b) Details for the new RESTRICTIVE regulations which they wish to actually PASS (not talk about, but actually PASS) in jan 2018, only 3 months away, are located here:
www.gazette.gc.ca/rp-pr/p1/2017/2017-07-15/html/reg2-eng.php
My COUNTER proposal is as follows (You can cut & paste, and/or add as you see fit, and then e-mail here: carrac@tc.gc.ca)
Feel free to use the short version below as your template. If anyone wants my more detailed reasoning for each point, please let me know and I can send it to you (or post it here).
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Dear Sir/Madam,
I 100% agree with you that safe flying of drones is very important, as well as minimizing the cost of SFOCS (special flight permissions) to transport Canada.
However, I believe the new proposed regulations located here www.tc.gc.ca/eng/civilaviation/o ... ly.html#regulations are overly restrictive and burdensome to the regular drone user. I do not believe it increases safety, but instead makes it more expensive for the regular user to fly, and stifles future drone innovoation and development. Because of rapid advances in technology (through no drone zones, redudant GPS, obstacle sensing technology, fly to home, etc), drones are incredibly safe to fly. They are likely only to continue to become safer and safer. These proposed regulations are more of a form of an unnecessary tax on citizens wishing to fly, and increase in bureaucracy. Since safety appears to be the primary concern, I have the following counter proposal which I believe would accomplish that, while keeping flying affordable, and enjoyable.
I have read the existing proposal, and outlined a COUNTER proposal that myself, as well as a number of other drone enthusiasts, believe should be implemented. I have included the reasoning behind my proposal. I believe the current interin order for flying (March 2017), with a few amendments from the new proposed regulations should instead be utilized, are more than sufficient to create a happy balance between drone enthusiasts, and Transport Canada. Please use the following counter proposal below in drafting the new drone regulations. I have encouraged other drone enthusiasts to use a similar proposal with any amendments they see fit.
The Short Version for the counter proposal:
a) Mandatory insurance is OPTIONAL. It should only be purchased for things like flying for commercial purposes over open assemblies of people, special flight events, or special flight conditions (i.e., flying at altitudes higher than 250m, etc)
b) - A pilot permit NOT required for in-city flying - but instead - an in-app test that must be passed to activate the drone for ALL drones over 250g, with several flight simulation tests in certain scenarious before the drone is activated/permitted to fly live.
This accomplishes the goal of making sure the user is adept at flying before flying without the cumbersome expense and task of administering an expensive license.
Further to that - adding a pre-flight check list built into the software that must be confirmed before take off. AND - it allows the flight test to updated in the future as the technology becomes better.
- A pilot permit should ONLY be required if someone wishes to obtain special permission to fly in restricted airspace, since it requires a much higher degree of flying
expertise and knowledge, OR - if someone is constructing their own drone (as it may not have the built in safety features that drone companies include).
- In city flying SHOULD be allowed without a pilot permit - PROVIDING - the drone has "obstacle detection" enabled while flying. This will prevent the user from flying into buildings,
flying into people, flying into trees, etc, etc - because the drone will automatically stop and/or fly around the object. This technology currently exists, is
very effective and sophisticated, and effectively maps out a 3D view of the terrain allowing the drone to have spatial awareness while flying. In otherwords - it
is safe to fly in a city.
c) Registration NOT required - but rather, marking the drone (name/#/etc). Registration simply is more expensive for the individual, and serves no real purpose other than added expenses and administration.
d) DRASTICALLY reducing fines to $50-$150/item, as opposed to the proposed $1000-$5000 per item per individual. $1000-$5000 is 1-5x the cost of most expensive drones, and very disproportiante in fines to other types of vehicles. Basically, a single fine could purchase 4-5 drones, which is grossly disproportinate to the cost.
e) Adding specific safety measures implemented by drone manufacturers for future drone development. (Specifically, a secondary low charge emergency battery in event of failure of the first one. And second, a type of non-electronic parachute/frisbee apparatus to deploy should the drone be tumbling (i.e., power failure, propellor failure) so it can have a safe landing).
f) Night flying being permitted PROVIDING it has a safety return to home altitude of 100m, the user only flies with VLS (most drones have night lights that can be seen, similar to aircraft), and is flown only on clear nights. (I.e., no rain/fog/etc). The user should also map out a flight path (i.e., using google maps) to pre-inspect where they wish to fly so they are aware of potential obstacles to avoid while doing night flying.
g) Maximum cruising flying altitude be increased to 400ft (120m) - as it provides more safety for setting return-to-home settings. Special exceptions for flying higher, i.e., 250m (750 feet) should be allowed (i.e., rural flying, insurance with in-city flying, etc). Special situations should be allowed for flying at higher altitudes. Most drones are limited to a maximum of 1500 ft (500m). Most drones also contain NO FLY zones - in which the drone CANNOT fly in those situations. So the drones can still fly safely.
k) Permitting farther lateral distances (i.e., 2.5km-3.5km) , providing the drone has certain safety features built in to ensure safe flying (i.e., return to home in event of signal loss, low battery indictator when the drone needs to return home because of distance).
l) Change the weight class of the drones from 250g, to 500g (for the small drone), and from 1kg to 2kg for the larger class drones. (Which allows you to fly tiny drones safely, and then medium class drones with some safety precautions).
Also - I believe this should apply to new drones constructed (and old drones have the existing interim order applied to them/grandfathered in).
Only if a drone did NOT contain the following should an actual pilot license be required to be obtained (i.e., if someone 'made' their own drone, or was flying one without certain safety features built in - applied to NEW drones), as obviously it would require special piloting knowledge/safter flying skills. (This should not apply to drones purchased prior to the coming-in-force date, rather they should be grandfathered in):
Certain required features should be things like:
a) No fly zone list
b) Built-in obstacle detection/avoidance
c) Safety measures (GPS/stabalization, return to home in event of signal loss, etc)
This is because drones have become incredibly safe to fly, and the following counter proposal addresses that, achieving a balance of safe flying, and fun for the regular user.
Thank-you for reading this counter proposal. I hope you implement the suggestions provided.
Sincerely,
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Captain