Canada’s Ridiculous UAS Regulations

Transport Canada just released some proposed guidance on the commercial operation of light unmanned aerial systems. Drones. If you haven't had a chance to look it over, here's the link (PDF). I suggest at least skimming it. (I'll wait while you do that.)

Clearly, our friends north of the border have come adrift from reality and seem to be operating on some planet other than Earth. First of all, they're proposing to provide UAS operators with mere guidance through an Advisory Circular, for cryin' out loud. Second, the entire document is but 30 pages long and has a shallow 46 points of guidance. Do they seriously believe that a field as complex and dynamic as UAS operation can be governed by so few rules and restrictions?

Evidently, they do and a careful reading of the document will reveal a nave mindset among the technocrats who dreamed up this circular. Throughout, the language implies that people who fly these devices are expected to exercise common sense and good judgment in their operation, while leaving the definition of these nebulous concepts entirely up to the drone operators. Furthermore, the AC seems utterly bereft of threatening and punitive language. How can it be considered serious regulation? What's next, a joining of hands for a ceremonial singing of Kumbaya? How can there be a carrot with no stick? Gain with no pain?

More troubling yet is that the Canadians seem to believe that UAS operation is somehow different than flying an actual airplane. In fact, the circular seems to have been written by people who have actual knowledge of UAS and may have seen them fly. Or worse, actually flown one. How else to explain their profoundly ignoring the innate value of UAS operators being required to hold pilot's licenses, as the FAA seems to be considering. I mean, break it down here. How can a UAS pilot possibly be competent or safe if he or she can't use an E6B, doesn't know about traffic pattern entries and can't do dead reckoning? And what about short field takeoffs and landings? (And never mind that many commercial drones are VTOLs. This is a meaningless formality.)

In their headlong rush to get out of the way of inevitable technology,Canadian regulators seem satisfied that a UAS pilot needs only a short course in regulations procedures and basic airspace. Maybe you could even do it online and take a quiz.The Canadians also whiff on the medical issue, saying that a UAS pilot should simply be fit with no known maladies or afflictions that would keep him from flying the UAS safely on the day he intends to do it. But how can this be assured without requiring a proctologic exam every 24 months?

Also, I wonder if this guidance is in compliance with ICAO standards. As it's written now, the AC is very likely to encourage a boom in the Canadian commercial UAS industry, creating more development, jobs and a vibrant industry without years of delay, obfuscation and bureaucratic dissembling. It may place Canada years ahead of the U.S. This is in utter contravention to everything we know about proper regulation and I wonder how long it will be before someone realizes they have to put a stop to it.

Canada, wake up while there's still time.

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