Transport Canada has just released its AIM guide on October 7th. Here is what affects us directly.
“If a mATP is modified or accessories added that increase its weight to 250g or more (such as propeller guards), that mATP must be registered under Part IX of the CARs. This registration is done on the Drone Management Portal (PGD), using the option “The drone was built with a kit, commercial parts, or custom-made parts”. Once registered in the PGD, the pATP can be used for a flight review. It must be taken into consideration that it will not have a RPAS safety assurance statement to fly in controlled airspace or near people. If the pATP reverts to its original unmodified version below 250g, then the ATP must be deregistered from the PGD and is again a mATP. »
3.4.8 Editing an ATP
“Modifications made to an RPAS with a Statement of Safety Assurance, including the addition of additional equipment, must be made in accordance with the manufacturer’s recommendations (CAR 901.70). The integration of complementary equipment from another manufacturer, modifications made to the structure or electrical systems of an RPAS (hardware and software) or any other change which does not correspond to the manufacturer’s specifications may constitute a modification of a RPAS. Changes that do not affect the original security assurance statement and therefore do not change the declared capabilities of an RPAS do not require notification to the Minister. An RPAS should always be used within the operational limitations defined by the manufacturer (CAR 901.31) who has made the RPAS safety assurance statement. Changes that may affect the declared capabilities of the original RPAS, add additional advanced usability capabilities, or adversely affect the safety or “airworthiness” of the original RPAS require the party making the change to file with the Minister a new RPAS security assurance statement as a modified RPAS. »
Thus, the use of third-party software (Litchi, Dronelink, Drone Harmony, etc., which are not ‘Stock’ software but third-party software) may constitute a modification of the SATP, and therefore be subject to a assessment of the security assurance statement. Therefore, either the software publisher or the user is supposed to take steps to ensure that their use is safe before proceeding with advanced operations.
“It is the responsibility of the party performing the modification or addition of equipment to assess whether there is an impact on the declared capabilities of this RPAS and that the RPAS remains in conformity with the specifications published by the manufacturer. Assessment of the impact that modifications may have on the RPAS should ensure that the modification or added equipment can be safely integrated into existing systems and does not introduce new failure conditions not considered in the design of the system origin of the manufacturer.
If the modification may affect the declared capabilities of the original RPAS, or if the modifying party does not have the technical information of the original design to properly conduct the evaluation, the declaration filed by the manufacturer of the RPAS is invalidated and the SATP is restricted to operations in base environments only, unless the author of the SATP modification makes a new security assurance statement. The author of the modification who files a security assurance declaration of a modified RPAS assumes the same. Regulatory responsibilities than a declared RPAS manufacturer (CAR 901.76).
Advisory Circular (AC) 922-001 — RPAS Safety Assurance serves as a guide to considerations that should be taken into account by reporting parties The addition of a parachute system may constitute a modification if its integration affects the ability of an RPAS to continue to conform to declared capabilities, or whether it is used to add additional operational capabilities, such as operations over people. The addition of a parachute does not in itself allow an ATP to fly over people; however, a Safety Assurance Statement from the RPAS for operations over people is required (CARs 922.06).
Users of RPA fitted with parachute systems are responsible for ensuring that they have properly registered their RPA to match the operating environments offered by the parachute, and that the RPA is used within the limits published by the manufacturer (including, but not limited to, altitude, wind, temperature, or other operational limits and minima). For example, if the parachute manufacturer has determined a minimum deployment altitude for his parachute to operate, it is the responsibility of the RPA pilot to ensure that this operational limitation is met and that he flies above the altitude. minimum published by the manufacturer. RPAs operated outside of the manufacturer’s operational limitations are not considered to operate within the RPAS’ stated capabilities and are not safe for flight (CAR 901.31). »
To summarize, if you want to do advanced operations with a SATP for which you have made modifications or that the addition of payload goes out of the specifications made by the manufacturer during its declaration of security assurance, it is up to you to justify that you either remain within the specifics of the manufacturer, or to make new ones, and to submit them to Transport Canada.
3.6.2 Application for a Special Flight Operations Certificate (SFOC) — RPAS
“The applicant should be able to demonstrate an operational need for the type of certificate requested, present an adaptable risk management plan, which identifies not only the potential hazards associated with the proposed operations, but also the associated risks, as well as a plan to mitigate them. AC 903-001 — Operational Risk Assessment of Remotely Piloted Aircraft Systems (ERO RPAS) provides information and guidance to manufacturers and users for the purpose of developing or using an RPAS for operations in accordance with the requirements of the Part IX, Subpart 3 of the Canadian Aviation Regulations (CARs). »
3.5.3 Conduct of flight reviews
“Flight reviews are conducted in person at a site selected by the candidate. They may take place in controlled or uncontrolled airspace; however, the flight review itself must comply with Part IX of the CARs. The candidate must be able to meet the requirements to be able to use the ATP in this airspace. He is not required to have the ATP pilot certificate — advanced operations. Prior to the flight review, the candidate may be assigned by the flight reviewer to an advanced operational type ATP assignment. This will be used during the ground portion of the flight review to validate the candidate’s ability to plan and execute an advanced RPA operation. Only a pATP (250 g to 25 kg) can be used to carry out a flight review. Subparagraph 921.06(1)(c)(i) of the standard states that the RPA used for flight review must be registered under section 901.02 of the CARs(…). »
Before, you had to have an authorized drone on a Transport Canada list, which is no longer the case.