I've just sent them this question in email, not hopeful in getting a reply anytime soon...
Transport Canada,
I am Canadian private pilot and a model aircraft enthusiast. I would like to inquire about the interpretations and intent behind specific clauses in the exemption of small (<2kg) UAV from sections 602.41 and 603.66 of the CARs.
http://www.tc.gc.ca/civilaviation/regse ... n/2880.htm
I believe the intention of this is to allow small UAV to operate within Canada safetly and encourage a wave of technological and business development for Canadians and associated companies. For one, I do appreciate the need for clear and reasonable rules so all Canadians can share our airspace resource safely and productively. However, upon reading the exemptions in detail, there are two clauses that would make this exemption difficult to apply and drastically decrease the practical value if the intent is indeed as I had expected. While I understand that these restrictions doesn't apply to my recreational use of RC fixedwing/rotorcrafts, through I am concerned about some specific clauses as stated the purpose...
16. The pilot operating under this exemption shall not use a first person view device.
26. The pilot operating under this exemption shall only operate a UAV at least five (5) nautical miles from a built up area.
As defined on the page, the first person view (FPV) device include a monitor that projects a view from the UAV. So does #16 prohibit any a pilot from using FPV even if he/she is using it frame a picture/video rather than as a primary means of navigation? If that is the case, then this restriction is prohibitive and would prevent the most common non-recreational use of UAV which is photo or video taking as it is nearly impossible to take a picture/video without the ability to see what the camera is pointing at. I can see that a commercial UAV pilot should be restricted from relying on FPV for navigation (as through a video goggles), but there is not need for the sake of safety to prevent the use of any FPV device.
The restriction 26 on being 5 miles from a built up area appears overly broad. Depending on the definition of a built up area, it would almost all locations where Canadians live, including all urban/suburban parks, many farms, and waterfronts. Does that mean one can only use this exemption in remote locations and must seek a specific SFOC for any other locations even for a small UAV that is <2kg? Would this prevent a person from using a UAV to take a picture of their suburban home / cottage to post on a for-sale ad, as their home is almost surely located in a built up area?
I appreciate the original intent of these exemptions as it has the opportunity to open up Canada for research, investment and innovations, but am concerned that the above 2 restrictions would totally nullify the intent and make these exemptions useless in practice. There appears no need for such restrictive rules especially for UAV that are so small. I hope my someone can help me clarify the interpretations of these rules.
