TC issues Advisory Circular on “SAFE” RPAS Design

As part of the new CAR 900 Regulations for RPAS operations, the concept of design specifications and declarations, covering both fixed wing and rotary RPAS Aircraft (A/C) was introduced. Transport Canada officially calls it “RPAS Safety Assurance”.

The intent of the “SAFE” rating for A/C under 25 kg was to provide manufacturers and operators with a path to be able to fly in three situations that had previously been covered by either SFOC Complex Standing documents or the use of Compliant A/C.

The new “SAFE” categories are:

  • Part a) Flights in controlled airspace under 400 ft AGL
  • Part b) Flights less than 30m but more than 5m from people not involved in RPAS operation
  • Part c) Flights less than 5m and over people not involved in the operation.

These operations are described in the new 900 CARs, but until recently, there was no documentation to cover what a manufacturer needed to do to specify which of their A/C were capable of flight in each of these categories.

As Transport Canada states on their website…

This standard describes the technical requirements manufacturers are required to meet in order to make a declaration in accordance with section 901.76 of the CARs. Under section 901.79 of the CARs, the manufacturer is required to retain records of tests undertaken to ensure the model of RPAS meets the applicable technical requirements. An RPAS for which a manufacturer makes no declaration cannot be used to conduct advanced operations identified in CARs section 901.69.

Previously declared Compliant A/C are grandfathered for part a) and b).

The declarations need to be done by June 1st to allow flight in these categories when the new regulations come into force.TC is now releasing a draft Advisory Circular, AC922, that provides the detail behind the standard mentioned in the CARS.

You can get a copy of the DRAFT AC922 here.

TC has done a pre-release of this document to manufacturers and USC, and held a meeting last week to start the consultation process. 

Here at ckmmphoto, we were happy to see the 900 series RPAS regulations roll out, as that helps provide some stability to our business, our customers and other businesses in the RPAS industry, and glad to see the AC come out as well to get the SAFE process started.

Our initial reading of the AC raises a number of concerns:

  • Manufacturers of current, non-compliant have to declare one or more “SAFE” categories for each of their current A/C or those A/C will only be allowed to fly in Class G airspace. This means that current Complex SFOC owners, who fly in controlled airspace today. with those same A/Cs, will be restricted to Class G if their A/C manufacturer does not declare.
  • If manufacturers of non-compliant A/C do not declare their various models “SAFE”,  Complex SFOC operators will be forced to go and buy new A/C that ARE declared “SAFE” to continue to operate where they can today. 
  • Manufacturers may not declare prior generations of their A/C “SAFE”, meaning in that case, new A/C will have to be purchased.
  • The complexity of testing and preparing documentation and the effort required raises a concern on timing. The documentation and declarations of the “SAFE” categories needs to be done by June 1st to allow operations in any of the categories, and that is a very short timeframe in engineering time.
  • That same complexity of testing for each of the categories has also raised the concern about costs and overheads to smaller manufactures and may cause them to cease operations.

Fortunately, the AC is draft and is being circulated for comments and feedback. Please down load a copy and send your comments BY FEBRUARY 22.

You can send comments to: TC.RPASInfo-InfoRPAS.TC@tc.gc.ca

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