Here you go. This is my offering to Mr. Garneau.
As mentioned by another member here, it's not important that everyone agree with every point; it's more important to take a stand and at least try. If I had to rewrite it 5 times I'd probably rewrite it 5 different ways, but I had to at finally click "send" at some point.
Honourable Minister Garneau,
Having become aware of the restrictions you have recently imposed upon recreational drone use in Canada, I feel compelled to respectfully offer feedback which will hopefully compel a review of restrictions that, in their current form, virtually eliminate even the most casual and safe use and enjoyment of drones in our country.
While I certainly agree that some restrictions are necessary to help integrate this new and evolving technology safely within our existing transportation infrastructure, as well as provide a reasonable expectation of safety to the public in general, I also believe that a more appropriate balance is required to allow this technology to grow and flourish as the emerging advance it is poised to become.
Please consider the following:
While several of the rules are understandable and acceptable, such as the range from an airports and controlled air space, as well as staying clear of forest fires, first responders, and being sure to stay within line of sight including avoiding clouds and darkness, there are some troubling points that as mentioned, if interpreted to the letter of print, virtually eliminate drone use entirely.
To the specific points presented in your announcement of March 16, 2017, the height restriction of 90m is approximately 30m lower than that of our US counterparts at 120m, which is still well below the minimum altitude of an aircraft outside of an airport or point of take-off/landing.
However, the most troubling of all is the restriction of maintaining a distance of 75m from “buildings, vehicles, vessels, animals, people, crowds, etc.” First and foremost, the “etc” is of particular concern in that it could be interpreted that drone flight should be restricted from 75m of virtually anything. Even with a less a hard approach to the “etc”, I respectfully submit that even outside of built up areas, in our country’s vast expanses of wilderness, I have to imagine that I am always within 75m of an animal at any given time. Furthermore, in any free and accessible location that it is permissible to launch and fly from, that same area is just as open to other members of the general public and upon their arrival and presence a drone pilot would then be in violation of the new restrictions.
With this reasonable interpretation of the new restrictions, it becomes clear to conclude that recreational drone flight can be considered effectively impossible anywhere in Canada.
While I admit to not being in a position to verify quoted specific statistics with regard to the threat to aircraft, simple research has shown that there have not yet, thankfully, been any confirmed aircraft/drone strikes on record. There have however been reportedly some 65,000 bird strikes, and some studies in the UK are showing that there is no more threat of damage by drone than bird. It is important to note that pilots have not been required to verify with certainty that the sightings they’ve been reporting are in fact drones, which can skew the reported statistics.
It also becomes critically important to review the tremendous amount of benefit that this technology and its use can provide.
- There are recent and growing reports of drones providing critical support with regard to search and rescue teams, and many of these drones are supplied and operated by civilians that happen to be in the “right place at the right time”, when location of missing persons is exceptionally time sensitive
- The widespread use of some of the technical and advanced electronics can certainly forward the development of better, safer technologies, much faster than any other means. This includes:
- Batteries, which can benefit transportation industries and environmental causes, as well as the medical field and the refinement of safer batteries in general in response to recent reports of lithium polymer instability.
- The GPS capability of several of the more popular models, which with propagation can evolve exponentially, may enhance mapping, search and rescue grids, and any number of uses that location accuracy can assist with
- Wireless signals have clearly emerged as a preferred and beneficial means of communication, and can reach unprecedented testing and refinement when used and tested by non-critical, recreational means
- Autonomous flight is certainly an exploratory technology of the future, and with all due respect, your own experience as an astronaut could have certainly been adversely affected had the development of technology been as stifled and these new restrictions are.
There is no doubt that rules and guidelines are required to ensure public safety. I would suggest that a reasonable route to pursue may be licensing; much as Canadians are now required to have a Pleasure Craft Operators License to ensure that guidelines are understood and followed, with reasonable means of enforcement available.
There are two reasons this point becomes relevant:
- This will help discourage any casual operators that are simply interested in the fascination of the hobby without fully committing to the understanding of safety requirements that protect us all, of whom which can be the primary source of reckless flight, while additionally allowing law enforcement a simple and effective means of deterrence;
- This can be tied to drone ownership and registration, much like the US, so that registration can be affixed to the aircraft rather than the personal information now required to be attached, which can lead to privacy and confrontational issues
Licensing can also be size/weight specific, to ensure that the larger drones which can be a greater threat to aircraft or persons on the ground, can have rules set for their individualized use.
There are normal and acceptable risks we face and willingly accept every day as commonplace. Cars and 80,000lb trucks use the same roads as cyclists and pedestrians. Thousands upon thousands of aircraft are over our heads all the time. There are endless circumstances that we accept as normal, though any of the above is subject to human error or mechanical failure at any time. I implore you to reconsider such stifling restrictions that an entire emerging hobby’s existence is threatened.
Finally Mr. Garneau, this technology is a fantastic source of family outdoor fun and adventure. The abundance of learning and growth that I’ve been able to enjoy with my family, along with the excellent and newly discovered photographic footage available, is unprecedented.
Thank you for your time. I would welcome any feedback or interaction that you would consider helpful on this matter.
Respectfully,
(Me)
