Regulations Amending the Canadian Aviation Regulations (RPAS – Beyond Visual Line-of-Sight and Other Operations): SOR/2025-70

Canada Gazette, Part II, Volume 159, Number 7

Registration
SOR/2025-70 March 6, 2025

AERONAUTICS ACT

P.C. 2025-273 March 5, 2025

Her Excellency the Governor General in Council, on the recommendation of the Minister of Transport, makes the annexed Regulations Amending the Canadian Aviation Regulations (RPAS – Beyond Visual Line-of-Sight and Other Operations) under paragraph 4.4(2)(b)footnote a, section 4.9footnote b, subsection 5.9(1)footnote c and paragraphs 6.71(3)(a)footnote d and 7.6(1)(a)footnote e and (b)footnote f of the Aeronautics Act footnote g.

Regulations Amending the Canadian Aviation Regulations (RPAS – Beyond Visual Line-of-Sight and Other Operations)

Amendments

1 (1) The definition small remotely piloted aircraft in subsection 101.01(1) of the Canadian Aviation Regulations footnote 1 is repealed.

(2) Subsection 101.01(1) of the Regulations is amended by adding the following in alphabetical order:

command and control link
means the data link between a remotely piloted aircraft and a control station that is used in the management of a flight; (liaison de commande et de contrôle)
control station
means the collection of facilities and equipment from which a remotely piloted aircraft is controlled and monitored; (poste de contrôle)

2 Section 103.12 of the Regulations is amended by striking out “and” at the end of paragraph (h), by adding “and” at the end of paragraph (i) and by adding the following after paragraph (i):

3 Part IX of Schedule II to Subpart 3 of Part I of the Regulations is amended by adding the following after the reference “Section 900.06”:
Column I Designated Provision Column II Maximum Amount of Penalty ($)
Individual Corporation
Section 900.07 3,000 15,000
Subsection 900.08(1) 1,000 5,000
Subsection 900.09(1) 5,000 25,000
Subsection 900.13(1) 5,000 25,000
Section 900.14 3,000 15,000
Subsection 900.18(1) 1,000 5,000
Section 900.19 1,000 5,000
Section 900.20 1,000 5,000

4 The heading before the reference “Section 901.02” in Part IX of Schedule II to Subpart 3 of Part I of the Regulations is replaced by the following:

SUBPART 1 — SMALL REMOTELY PILOTED AIRCRAFT AND MEDIUM REMOTELY PILOTED AIRCRAFT

5 The references “Section 901.02” to “Section 901.09” in column I of Subpart 1 of Part IX of Schedule II to Subpart 3 of Part I of the Regulations and the corresponding amounts in column II are repealed.

6 The reference “Subsection 901.12(1)” in column I of Subpart 1 of Part IX of Schedule II to Subpart 3 of Part I of the Regulations and the corresponding amounts in column II are repealed.

7 The reference “Section 901.13” in column I of Subpart 1 of Part IX of Schedule II to Subpart 3 of Part I of the Regulations is replaced by “Subsection 901.13(1)”.

8 The references “Subsection 901.14(1)” and “Subsection 901.14(2)” in column I of Subpart 1 of Part IX of Schedule II to Subpart 3 of Part I of the Regulations and the corresponding amounts in column II are replaced by the following:
Column I Designated Provision Column II Maximum Amount of Penalty ($)
Individual Corporation
Section 901.14 3,000 15,000
9 The reference “Section 901.30” in column I of Subpart 1 of Part IX of Schedule II to Subpart 3 of Part I of the Regulations and the corresponding amounts in column II are replaced by the following:
Column I Designated Provision Column II Maximum Amount of Penalty ($)
Individual Corporation
Subsection 901.30(1) 1,000 5,000
Subsection 901.30(2) 1,000 5,000
10 The reference “Section 901.34” in column I of Subpart 1 of Part IX of Schedule II to Subpart 3 of Part I of the Regulations and the corresponding amounts in column II are replaced by the following:
Column I Designated Provision Column II Maximum Amount of Penalty ($)
Individual Corporation
Subsection 901.34(1) 1,000 5,000
Subsection 901.34(2) 1,000 5,000
Subsection 901.34(3) 1,000 5,000
11 Subpart 1 of Part IX of Schedule II to Subpart 3 of Part I of the Regulations is amended by adding the following after the reference “Section 901.38”:
Column I Designated Provision Column II Maximum Amount of Penalty ($)
Individual Corporation
Section 901.38.1 1,000 5,000
12 The portion of the reference “Subsection 901.41(1)” in Subpart 1 of Part IX of Schedule II to Subpart 3 of Part I of the Regulations, in column II, is replaced by the following:
Column II Maximum Amount of Penalty ($)
Individual Corporation
3,000 15,000
13 The portion of the reference “Subsection 901.47(3)” in Subpart 1 of Part IX of Schedule II to Subpart 3 of Part I of the Regulations, in column II, is replaced by the following:
Column II Maximum Amount of Penalty ($)
Individual Corporation
3,000 15,000
14 Subpart 1 of Part IX of Schedule II to Subpart 3 of Part I of the Regulations is amended by adding the following after the reference “Subsection 901.47(3)”:
Column I Designated Provision Column II Maximum Amount of Penalty ($)
Individual Corporation
Subsection 901.47(4) 3,000 15,000
15 Subpart 1 of Part IX of Schedule II to Subpart 3 of Part I of the Regulations is amended by adding the following after the reference “Subsection 901.49(2)”:
Column I Designated Provision Column II Maximum Amount of Penalty ($)
Individual Corporation
Section 901.50 1,000 5,000
Section 901.51 3,000 15,000
16 Subpart 1 of Part IX of Schedule II to Subpart 3 of Part I of the Regulations is amended by adding the following after the reference “Section 901.58”:
Column I Designated Provision Column II Maximum Amount of Penalty ($)
Individual Corporation
Section 901.59 1,000 5,000
17 Subpart 1 of Part IX of Schedule II to Subpart 3 of Part I of the Regulations is amended by adding the following after the reference “Section 901.67”:
Column I Designated Provision Column II Maximum Amount of Penalty ($)
Individual Corporation
Section 901.68 1,000 5,000

18 The reference “Subsection 901.69(1)” in column I of Subpart 1 of Part IX of Schedule II to Subpart 3 of Part I of the Regulations is replaced by “Section 901.69”.

19 Subpart 1 of Part IX of Schedule II to Subpart 3 of Part I of the Regulations is amended by adding the following after the reference “Subsection 901.71(1)”:
Column I Designated Provision Column II Maximum Amount of Penalty ($)
Individual Corporation
Subsection 901.71(3) 1,000 5,000
20 The references “Subsection 901.76(1)” to “Section 901.87” in column I of Subpart 1 of Part IX of Schedule II to Subpart 3 of Part I of the Regulations and the corresponding amounts in column II are replaced by the following:
Column I Designated Provision Column II Maximum Amount of Penalty ($)
Individual Corporation
Subsection 901.74(1) 1,000 5,000
Subsection 901.74(2) 1,000 5,000
Section 901.75 1,000 5,000
Section 901.88 1,000 5,000
Subsection 901.89(1) 1,000 5,000
Section 901.91 1,000 5,000
Section 901.92 1,000 5,000
Section 901.93 1,000 5,000
Section 901.94 1,000 5,000
Subsection 901.95(1) 1,000 5,000
Subsection 901.96(1) 1,000 5,000
Subsection 901.96(2) 1,000 5,000
Subsection 901.175(1) 3,000 15,000
Subsection 901.175(2) 3,000 15,000
Section 901.177 1,000 5,000
Section 901.178 1,000 5,000
Paragraph 901.180(a) 1,000 5,000
Paragraph 901.180(b) 1,000 5,000
Paragraph 901.180(c) 1,000 5,000
Section 901.181 1,000 5,000
Subsection 901.182(1) 1,000 5,000
Subsection 901.182(2) 1,000 5,000
Section 901.183 1,000 5,000
Section 901.184 1,000 5,000
Subsection 901.194(3) 3,000 15,000
Subsection 901.194(7) 1,000 5,000
Section 901.195 3,000 15,000
Section 901.197 3,000 15,000
Section 901.198 3,000 15,000
Section 901.199 1,000 5,000
Section 901.200 3,000 15,000
Subsection 901.201(1) 3,000 15,000
Subsection 901.201(2) 3,000 15,000
Subsection 901.217(1) 1,000 5,000
Subsection 901.217(2) 1,000 5,000
Subsection 901.217(3) 1,000 5,000
Subsection 901.217(4) 1,000 5,000
Subsection 901.218(1) 1,000 5,000
Subsection 901.219(1) 1,000 5,000
Subsection 901.219(3) 1,000 5,000
Subsection 901.219(4) 1,000 5,000
Subsection 901.219(5) 1,000 5,000
Subsection 901.220(1) 1,000 5,000
Subsection 901.220(2) 1,000 5,000
Subsection 901.221(1) 1,000 5,000
Subsection 901.221(2) 1,000 5,000
Section 901.222 1,000 5,000
Subsection 901.223(1) 1,000 5,000
Subsection 901.223(2) 1,000 5,000

21 The Regulations are amended by adding the following after section 104.06:

Annual Adjustment

104.06.1 (1) The charges set out in the following provisions are to be adjusted in each fiscal year on April 1 by the percentage change over 12 months in the April All-items Consumer Price Index for Canada, as published by Statistics Canada under the Statistics Act, for the previous fiscal year:

(2) A charge is not adjusted by operation of subsection (1) in a fiscal year if the percentage change described in that subsection for that fiscal year is less than 1%.

(3) If subsection (2) applies with respect to a fiscal year, the percentage change is carried forward to the subsequent fiscal year. If the combined percentage change is less than 1%, the charge is not adjusted for that subsequent fiscal year and the combined percentage change is carried forward to the next subsequent fiscal year.

22 Subsection 104.06.1(1) of the Regulations is amended by striking out “and” at the end of paragraph (c) and by replacing paragraph (d) with the following:

23 The Regulations are amended by adding the following after section 104.06.1:

Exception — Emergency Response Operations

104.06.2 A charge imposed in respect of the issuance of documents referred to in paragraphs 1(e) to (i) of column I of Schedule VII to this Subpart is not payable by a government organization in respect of an emergency response operation.

24 Schedule II to Subpart 4 of Part I of the Regulations is amended by replacing the references after the heading “SCHEDULE II” with the following:

(Sections 104.01 and 104.02 and paragraph 104.06.1(1)(a))

25 Paragraph 3(d) of Schedule II to Subpart 4 of Part I of the Regulations is replaced by the following:
Item

Column I

Document or Preparatory Action in Respect of Which a Charge Is Imposed

Column II

Charge ($)
3 (d) a remotely piloted aircraft registration 10

26 Schedule IV to Subpart 4 of Part I of the Regulations is amended by replacing the references after the heading “SCHEDULE IV” with the following:

(Sections 104.01 and 104.02 and paragraphs 104.06(a) and 104.06.1(1)(b))

27 The portion of item 29 of Schedule IV to Subpart 4 of Part I of the Regulations in column I is replaced by the following:
Item

Column I

Document or Preparatory Action in Respect of Which a Charge Is Imposed
29 Endorsement of a pilot certificate — remotely piloted aircraft — advanced operations or a pilot certificate — remotely piloted aircraft — level 1 complex operations with a flight reviewer rating
28 Schedule IV to Subpart 4 of Part I of the Regulations is amended by adding the following after item 29:
Item

Column I

Document or Preparatory Action in Respect of Which a Charge Is Imposed

Column II

Charge ($)
30 Conduct of the taking or retaking of an examination for a pilot certificate — remotely piloted aircraft — level 1 complex operations, or for recency requirements 50
31 Issuance of a pilot certificate — remotely piloted aircraft — level 1 complex operations 125

29 Schedule VI to Subpart 4 of Part I of the Regulations is amended by replacing the references after the heading “SCHEDULE VI” with the following:

(Sections 104.01 and 104.02 and paragraph 104.06.1(1)(c))

30 Schedule VI to Subpart 4 of Part I of the Regulations is amended by adding the following after item 15:
Item

Column I

Document or Preparatory Action in Respect of Which a Charge Is Imposed

Column II

Charge ($)
16 Issuance of an acceptance letter (CAR 901.196) 1,200

31 (1) Schedule VII to Subpart 4 of Part I of the Regulations is amended by replacing the references after the heading “SCHEDULE VII” with the following:

(Sections 104.01 and 104.02 and paragraph 104.06.1(1)(d))

(2) Schedule VII to Subpart 4 of Part I of the Regulations is amended by replacing the references after the heading “SCHEDULE VII” with the following:

(Sections 104.01 and 104.02, paragraphs 104.06.1(1)(d) and (e) and section 104.06.2)

32 Item 1 of Schedule VII to Subpart 4 of Part I of the Regulations is amended by adding the following after paragraph (d):
Item

Column I

Document or Preparatory Action in Respect of Which a Charge Is Imposed

Column II

Charge ($)
1 (e) very low-complexity RPAS operations 20
(f) low-complexity RPAS operations 75
(g) medium-complexity RPAS operations 900
(h) high-complexity RPAS operations 2,000
(i) an amendment to a special flight operations certificate — RPAS 60
33 Schedule VII to Subpart 4 of Part I of the Regulations is amended by adding the following after item 18:
Item

Column I

Document or Preparatory Action in Respect of Which a Charge Is Imposed

Column II

Charge ($)
RPAS Operators
19 Issuance of an RPAS operator certificate 125

34 Section 106.01 of the Regulations is amended by striking out “and” at the end of paragraph (e), by adding “and” at the end of paragraph (f) and by adding the following after paragraph (f):

35 Paragraph 106.03(b) of the Regulations is replaced by the following:

36 Section 400.01.1 of the Regulations is replaced by the following:

400.01.1 This Part does not apply in respect of the issuance of a Canadian aviation document in respect of the operation of remotely piloted aircraft systems.

37 The portion of subsection 501.01(1) of the Regulations before paragraph (a) is replaced by the following:

501.01 (1) Subject to subsection (2), the owner of a Canadian aircraft — other than a remotely piloted aircraft that is an element of a remotely piloted aircraft system in respect of which a design approval document has not been issued or applied for under Subpart 21 of this Part or an ultra-light aeroplane — shall submit to the Minister an Annual Airworthiness Information Report in respect of the aircraft, in the form and manner specified in Chapter 501 of the Airworthiness Manual, either as

38 The portion of section 507.01 of the Regulations before paragraph (a) is replaced by the following:

507.01 This Subpart applies in respect of aircraft — other than remotely piloted aircraft that are an element of a remotely piloted aircraft system in respect of which a design approval document has not been issued or applied for under Subpart 21 of this Part, ultra-light aeroplanes and hang gliders — that are

39 The portion of section 509.01 of the Regulations before paragraph (a) is replaced by the following:

509.01 This Subpart applies in respect of the following aircraft if they meet the export requirements specified in Chapter 509 of the Airworthiness Manual, except for aircraft that are operated under a special certificate of airworthiness in the owner-maintenance or amateur-built classification, remotely piloted aircraft that are an element of a remotely piloted aircraft system in respect of which a design approval document has not been issued or applied for under Subpart 21 of this Part, ultra-light aeroplanes and hang gliders:

40 The portion of section 571.01 of the Regulations before paragraph (a) is replaced by the following:

571.01 This Subpart applies in respect of maintenance and elementary work performed on the following aircraft, except for remotely piloted aircraft that are an element of a remotely piloted aircraft system in respect of which a design approval document has not been issued or applied for under Subpart 21 of this Part, ultra-light aeroplanes and hang gliders:

41 The heading before section 601.04 of the Regulations is replaced by the following:

Flight in Class F Special Use Restricted Airspace or Class F Special Use Advisory Airspace

42 Section 700.01.1 of the Regulations is replaced by the following:

700.01.1 This Part does not apply in respect of the operation of remotely piloted aircraft systems.

43 (1) The definitions autonomous, command and control link, control station, detect and avoid functions, first-person view device and flight termination system in section 900.01 of the Regulations are repealed.

(2) The definitions mandatory action, payload, visual line-of-sight or VLOS and visual observer in section 900.01 of the Regulations are replaced by the following:

mandatory action
means the inspection, repair or modification of a remotely piloted aircraft system that is necessary to prevent an unsafe or potentially unsafe condition. (mesure obligatoire)
payload
means a system, object or collection of objects, including a slung load, that is on board or is otherwise connected to a remotely piloted aircraft but that is not required for flight. (charge utile)
visual line-of-sight or VLOS
means unaided visual contact maintained with a remotely piloted aircraft in a manner sufficient to maintain control of the aircraft, know its location and scan the airspace in which it is operating in order to detect conflicting air traffic and other hazards and take action to avoid them. (visibilité directe ou VLOS)
visual observer
means a crew member who is trained to assist the pilot in ensuring the safe conduct of a flight. (observateur visuel)

(3) Section 900.01 of the Regulations is amended by adding the following in alphabetical order:

advertised event
means an outdoor event that is advertised to the general public, including a concert, festival, market or sporting event. (événement annoncé)
BVLOS
means beyond visual line-of-sight. (BVLOS)
BVLOS operation
means an operation of a remotely piloted aircraft that is not in visual line-of-sight, but does not include an extended VLOS operation or a sheltered operation. (opération en BVLOS)
contingency procedures
means the procedures to be followed to address conditions that could lead to an unsafe situation. (procédure de contingence)
contingency volume
means the area immediately surrounding the flight geography within which contingency procedures are intended to be used to return a remotely piloted aircraft to the flight geography or safely terminate the flight. (volume de contingence)
extended VLOS operation
means an operation of a remotely piloted aircraft that is not in visual line-of-sight but during which unaided visual contact is maintained with the airspace in which the aircraft is operating in a manner sufficient to detect conflicting air traffic and other hazards and take action to avoid them. (opération en VLOS prolongée)
flight geography
means the area within which a remotely piloted aircraft is intended to fly for a specific operation. (géographie de vol)
ground risk buffer
means the area immediately surrounding the contingency volume that, when measured horizontally from the perimeter of the contingency volume, is at least equal to the planned maximum altitude of the remotely piloted aircraft for the flight. (tampon de risque au sol)
medium remotely piloted aircraft
means a remotely piloted aircraft that has an operating weight of more than 25 kg (55 pounds) but not more than 150 kg (331 pounds). (aéronef télépiloté moyen)
operating weight
means the weight of a remotely piloted aircraft at any point during a flight, including any payload and any safety equipment that is on board or otherwise connected to the aircraft. (masse opérationnelle)
operational volume
means the area that is composed of the flight geography, contingency volume and ground risk buffer. (volume opérationnel)
populated area
means an area with more than five people per square kilometre. (zone peuplée)
RPAS ground school instruction
means instructor-led training given to one or more persons, delivered in-person or virtually, and provided through an organized program of lectures, homework or self-paced study. (instruction théorique au sol pour les SATP)
RPAS operations manual
means the manual established by an RPAS operator under section 901.217. (manuel d’exploitation de SATP)
RPAS operator
means the holder of an RPAS operator certificate. (exploitant de SATP)
RPAS operator certificate
means a certificate issued under section 901.214. (certificat d’exploitation de SATP)
sheltered operation
means an operation of a remotely piloted aircraft that is not in visual line-of-sight and during which the aircraft remains at a distance of less than 200 feet (61 m), measured horizontally, from a building or structure and at an altitude no greater than 100 feet (30 m) above that building or structure. (opération protégée)
small remotely piloted aircraft
means a remotely piloted aircraft that has an operating weight of at least 250 g (0.55 pounds) but not more than 25 kg (55 pounds). (petit aéronef télépiloté)
sparsely populated area
means an area with more than 5 but not more than 25 people per square kilometre. (zone peu densément peuplée)
Standard 922
means Standard 922 — RPAS Safety Assurance, published by the Department of Transport. (norme 922)
VLOS operation
means an operation of a remotely piloted aircraft in visual line-of-sight. (opération en VLOS)
Water Aerodrome Supplement
has the same meaning as in section 300.01. (Supplément hydroaérodromes)

44 The Regulations are amended by adding the following after section 900.02:

Delayed Application of Certain Provisions

900.02.1 Paragraph 901.26(b), subsections 901.30(2), 901.34(2), (3) and (4) and 901.47(3) and sections 901.74, 901.75, 901.88, 901.89, 901.91, 901.92, 901.95 and 901.96 do not apply until November 4, 2025.

45 Section 900.02.1 of the Regulations and the heading before it are repealed.

46 The heading “Division II — General Prohibition” before section 900.06 of the Regulations is replaced by the following:

Division II — General Operating and Flight Rules

47 The Regulations are amended by adding the following after section 900.06:

Inadvertent Entry Into Restricted Airspace

900.07 A person who operates a remotely piloted aircraft shall ensure that the appropriate air traffic control unit, flight service station or user agency is notified immediately any time the aircraft is no longer under the person’s control and inadvertently enters or is likely to enter into Class F Special Use Restricted airspace, as specified in the Designated Airspace Handbook.

Prohibition — Emergency Security Perimeter

900.08 (1) No person shall operate a remotely piloted aircraft over or within the security perimeter established by a public authority in response to an emergency.

(2) Subsection (1) does not apply to the operation of a remotely piloted aircraft for the purpose of an operation to save human life, a police operation, a fire-fighting operation or any other operation that is conducted in the service of a public authority.

Prohibition — Commercial Air Service

900.09 (1) Subject to subsections (2) and (3), no person shall operate a remotely piloted aircraft having an operating weight of 250 g (0.55 pounds) or more to provide a commercial air service unless that person is Canadian or an employee, an agent or mandatary or a representative of an RPAS operator.

(2) A person who does not meet the criteria referred to in subsection (1) may operate a remotely piloted aircraft to provide a specialty air service if

(3) A person that does not meet the criteria referred to in subsection (1) may operate a remotely piloted aircraft to provide an air transport service if the person holds a licence issued under section 61 of the Canada Transportation Act.

[900.10 to 900.12 reserved]

Division III — Registration of Remotely Piloted Aircraft

Registration

900.13 (1) Subject to subsection (2), no person shall operate a remotely piloted aircraft system that includes a remotely piloted aircraft having an operating weight of 250 g (0.55 pounds) or more unless the remotely piloted aircraft is registered in accordance with this Division.

(2) A person may operate a remotely piloted aircraft system that includes a remotely piloted aircraft that is not registered in accordance with this Division if the operation is conducted in accordance with a special flight operations certificate — RPAS issued under section 903.03.

Registration Number

900.14 No pilot shall operate a remotely piloted aircraft system unless the registration number referred to in paragraph 900.16(3)(a) is clearly visible on the remotely piloted aircraft.

Qualifications To Be Registered Owner of Remotely Piloted Aircraft

900.15 (1) Subject to subsection (2), a person is qualified to be the registered owner of a remotely piloted aircraft if they are

(2) No individual is qualified to be the registered owner of a remotely piloted aircraft unless that individual is at least 14 years of age.

Registration Requirements

900.16 (1) The Minister shall, on receipt of an application, register a remotely piloted aircraft if the applicant is qualified to be the registered owner of the aircraft.

(2) The application shall include the following information:

(3) On registering the remotely piloted aircraft, the Minister shall issue to the registered owner of the aircraft a certificate of registration that includes

Register of Remotely Piloted Aircraft

900.17 The Minister shall establish and maintain a register of remotely piloted aircraft in which there shall be entered, in respect of each aircraft for which a certificate of registration has been issued under section 900.16,

Cancellation of Certificate of Registration

900.18 (1) A registered owner of a remotely piloted aircraft shall, within seven days after becoming aware that any of the following events has occurred, notify the Minister that

(2) When an event referred to in subsection (1) has occurred, the certificate of registration in respect of the remotely piloted aircraft is cancelled.

(3) The certificate of registration of a remotely piloted aircraft is cancelled when

(4) For the purposes of this Division, an owner has legal custody and control of a remotely piloted aircraft when the owner has complete responsibility for the operation and maintenance of the remotely piloted aircraft system of which the aircraft is an element.

Change of Name or Address

900.19 The registered owner of a remotely piloted aircraft shall notify the Minister of any change in the name or address of the registered owner by not later than seven days after the change.

Access to Certificate of Registration

900.20 No pilot shall operate a remotely piloted aircraft system unless the certificate of registration issued in respect of the remotely piloted aircraft that is an element of the system is easily accessible to the pilot for the duration of the operation.

48 The heading “Subpart 1 — Small Remotely Piloted Aircraft” before section 901.01 of the Regulations is replaced by the following:

Subpart 1 — Small Remotely Piloted Aircraft and Medium Remotely Piloted Aircraft

49 Section 901.01 of the Regulations is replaced by the following:

901.01 This Subpart applies in respect of the operation of remotely piloted aircraft systems that include a small remotely piloted aircraft or a medium remotely piloted aircraft.

50 Division II of Subpart 1 of Part IX of the Regulations is replaced by the following:

Division II — [Reserved]

[901.02 to 901.10 reserved]

51 (1) Subsection 901.11(1) of the Regulations is replaced by the following:

901.11 (1) Subject to subsection (2), no pilot shall operate a remotely piloted aircraft system unless the pilot or a visual observer has the aircraft in visual line-of-sight.

(2) Subsection 901.11(2) of the Regulations is replaced by the following:

(2) A pilot may operate a remotely piloted aircraft system without the pilot or a visual observer having the aircraft in visual line-of-sight if the operation is one referred to in paragraph 901.62(b) or (c) that is conducted in accordance with Division V or is an operation referred to in section 901.87 that is conducted in accordance with Division VI or if the operation is conducted in accordance with a special flight operations certificate — RPAS issued under section 903.03.

52 Section 901.12 of the Regulations is replaced by the following:

[901.12 reserved]

53 Sections 901.13 to 901.15 of the Regulations are replaced by the following:

901.13 (1) Subject to subsection (2), no pilot operating a remotely piloted aircraft shall cause the aircraft to leave Canadian Domestic Airspace.

(2) A pilot may operate a remotely piloted aircraft outside of Canadian Domestic Airspace if the operation is conducted in accordance with a special flight operations certificate — RPAS issued under section 903.03.

Controlled Airspace

901.14 Subject to subsection 901.71(1), no pilot shall operate a remotely piloted aircraft in controlled airspace.

Inadvertent Entry into Controlled Airspace

901.15 A pilot of a remotely piloted aircraft shall ensure that the appropriate air traffic control unit, flight service station or user agency is notified immediately any time the aircraft is no longer under the pilot’s control and inadvertently enters or is likely to enter into controlled airspace.

54 Section 901.14 of the Regulations is replaced by the following:

901.14 No pilot shall operate a remotely piloted aircraft in controlled airspace except in accordance with

55 Subsection 901.20(1) of the Regulations is replaced by the following:

901.20 (1) No pilot shall operate a remotely piloted aircraft system if visual observers are used to assist the pilot in detecting and avoiding conflicting air traffic and other hazards unless reliable and timely communication is maintained between the pilot and each visual observer during the operation.

56 (1) Section 901.22 of the Regulations and the heading before it are replaced by the following:

Carriage of Persons

901.22 No pilot shall operate a remotely piloted aircraft that carries persons on board.

(2) Section 901.22 of the Regulations is replaced by the following:

901.22 No pilot shall operate a remotely piloted aircraft that carries persons on board except in accordance with a special flight operations certificate – RPAS issued under section 903.03.

57 (1) The portion of subsection 901.23(1) of the French version of the Regulations before paragraph (a) is replaced by the following:

901.23 (1) Il est interdit au pilote d’utiliser un système d’aéronef télépiloté, à moins que les procédures ci-après aient été établies :

(2) Subparagraph 901.23(1)(b)(ii) of the French version of the Regulations is replaced by the following:

(3) Paragragh 901.23(1)(b) of the Regulations is amended by striking out “and” at the end of subparagraph (v), by adding “and” at the end of subparagraph (vi) and by adding the following after subparagraph (vi):

(4) Subsection 901.23(2) of the Regulations is replaced by the following:

(2) If the manufacturer of the remotely piloted aircraft system or the person who has made a declaration referred to in section 901.194 in respect of that model of system provides instructions with respect to the topics referred to in paragraphs (1)(a) and (b), the procedures established under subsection (1) shall reflect those instructions.

58 Section 901.24 of the Regulations is replaced by the following:

901.24 A pilot of a remotely piloted aircraft shall, before commencing a flight, be familiar with the information that is relevant to the intended flight, including

59 Section 901.26 of the Regulations is replaced by the following:

901.26 Unless the operation is conducted under Division V, no pilot shall operate

60 Section 901.27 of the Regulations is replaced by the following:

901.27 No pilot shall operate a remotely piloted aircraft system unless, before commencing the operation, they determine that the operational volume is suitable by conducting a site survey that takes into account the following factors:

61 Paragraphs 901.29(b) to (d) of the Regulations are replaced by the following:

62 Section 901.30 of the Regulations and the heading before it are replaced by the following:

Availability of Manuals

901.30 (1) No pilot shall conduct the take-off or launch of a remotely piloted aircraft unless the operating manuals applicable to the remotely piloted aircraft system of which the aircraft is an element are immediately available to crew members.

(2) No pilot shall conduct the take-off or launch of a remotely piloted aircraft to conduct a BVLOS operation under Division VI unless the RPAS operator’s RPAS operations manual is immediately available to crew members.

63 Section 901.31 of the Regulations and the heading before it are replaced by the following:

Operating Manuals

901.31 No pilot shall operate a remotely piloted aircraft system unless it is operated in accordance with the applicable operating manuals.

64 Section 901.32 of the Regulations is replaced by the following:

901.32 No pilot shall operate a remotely piloted aircraft system that is not designed to allow pilot intervention in the management of a flight.

65 Section 901.34 of the Regulations is replaced by the following:

901.34 (1) No pilot shall operate a remotely piloted aircraft to conduct a VLOS operation unless the weather conditions at the time of flight permit

(2) If the ground visibility is four miles or less, no pilot shall operate a medium remotely piloted aircraft to conduct a VLOS operation at a distance of more than half of the ground visibility unless the operation is conducted in accordance with a special flight operations certificate — RPAS issued under section 903.03.

(3) Subject to subsection (4), no pilot shall operate a remotely piloted aircraft to conduct a BVLOS operation unless ground visibility is not less than three miles and the aircraft is operated clear of cloud.

(4) A pilot may operate a remotely piloted aircraft to conduct a BVLOS operation in cloud or when the ground visibility is less than three miles if

66 Section 901.35 of the Regulations is replaced by the following:

901.35 (1) No pilot shall operate a remotely piloted aircraft system when icing conditions are observed, are reported to exist or are likely to be encountered along the route of flight unless the aircraft is equipped with de-icing or anti-icing equipment or the pilot has a means to detect icing.

(2) No pilot shall operate a remotely piloted aircraft system with frost, ice or snow adhering to any of the critical surfaces of the remotely piloted aircraft.

(3) For the purposes of subsection (2), critical surfaces means the wings, control surfaces, rotors, propellers, horizontal stabilizers, vertical stabilizers or any other stabilizing surfaces of the remotely piloted aircraft, as well as any other surfaces identified as critical surfaces in the operating manuals applicable to the system.

67 (1) Section 901.38 of the Regulations is replaced by the following:

901.38 (1) No pilot shall operate a remotely piloted aircraft system using a first-person view device unless a visual observer maintains unaided visual contact with the airspace in which the remotely piloted aircraft is operating in order to detect conflicting air traffic and other hazards and take action to avoid them.

(2) For the purposes of subsection (1), first-person view device means a device that generates and transmits a streaming video image to a control station display or monitor, giving the pilot of a remotely piloted aircraft the illusion of flying the aircraft from an onboard pilot’s perspective.

(2) Subsection 901.38(1) of the Regulations is replaced by the following:

901.38 (1) Unless the operation is conducted under Division VI, no pilot shall operate a remotely piloted aircraft system using a first-person view device unless a visual observer maintains unaided visual contact with the airspace beyond the field of view displayed on the device in order to detect conflicting air traffic and other hazards and take action to avoid them.

68 The Regulations are amended by adding the following after section 901.38:

Anti-collision Lights

901.38.1 (1) Subject to subsection (3), no pilot shall operate a remotely piloted aircraft to conduct a BVLOS operation unless the aircraft is equipped with anti-collision lights and those lights are turned on.

(2) For the purposes of subsection (1), anti-collision lights shall

(3) Anti-collision lights may be turned off if the pilot determines that, because of operating conditions, doing so would be in the interests of aviation safety.

69 Subsection 901.39(1) of the Regulations is replaced by the following:

901.39 (1) No pilot shall operate a remotely piloted aircraft system at night unless the remotely piloted aircraft is equipped with lights that are sufficient to allow the aircraft to be visible to the pilot or a visual observer, whether with or without night-vision goggles, and those lights are turned on.

70 Sections 901.40 and 901.41 of the Regulations are replaced by the following:

901.40 (1) Subject to subsections (2) and (3), no pilot shall operate more than one remotely piloted aircraft at a time unless

(2) A pilot may operate more than five remotely piloted aircraft at a time if the operation is conducted in accordance with a special flight operations certificate — RPAS issued under section 903.03.

(3) A pilot may operate more than one remotely piloted aircraft at a time to conduct an operation that is not a VLOS operation if the operation is conducted in accordance with a special flight operations certificate — RPAS issued under section 903.03.

Advertised Events

901.41 (1) No pilot shall operate a remotely piloted aircraft system at any advertised event except in accordance with a special flight operations certificate — RPAS issued under section 903.03.

(2) Subsection (1) does not apply to the operation of a remotely piloted aircraft system for the purpose of an operation to save human life, a police operation, a fire-fighting operation or any other operation that is conducted in the service of a public authority.

71 Paragraph 901.42(a) of the French version of the Regulations is replaced by the following:

72 (1) Paragraph 901.43(1)(a) of the Regulations is repealed.

(2) Paragraph 901.43(1)(d) of the Regulations is replaced by the following:

73 Section 901.44 of the Regulations is replaced by the following:

901.44 No pilot shall activate a system that terminates the flight of a remotely piloted aircraft if it will endanger or will likely endanger aviation safety or the safety of any person.

74 Subsections 901.47(2) and (3) of the Regulations are replaced by the following:

(2) Subject to section 901.73, no pilot shall operate a remotely piloted aircraft to conduct a VLOS operation if the aircraft is at a distance of less than

(3) No pilot shall operate a remotely piloted aircraft to conduct a BVLOS operation if the aircraft is at a distance of less than five nautical miles from the centre of an aerodrome that is listed in the Canada Flight Supplement or the Water Aerodrome Supplement unless the operation is conducted in accordance with a special flight operations certificate — RPAS issued under section 903.03.

(4) No pilot shall operate a remotely piloted aircraft if the aircraft is at a distance of less than three nautical miles from the centre of an aerodrome operated under the authority of the Minister of National Defence unless authorized to do so by the Department of National Defence.

75 The reference “[901.50 to 901.52 reserved]” after section 901.49 of the Regulations is replaced by the following:

Dropping of Objects

901.50 No pilot shall create a hazard to persons or property on the surface by dropping an object from a remotely piloted aircraft in flight.

Service Difficulty Reporting

901.51 The pilot of a remotely piloted aircraft system of a model for which a declaration referred to in section 901.194 has been made and for which an acceptance letter has been issued under section 901.196 shall ensure that any reportable service difficulty that is discovered with respect to the system is reported to the person who has made the declaration as soon as feasible after the discovery.

[901.52 reserved]

76 Section 901.53 of the Regulations is replaced by the following:

901.53 This Division applies in respect of the operation of small remotely piloted aircraft to conduct a VLOS operation in uncontrolled airspace and at a distance of not less than 100 feet (30 m), measured horizontally and at any altitude, from any person not involved in the operation.

77 (1) Paragraph 901.54(1)(b) of the Regulations is replaced by the following:

(2) Subsection 901.54(2) of the Regulations is replaced by the following:

(2) Subsection (1) does not apply if the operation of the remotely piloted aircraft system is conducted under the direct supervision of a person who is permitted to operate such a system under this Division, Division V or Division VI.

78 Paragraph 901.55(b) of the Regulations is replaced by the following:

79 Subsection 901.56(1) of the Regulations is replaced by the following:

901.56 (1) No holder of a pilot certificate — small remotely piloted aircraft (VLOS) — basic operations, a pilot certificate — remotely piloted aircraft — advanced operations or a pilot certificate — remotely piloted aircraft — level 1 complex operations shall operate a remotely piloted aircraft system under this Division unless the holder has, within the 24 months preceding the flight,

80 (1) Paragraph 901.57(a) of the Regulations is replaced by the following:

(2) Paragraph 901.57(b) of the French version of the Regulations is replaced by the following:

81 Paragraph 901.58(b) of the Regulations is replaced by the following:

82 Section 901.59 of the Regulations and the heading before it are replaced by the following:

Retaking of Examination

901.59 No person who fails an examination taken under this Division shall retake the examination for a period of 24 hours after the examination.

83 Section 901.62 of the Regulations is replaced by the following:

901.62 This Division applies in respect of the following operations of a remotely piloted aircraft system:

84 (1) Paragraph 901.63(1)(b) of the Regulations is replaced by the following:

(2) Subsection 901.63(2) of the Regulations is replaced by the following:

(2) Subsection (1) does not apply if the operation of the remotely piloted aircraft system is conducted under the direct supervision of a person who is permitted to operate such a system under this Division or Division VI.

85 Paragraphs 901.64(b) and (c) of the Regulations are replaced by the following:

86 Subsection 901.65(1) of the Regulations is replaced by the following:

901.65 (1) No holder of a pilot certificate — remotely piloted aircraft — advanced operations or a pilot certificate — remotely piloted aircraft — level 1 complex operations shall operate a remotely piloted aircraft system under this Division unless the holder has, within the 24 months preceding the flight,

87 Paragraph 901.66(a) of the Regulations is replaced by the following:

88 Section 901.67 of the French version of the Regulations is replaced by the following:

901.67 Il est interdit d’accomplir les actes visés aux alinéas 901.58a) à c) relativement à l’examen visé à la présente section.

89 Sections 901.68 and 901.69 of the Regulations are replaced by the following:

901.68 No person who fails an examination or a flight review taken under this Division shall retake the examination or flight review for a period of 24 hours after the examination or review.

Declaration — Permitted Operations

901.69 No pilot shall operate a remotely piloted aircraft system under this Division to conduct any of the following operations unless a declaration to the Minister has been made in accordance with section 901.194 in respect of that model of system and in respect of each of the technical requirements set out in Standard 922 that is applicable to the operation:

90 Section 901.70 of the Regulations is replaced by the following:

901.70 (1) No pilot shall conduct any of the operations described in section 901.69 using a remotely piloted aircraft system that has been modified in any way unless

(2) No pilot shall conduct an operation described in paragraph 901.69(f) or (g) using a remotely piloted aircraft system that has been modified in any way unless the modification was performed in accordance with the instructions of the person who has made a declaration referred to in 901.194 in respect of that model of system.

91 (1) The portion of subsection 901.71(1) of the Regulations before paragraph (a) is replaced by the following:

901.71 (1) No pilot shall operate a remotely piloted aircraft in controlled airspace under this Division unless an authorization has been issued by the provider of air traffic services in the area of operation and, if requested, the following information has been provided to that provider:

(2) Paragraphs 901.71(1)(d) to (f) of the Regulations are repealed.

(3) Section 901.71 of the Regulations is amended by adding the following after subsection (2):

(3) No pilot shall operate a remotely piloted aircraft in controlled airspace under this Division unless the authorization referred to in subsection (1) is easily accessible to the pilot during the operation.

92 Section 901.73 of the Regulations is replaced by the following:

901.73 No pilot shall operate a remotely piloted aircraft system under this Division if the remotely piloted aircraft is at a distance of less than three nautical miles from the centre of an airport or less than one nautical mile from the centre of a heliport unless the operation is conducted in accordance with the established procedure with respect to the safe use of remotely piloted aircraft systems that is applicable to that airport or heliport.

93 The reference “[901.74 and 901.75 reserved]” after section 901.73 of the Regulations is replaced by the following:

Extended VLOS Operations and Sheltered Operations

901.74 (1) No pilot shall operate a remotely piloted aircraft system under this Division to conduct an extended VLOS operation or a sheltered operation unless

(2) No pilot shall operate a remotely piloted aircraft system under this Division to conduct an extended VLOS operation unless a visual observer maintains unaided visual contact with the airspace in which the remotely piloted aircraft is operating in a manner sufficient to detect conflicting air traffic and other hazards and take action to avoid them.

Visual Observers

901.75 No visual observer shall perform visual observer duties with respect to an extended VLOS operation under this Division unless they

[901.76 to 901.86 reserved]

94 Divisions VI and VII of Subpart 1 of Part IX of the Regulations are replaced by the following:

Division VI — Level 1 Complex Operations
Application

901.87 This Division applies in respect of the following operations of a remotely piloted aircraft system:

Requirement for RPAS Operator Certificate

901.88 No person shall operate a remotely piloted aircraft system under this Division unless the person

Pilot Requirements

901.89 (1) Subject to subsection (2), no person shall operate a remotely piloted aircraft system under this Division unless the person

(2) Subsection (1) does not apply if the operation of the remotely piloted aircraft system is for the purpose of training and is conducted under the direct supervision of a person who is 18 years of age or older and who is permitted to operate a remotely piloted aircraft system under this Division.

Issuance of Pilot Certificate — Remotely Piloted Aircraft — Level 1 Complex Operations

901.90 The Minister shall, on receipt of an application, issue a pilot certificate — remotely piloted aircraft — level 1 complex operations if the applicant demonstrates to the Minister that the applicant

Recency Requirements

901.91 No holder of a pilot certificate — remotely piloted aircraft — level 1 complex operations shall operate a remotely piloted aircraft system under this Division unless the holder has, within the 24 months preceding the flight,

Access to Certificate and Proof

901.92 No pilot shall operate a remotely piloted aircraft system under this Division unless the following are easily accessible during the operation:

Examination Rules

901.93 No person shall commit an act referred to in paragraphs 901.58(a) to (c) in respect of an examination taken under this Division.

Retaking of an Examination or Flight Review

901.94 No person who fails an examination or a flight review taken under this Division shall retake the examination or flight review for a period of 24 hours after the examination or review.

Declaration — Permitted Operations

901.95 (1) No pilot shall operate a remotely piloted aircraft system under this Division unless a declaration to the Minister has been made in accordance with section 901.194 in respect of that model of system and in respect of each of the technical requirements set out in Standard 922 that is applicable to the operation.

(2) Despite subsection (1), a pilot may operate a remotely piloted aircraft system under this Division without a declaration having been made in respect of the technical requirements set out in section 922.10 of Standard 922 if a visual observer maintains unaided visual contact with the airspace in which the remotely piloted aircraft is operating in a manner sufficient to detect conflicting air traffic and other hazards and take action to avoid them and the operation is conducted in accordance with the Standard 923 — Vision-Based Detect and Avoid.

Operation of a Modified Remotely Piloted Aircraft System

901.96 (1) No pilot shall operate a remotely piloted aircraft system under this Division if the system has been modified in any way unless

(2) No pilot shall conduct an operation described in paragraph 901.87(b) using a remotely piloted aircraft system that has been modified in any way unless the modification was performed in accordance with the instructions of the person who has made a declaration referred to in section 901.194 in respect of that model of system.

[901.97 to 901.109 reserved]

Division VII — [Reserved]

[901.110 to 901.132 reserved]

Division VIII — [Reserved]

[901.133 to 901.155 reserved]

Division IX — [Reserved]

[901.156 to 901.174 reserved]

Division X — Training and Flight Review
Prohibition — Flight Reviewer

901.175 (1) No person shall perform the duties of a flight reviewer for a flight review referred to in paragraph 901.64(c) unless that person

(2) No person shall perform the duties of a flight reviewer for a flight review referred to in paragraph 901.90(e) unless that person

Flight Reviewer Rating

901.176 The Minister shall, on receipt of an application, endorse the applicant’s pilot certificate with a flight reviewer rating if the applicant demonstrates to the Minister that the applicant

Examination Rules

901.177 No person shall commit an act referred to in paragraphs 901.58(a) to (c) in respect of an examination referred to in paragraph 901.176(d).

Retaking of Examination

901.178 No person who fails an examination referred to in paragraph 901.176(d) shall retake the examination for a period of 24 hours after the examination.

Eligibility to Make Declaration

901.179 A training provider is eligible to make a declaration to the Minister in accordance with the requirements of section 921.05 or 921.08 of Standard 921 — Remotely Piloted Aircraft if the training provider is Canadian.

Training Provider Requirements — Flight Reviews

901.180 A training provider that has made a declaration referred to in paragraph 901.175(1)(b) or (2)(b) shall

Conduct of Flight Reviews

901.181 No person shall conduct a flight review referred to in paragraph 901.64(c) or 901.90(e) unless the review is conducted in accordance with section 921.06 of Standard 921 — Remotely Piloted Aircraft.

Training Provider Requirements — RPAS Ground School Instruction

901.182 (1) No training provider shall deliver the RPAS ground school instruction referred to in paragraph 901.90(c) unless the training provider

(2) A training provider shall inform the Minister within 30 days after any change in the appointment of a chief ground instructor.

Requirements for Chief Ground Instructor

901.183 No person shall act as chief ground instructor unless the person holds a pilot certificate — remotely piloted aircraft — level 1 complex operations issued under section 901.90 and endorsed with a flight reviewer rating under section 901.176.

Proof of Ground Instruction

901.184 A training provider shall provide written proof of completion to every person who completes the RPAS ground school instruction referred to in paragraph 901.90(c).

[901.185 to 901.193 reserved]

Division XI — RPAS Declaration
Declaration

901.194 (1) A person who makes a declaration to the Minister in respect of a model of remotely piloted aircraft system and in respect of any technical requirement set out in Standard 922 shall do so in accordance with subsection (2).

(2) The declaration shall

(3) In the case of a model of remotely piloted aircraft system that is intended to conduct any of the operations described in paragraph 901.69(f) or (g) or 901.87(b), no person shall provide the Minister with a declaration referred to in subsection (1) unless an acceptance letter has been issued in respect of that model of system under section 901.196 in the two years before the making of the declaration.

(4) The declaration is invalid if

(5) In the case referred to in paragraph (4)(b) in respect of a notification referred to in paragraph 901.195(1)(b), the declaration is only invalid with respect to the operations described in paragraphs 901.69(f) and (g) and 901.87(b).

(6) In the case referred to in paragraph (4)(c), the declaration is only invalid with respect to the operations described in paragraphs 901.69(f) and (g) and 901.87(b) and only for the period during which the annual report is outstanding.

(7) A person who has made a declaration shall notify the Minister within 30 days after any change to the names, address or contact information referred to in paragraph (2)(a).

Notice to the Minister

901.195 (1) A person who has made a declaration referred to in section 901.194 shall notify the Minister of

(2) The person shall notify the Minister, in the case referred to in paragraph (1)(a), as soon as feasible after the deficiency is identified and, in the case referred to in paragraph (1)(b), on the day on which the person ceases to maintain the service difficulty reporting system.

Issuance of Acceptance Letter

901.196 (1) The Minister shall, on receipt of an application containing the information set out in subsection (2), issue an acceptance letter to the applicant in respect of a model of remotely piloted aircraft system that is the subject of the application, if the applicant demonstrates the ability to

(2) The applicant shall provide the following information:

Establishing a Service Difficulty Reporting System

901.197 (1) If a declaration referred to in section 901.194 is made in respect of a model of remotely piloted aircraft system for which an acceptance letter has been issued under section 901.196, the person who has made the declaration shall establish and maintain a service difficulty reporting system for the purpose of receiving, recording, analyzing and investigating reports and information concerning any reportable service difficulty related to that model.

(2) The service difficulty reporting system shall include

Investigation of Service Difficulty Reports

901.198 If a person receives a service difficulty report in respect of a model of remotely piloted aircraft system for which they have made a declaration referred to in section 901.194 and for which an acceptance letter has been issued under section 901.196, that person shall investigate the service difficulty and, if it results from a deficiency in the model that causes the system to no longer meet the technical requirements specified under subparagraph 901.194(2)(a)(iv), develop a mandatory action to rectify the deficiency.

Annual Report

901.199 (1) A person who has made a declaration referred to in section 901.194 in respect of a model of remotely piloted aircraft system for which an acceptance letter has been issued under section 901.196 shall submit to the Minister an annual report in respect of that model.

(2) The annual report shall include

(3) The annual report shall be submitted to the Minister each year by not later than the anniversary of the day on which the declaration referred to in section 901.194 was made.

Documentation

901.200 A person who has made a declaration referred to in section 901.194 in respect of a model of remotely piloted aircraft system shall make available to each user of that model of system

Record-keeping

901.201 (1) A person who has made a declaration referred to in section 901.194 in respect of a model of remotely piloted aircraft system shall keep, and make available to the Minister on request, a record of

(2) The person shall keep the records referred to in subsection (1) for the later of

[901.202 to 901.212 reserved]

Division XII — RPAS Operator Certificate
Eligibility to Hold an RPAS Operator Certificate

901.213 A person is eligible to hold an RPAS operator certificate if

Issuance

901.214 The Minister shall, on receipt of an application containing the following information, issue an RPAS operator certificate:

Contents of RPAS Operator Certificate

901.215 An RPAS operator certificate shall contain the following information:

General Conditions of RPAS Operator Certificate

901.216 The general conditions of an RPAS operator certificate are the following:

RPAS Operations Manual

901.217 (1) Every RPAS operator shall establish and maintain an RPAS operations manual that consists of the following information:

(2) If there is a change in any aspect of an RPAS operator’s operations or the RPAS operations manual no longer meets the requirements of subsection (1), the RPAS operator shall amend its operations manual.

(3) An RPAS operator shall provide a copy of its RPAS operations manual and a copy of every amendment to that manual to every person who is involved in the RPAS operator’s operations.

(4) An RPAS operator shall provide a copy of its RPAS operations manual to the Minister on request.

Processes

901.218 (1) An RPAS operator shall establish and maintain processes for

(2) The processes required under subsection (1) shall be under the control of the accountable executive appointed by the RPAS operator under paragraph 106.02(1)(a).

Training Program

901.219 (1) Every RPAS operator shall establish and maintain a training program that is designed to ensure that each person who receives training acquires the competence to perform their assigned duties.

(2) An RPAS operator’s training program shall include

(3) An RPAS operator shall ensure that any training provided to meet the requirements of this section is based on the content of the RPAS operator’s training program.

(4) No RPAS operator shall permit a person to act, and no person shall act, as an instructor unless

(5) No RPAS operator shall permit a person to act, and no person shall act, as an instructor unless the person has received, before the day on which the person begins to act as an instructor, training that includes the following elements:

Person Responsible for RPAS Maintenance

901.220 (1) An RPAS operator shall appoint a person responsible for RPAS maintenance.

(2) The person responsible for RPAS maintenance shall plan and oversee the maintenance of the RPAS operator’s remotely piloted aircraft systems, including coordinating maintenance arrangements with third-party maintenance providers.

Maintenance Control Manual (MCM)

901.221 (1) An RPAS operator shall establish and maintain a maintenance control manual that includes

(2) The RPAS operator shall ensure that the maintenance control manual is made available to the Minister on request.

Designation of Pilot-in-Command

901.222 An RPAS operator shall designate a pilot-in-command for each operation conducted under Division VI.

Records

901.223 (1) Every RPAS operator shall keep the following records:

(2) Every RPAS operator shall ensure that the records are made available to the Minister on request and are retained for a period of

95 (1) Section 903.01 of the Regulations is replaced by the following:

903.01 No person shall conduct any of the following operations using a remotely piloted aircraft system unless the person complies with the provisions of a special flight operations certificate — RPAS issued by the Minister under section 903.03:

(2) Paragraph 903.01(a) of the Regulations is replaced by the following:

(3) Paragraph 903.01(c) of the Regulations is replaced by the following:

96 The portion of section 903.02 of the Regulations before paragraph (a) is replaced by the following:

903.02 An application for a special flight operations certificate — RPAS shall be submitted to the Minister and include the following information:

97 Sections 903.02 and 903.03 of the Regulations are replaced by the following:

903.02 (1) For the purpose of an application for a special flight operations certificate — RPAS, the operation, other than for the purpose of providing a commercial air service, of a remotely piloted aircraft system that includes a remotely piloted aircraft that is not registered in accordance with Division III is a very low-complexity operation.

(2) For the purposes of an application for a special flight operations certificate — RPAS, the operation of a remotely piloted aircraft system at an advertised event is a low-complexity operation.

(3) For the purpose of an application for a special flight operations certificate — RPAS, the following operations are medium-complexity operations:

(4) For the purpose of an application for a special flight operations certificate — RPAS, the following operations are high-complexity operations:

(5) If the application for a special flight operations certificate — RPAS is in respect of several operations, the highest complexity level applies except in the case of an application in respect of two or more medium-complexity operations, in which case the application is deemed to be in respect of a high-complexity operation.

(6) A person who proposes to operate a remotely piloted aircraft system to conduct very low-complexity or low-complexity operations shall apply to the Minister for a special flight operations certificate — RPAS by submitting the following information:

(7) A person who proposes to operate a remotely piloted aircraft system to conduct medium-complexity or high-complexity operations shall apply to the Minister for a special flight operations certificate — RPAS by submitting the following information:

Application to Amend a Special Flight Operations Certificate — RPAS

903.02.1 (1) The holder of a special flight operations certificate — RPAS may apply to the Minister to amend the certificate to change

(2) An application to amend a special flight operations certificate — RPAS shall include the following information:

Issuance or Amendment of Special Flight Operations Certificate — RPAS

903.03 The Minister shall, on receipt of an application submitted in accordance with section 903.02 or 903.02.1, issue or amend a special flight operations certificate — RPAS if the applicant demonstrates to the Minister the ability to perform the proposed operations without adversely affecting aviation safety or the safety of any person.

Contents of Special Flight Operations Certificate — RPAS

903.04 A special flight operations certificate — RPAS shall contain the following information:

98 The Regulations are amended by replacing “pilot certificate — small remotely piloted aircraft (VLOS) — advanced operations” with “pilot certificate — remotely piloted aircraft — advanced operations” in the following provisions:

Transitional Provisions

99 (1) The charge that applies in respect of the issuance of a special flight operations certificate — RPAS, the application for which is submitted before the day on which section 32 comes into force, is that which applies on the day on which the application was submitted.

(2) For the purpose of subsection (1), the application is considered to be submitted on the day on which it is delivered or, if it is sent by mail, the day on which it is mailed, with the date of the postmark being evidence of that day.

Coming into Force

100 (1) Subject to subsection (2), these Regulations come into force on April 1, 2025, but if they are published in the Canada Gazette, Part II, after that day, they come into force on the day on which they are published.

(2) Sections 11, 22 and 23, subsection 31(2), sections 32 and 45, subsection 51(2), section 54, subsection 56(2), sections 60 and 63, subsection 67(2), section 68, subsections 72(1) and 95(2) and (3) and section 97 come into force on November 4, 2025.

REGULATORY IMPACT ANALYSIS STATEMENT

(This statement is not part of the Regulations.)

Executive summary

Issues: Technological advancements continue to emerge in the remotely piloted aircraft systems (RPAS) sector with the development of larger systems and higher levels of automation that have the potential to create new economic opportunities and perform tasks more quickly and safely than a person or other mode of transportation, often at a lower cost. The Government of Canada (GoC) introduced the first set of RPAS rules in 2019, which addressed safety concerns and created a flexible and predictable environment for small RPAS flown within visual line-of-sight (VLOS). However, the pace of technology has continued to accelerate since then, and industry has confirmed that a lack of regulations for medium-sized RPAS and beyond visual line-of-sight (BVLOS) operations is a key barrier to economic growth in the sector. To date, BVLOS operations and flying medium-sized RPAS can only be done through a case-by-case approval process, which can be time consuming and result in administrative burden for the RPAS industry. A more flexible and responsive regulatory environment is needed for the industry to continue to develop.

To unlock the potential of medium-sized RPAS and beyond visual line-of-sight operations, regulatory amendments are needed to allow more routine operations, provide regulatory predictability, and support economic growth. This will help the Canadian RPAS industry to remain competitive in the global market.

Description: The Regulations Amending the Canadian Aviation Regulations (RPAS – Beyond Visual Line-of-Sight and Other Operations) (the Regulations) will allow operations with a remotely piloted aircraft up to 150 kg to be flown within visual line-of-sight and introduce rules for routine beyond visual line-of-sight operations with a remotely piloted aircraft of up to 150 kg over sparsely populated areas, at low altitudes, and in uncontrolled airspace. The Regulations will remove the requirement for a Special Flight Operations Certificate (SFOC) for these operations. The Regulations include requirements for a new pilot certification, new technical standards for the aircraft and supporting systems, new operational procedures, such as increased distances from airports, heliports, and people, as well as new requirements for individuals and organizations to operate BVLOS. In addition, the Regulations will update existing service fees and introduce fees for existing services that are currently provided for free and the new services that will be provided to the RPAS sector.

Rationale: The RPAS sector is quickly advancing, bringing forward new use cases including package delivery to remote communities; assessing a fire for hot spots; environmental impact assessments; and infrastructure inspections that can be done more efficiently and effectively than if carried out by a traditional aircraft, other modes of transportation or by a person. Over the last five years, Transport Canada (TC) has carried out pilot projects, collaborated on research and development with the National Research Council, and issued hundreds of SFOCs to gain the insight required to develop a safety framework that provides both flexibility and predictability for RPAS operators, while promoting economic growth and innovation.

Costs for the Regulations are expected to total $26.61 million (present value in 2023 Canadian dollars, discounted to the base year of 2025 at a 7% rate) over a ten-year timeframe from 2025 to 2034. Costs will apply to industry primarily for maintenance and certification requirements, as well as increased operating costs. Costs will apply to the GoC for the maintenance of an online service platform, the Drone Management Portal (DMP), as well as stakeholder engagement and regulatory enforcement. The total benefits, which are estimated to be $73.65 million (present value in 2023 Canadian dollars, discounted to the base year of 2025 at a 7% rate) over the 10-year timeframe, will result primarily from enabling high-value RPAS operations, eliminating the need for SFOCs for certain RPAS operations, increased profits for domestic RPAS manufacturers, and increased recreational pilot activities. The Regulations are therefore expected to result in an overall monetized net benefit of $47.04 million (present value in 2023 Canadian dollars, discounted to the base year of 2025 at a 7% rate) between 2025 and 2034. Costs and benefits are expressed in 2023 dollars discounted to the base year of 2025 at a 7% rate.footnote 2

The “one-for-one-rule” applies since there will be an incremental decrease in administrative burden on business, which is considered burden “out” under the rule. The Regulations are expected to decrease the administrative burden on affected stakeholders by an annualized total of $396,526 in 2012 dollars, discounted to 2012 at a 7% rate. No regulatory titles are repealed or introduced. Analysis under the small business lens concluded that the Regulations will impact small businesses. There will be an estimated 33 675 small businesses affected, with an anticipated net benefit of $46.34 million over the ten-year timeframe, in 2023 dollars discounted to 2025 at a 7% rate.

TC has consulted extensively with other civil aviation authorities around the world to harmonize approaches to rulemaking where possible. To date, TC’s approach to regulating domestic operations has been comparable to other countries, such as the United States (U.S.), Brazil, the European Union (EU), and Australia.

Issues

The RPAS industry (also known as the drone industry) continues to grow quickly in Canada and across the globe — it is projected to increase globally from $22.5 billion USD in 2020 to $54.6 billion USD in 2030 (The Global Drone Market Report 2023-2030, 2024). The technology and different use cases for drones continue to outpace GoC regulations. New regulations are required to support the industry and allow more complex operations on a routine basis. Existing regulations allow for small drones to be flown within VLOS; however, to operate BVLOS and to fly medium-sized drones, operators have to first obtain an SFOC. This process, which is done on a case-by-case basis, can be time-consuming for applicants and departmental officials and can result in negative economic impacts, including administrative burden, for the drone industry.

In 2019, TC published the Transportation Sector Regulatory Roadmap in response to the first round of the Treasury Board Secretariat’s (TBS) targeted Regulatory Reviews. Through the Review, stakeholders stated that the lack of regulations for BVLOS operations was a barrier to economic growth in the drone industry. Additionally, a 2019 study by Avascent surveyed 15 different Canadian industries using drones, including agriculture, mining, academia, real estate, and law enforcement, and found that 80% of respondents reported that a lack of regulations for BVLOS was a barrier affecting the sector’s growth. Industry also expressed interest in a more predictable regulatory environment for testing larger aircraft (greater than 25 kg) within VLOS to develop new technologies in a timely, cost-effective way.

To ensure safe drone operations as the sector and technology rapidly evolve and grow, the GoC needs to take a proactive and iterative approach to regulating by introducing a series of rules over time that incrementally allow more complex operations. This will enable a competitive Canadian market and support innovation in Canada. Without regulatory predictability, there is a risk that the RPAS industry could move outside of Canada to remain economically viable.

The GoC promotes a balanced approach to financing government programs whereby those who benefit from program services pay a share of the costs for those services. Although fees were introduced in 2019 for TC’s VLOS drone services (e.g., registration), SFOCs have been issued at no charge to the applicant, meaning the cost of delivering this service is borne by the Canadian taxpayer not the beneficiary of the service. The Regulations include fees for RPAS services, including SFOCs, to better align with the user-pays principle.

Background

Drone technologies are changing the way people work in industries including agriculture, mining, search and rescue, infrastructure inspection, photography, and filmmaking. For example, a drone can be used to collect data more efficiently to inform precision agriculture or keep a person out of harm’s way when assessing a fire for hot spots before sending in firefighters. The use of a drone versus a traditional aircraft in some situations, such as to inspect a bridge, power line or pipeline, can be less costly, less time-consuming, and safer because the pilot can remain on the ground. Drones are also regularly used by first responders to find missing people, locate suspects, and transport first aid supplies in emergencies. Flying drones has also become a new hobby for new and old aviation enthusiasts alike for taking photos and drone racing.

Canadian civil aviation is the responsibility of the Minister of Transport under the Aeronautics Act. Under the Act, the Minister is responsible for the development of regulations governing aeronautics and the supervision of all matters connected with aeronautics. In 2019, the GoC published the first set of rules in Canada for drones within VLOS that weigh up to and including 25 kg with the creation of Part IX of the Canadian Aviation Regulations (CARs). These rules established the baseline that future regulatory projects — including the current Regulations —will build from as Canada works towards incrementally integrating increasingly complex RPAS technologies into the transportation system. To support the implementation of Part IX, TC developed an online system — the Drone Management Portal — where Canadians can register their drone, take a pilot exam, receive their pilot certificates, as well as submit their payment for services. At the end of 2024, there were nearly 108 000 small drones that have been registered with TC, compared to 37 000 registered traditional aircraft, and over 130 000 pilot certificates issued to drone pilots across Canada.

Prior to Part IX of the CARs, the only way to fly a drone commercially was to obtain an SFOC, which is reviewed and approved on a case-by-case basis, and recreational activities were subject to an Interim Order, which laid out a temporary set of rules. The Part IX VLOS rules reduced the need for SFOC applications by establishing a threshold below which an SFOC was not required, thereby enabling growth in the industry. However, technological advancements have led to an increase in requests for SFOC approvals for more complex operations.

Drone use cases are constantly evolving and expanding. There is great potential to use regulations to support the safe and predictable integration of drones into the broader aviation system while encouraging innovation and development in the drone industry. BVLOS operations are the future of drones and the introduction of routine operations in lower-risk environments will promote innovation and the development of new drone technologies so that the industry can move towards more complex operations and integrate within the broader aviation system. Larger drones and BVLOS operations can cover more geographic area in a shorter period and can also collect more data in fewer deployments compared to VLOS operations.

The Ontario Society of Professional Engineers has reported that the use of drone services could benefit industries in Canada that currently contribute over $600 billion to Canada’s national gross domestic product. In the province of Ontario alone, the aerospace industry created over 22 000 jobs in 2019. The Government of Québec also dedicated funding to support the development of a commercial drone cluster in the province’s 2016–2026 aerospace strategy, recognizing the potential and capabilities of the drone industry. On May 21, 2024, the Quebec government announced Quebec’s fourth innovation zone, Espace Aéro, stating it will invest $85 million to enhance Quebec’s attractiveness in the aerospace field and make it a world leader in sustainability and advanced air mobility.

Since 2020, TC has worked with industry on BVLOS pilot projects, trials, and research and development related to topics, such as collision avoidance, understanding the impacts of weather on drone flights, and collision impact testing, while also issuing SFOCs for lower-risk BVLOS operations. TC used the Joint Authorities for Rulemaking on Unmanned Systems’ (JARUS) internationally recognized Specific Operational Risk Assessment (SORA) to develop a safety framework for medium-sized drones and lower-risk BVLOS. The SORA is a risk assessment tool that considers things such as altitude, type of airspace, and ability to detect and avoid other aircraft. To date, TC has approved over 335 SFOCs for lower-risk BVLOS operations. The knowledge gained through working with industry, pilot projects, and research and development, has provided TC with the insights needed to develop a safe, predictable, and effective regulatory framework for lower-risk BVLOS operations.

As it continues to grow, the drone industry is expected to contribute to the creation of new jobs and opportunities in different sectors, such as forestry, mining, and environmental protection, as well as supporting delivery to remote and Indigenous communities and strengthening the supply chain. Growth in the drone industry is also expected to result in cost savings to companies as tasks, such as data collection, could be done more efficiently. Likewise, increased drone use is expected to reduce risks associated with dangerous tasks. While COVID-19 significantly impacted the traditional aviation industry, the drone industry has continued to grow. In 2024, NAV CANADA, Canada’s air navigation services provider, reported a 22% average annual increase in authorizations for drones to access controlled airspace since 2020.

The implementation of a new regulatory framework for medium-sized drones and lower-risk BVLOS operations will support growth and investment in the Canadian economy. It will also allow TC to shift resources towards issuing SFOCs for more complex operations — e.g., in urban centres, at higher altitudes, or for larger aircraft — and integration with the broader aviation sector.

Fee modernization, the Service Fees Act and the Directive on Charging and Special Financial Authorities

The Regulations will introduce new services and fees that support the expanded RPAS framework. Fee modernization is a priority across the GoC, as evidenced by the introduction of the Service Fees Act (SFA) in Budget 2017. The SFA signals that the GoC supports departments and agencies updating the fees they charge for products and services. It also represents the GoC’s commitment to modernizing its services and delivering value to Canadians by establishing service standards, remitting a portion of fees paid to clients when service standards are not met, adjusting fees annually by the consumer price index, and publishing the performance results for the public through annual reporting.

The modernization of TC’s fee regimes is aligned with the goals of Transportation 2030: A Strategic Plan for the Future of Transportation in Canada, a modernization initiative championed by the Minister of Transport. TC’s service and fee regimes in several business areas are being updated in consultation with stakeholders to provide more predictable service to industry, ensure the sustainability of TC services, and ensure that those who benefit from services pay a higher share of the costs for services.

The current fee regime for RPAS services and activities was created in 2019 to support the VLOS regulations. The Regulations will build on this to recover a greater share of the cost of administering drone registration, as well as look to recover fees for new services, such as examination and certification functions that support both VLOS and BVLOS operations, as well as the delivery of other services that would be provided to support the expanded RPAS framework, such as issuing SFOCs.

The Regulations adhere to the requirements of the Directive on Charging and Special Financial Authorities, which, among other things, outlines management practices and controls to ensure that charging practices for services are consistent across government and that amounts charged respect legislative limits. In accordance with the Directive, TC developed and published a fee proposal on the new and updated RPAS fees and held public consultations in the spring of 2021.

Objective

The Regulations have three objectives:

Regulatory predictability, economic growth, and innovation

The Regulations aim to support economic growth and innovation, reflect technological advancements, and allow the Canadian drone industry to remain competitive in the global drone market while permitting the safe use and testing of drones in lower-risk environments. To do this, the Regulations will move away from the case-by-case treatment of certain drone operations by replacing SFOC requirements for medium drones within VLOS and lower-risk BVLOS operations with a new regulatory framework. This will provide a predictable and flexible regulatory environment for the drone industry, supporting long-term investment planning while reducing costly administrative burdens on business.

Safety risk mitigation

The Regulations also aim to mitigate risks to other airspace users and people on the ground while permitting the safe use and testing of RPAS in lower-risk environments and ensuring that pilots have a relevant knowledge base. The Regulations focus on safety rules for the pilot, the product, procedures, and the organization.

Fee modernization

The modernization of TC’s fee regime is a key component of the department’s transformation plan. TC’s service and fee regime is being updated in consultation with stakeholders to provide more predictable service to industry; ensure the sustainability of TC services; and ensure that those who benefit from services pay a higher share of the costs for services.

In line with TC’s Fee Modernization Initiative, the Regulations introduce new fees and updated fees for services related to drone activities. These fees aim to recover a share of the costs of TC providing services to those who benefit from the activities, including the costs of administering drone registration, examination, and certification, as well as the delivery of other services that will be provided to support the program, such as issuing SFOCs.

Description

Scope

The Regulations build upon Part IX of the CARs and introduce new requirements to reflect the increased risks of the two new categories of operation:

The new requirements can be grouped into “the 3 Ps”: the Pilot (pilot training and certification), the Product (aircraft and supporting systems) and the Procedures (operational rules). In addition, there are new requirements for individuals and organizations operating BVLOS, such as appointing an accountable executive, and requirements to establish training programs and risk management processes, which are discussed in more detail below. These new requirements will allow for clearer organizational oversight with larger-scale operations, covering larger geographic areas, as well as an increase in the number and types of drones being operated.

Clarifying Canadian ownership requirements for commercial air services

The Regulations will clarify the ownership requirements to operate drones commercially in Canada, aligned with the existing rules for traditional aviation. To offer a commercial air service (any use of an aircraft for hire or reward) in Canada a person will need to be:

In addition, if a drone is carrying cargo, the operator would continue to be subject to the definition of “Canadian” under the Canadian Transportation Act (CTA) and must apply for an economic license from the Canadian Transportation Agency.

Non-Canadian operators from countries with whom Canada has a trade agreement in place may obtain authorization to perform specialty air services via an SFOC. “Specialty air services” means aerial mapping, aerial surveying, aerial photography, forest fire management, firefighting, aerial advertising, glider towing, parachute jumping, aerial construction, heli-logging, aerial sightseeing, flight training, aerial inspection, and surveillance and aerial spraying services. Individuals from countries with whom Canada does not have a trade agreement, who are looking to operate commercially, could apply for an exemption to the ownership requirements by contacting Transport Canada Civil Aviation. Non-Canadian operators wishing to fly their drone for recreational purposes will not be subject to the above requirements but will still require an SFOC to operate in Canada.

Incorporation by Reference

There are three standards developed by TC and two TC publications (TPs) that will be incorporated by reference, as amended from time to time, in the Regulations. Incorporation by Reference (IBR) is a term used to describe a mechanism which allows a document or list that is not in the text of regulations to be made a part of those regulations. An incorporated document typically provides more detail about how to comply with the regulations to which it has been incorporated. The incorporation of these elements is consistent with the scope of authority of the enabling statute (the Aeronautics Act) and these documents and standards can be properly characterized as elaborating on the regulations. The documents incorporated by reference are the following:

  1. Standard 921 — Remotely Piloted Aircraft
    • This standard is already incorporated under Part IX of the CARs and has been updated to support new pilot certification and training provider requirements.
  2. Standard 922 — RPAS Safety Assurance
    • This standard is already incorporated under Part IX of the CARs and has been updated to support the new technical requirements for the RPA.
  3. Standard 923 — Vision-Based Detect and Avoid
    • This is a new standard that has been developed to support the detection and avoidance of other aircraft.
  4. TP 15263 — Knowledge Requirements for Pilots of Remotely Piloted Aircraft Systems, 250 g up to and including 150 kg, Basic and Advanced Operations
    • This is an existing TC publication, which is already incorporated under Part IX of the CARs, and a new version has been developed to reflect the new knowledge requirements for the Advanced Pilot Certificate.
  5. TP 15530 — Knowledge Requirements for Pilots of Remotely Piloted Aircraft Systems — Level 1 Complex Operations
    • This is a new TC publication that has been developed to support the new knowledge requirements for Level 1 Complex operations.

All the standards and TPs are available on TC’s website. Once the Regulations are in force, TC will continue to monitor industry developments, including any new information from standard-setting bodies and the safety performance of operations subject to the new standards, and assess whether any standards need to be updated. Updates will be communicated to and consulted on with stakeholders via TC’s Canadian Aviation Regulation Advisory Council (CARAC) and posted on TC’s website.

The pilot

Expanding privileges for Advanced Pilot Certificates

Part IX of the CARs has created a strong safety baseline with no fatalities or serious injuries since coming into force in 2019. Since 2020, TC has monitored the way the industry has developed and, after re-examining the knowledge required to obtain an Advanced Pilot Certificate, TC has determined that the following operations may be added to the types of operations conducted by Advanced Pilot Certificate holders without the requirement to obtain a new pilot certificate:

The additional operating rules to mitigate risks with the new operations are discussed in more detail below in the section titled “The procedures.”

Lower-risk BVLOS

The Regulations will introduce a new pilot certification process for lower-risk BVLOS called Level 1 Complex Operations.

Prerequisite

Before becoming certified for Level 1 Complex Operations, a pilot will need to be at least 18 years old and have successfully completed the online exam for Advanced operations under Part IX of the CARs to ensure a sufficient base of aviation knowledge and knowledge of Part IX.

Pilot certification process
  1. The pilot certification process will start with a pilot attending mandatory RPAS training (“ground school”) delivered by a school that meets the RPAS training provider requirements, discussed in more detail below.
  2. After successfully completing ground school, the pilot will need to pass a new online multiple-choice exam delivered through TC’s DMP. The online exam will cover topics applicable to lower-risk BVLOS operations, such as population density considerations (i.e., the concentration of people in a geographic area), weather, how the drone operates, as well as in-depth flight planning, potential system failures, and technical knowledge related to system connection links and detecting and avoiding hazards and other airspace users.
  3. Next, the pilot will need to visit a flight reviewer to do an in-person flight review. At the beginning of the flight review, the Flight Reviewer will verify the pilot’s identity. The pilot will then need to pass a flight review which covers topics related to flying BVLOS such as flight planning, doing a site survey, contingency procedures, take-offs, and landings, as well as cover technical requirements related to the aircraft and supporting systems.

After these three steps are successfully completed, the pilot will be able to apply online for a Pilot Certificate for Level 1 Complex Operations in the DMP, which will be automatically issued upon receipt of payment of the associated fees.

The proposed Regulations were pre-published in the Canada Gazette, Part I, on June 24, 2023, for a period of 90 days. At that time, TC had proposed medical requirements associated with the Level 1 Complex pilot certificate. Stakeholders raised concerns about the potential impacts and applicability of such requirements. TC heard from stakeholders that the medical requirements could be limiting to certain groups, and that the operational complexity of lower-risk BVLOS should not necessitate an assessment of medical fitness. In light of the comments, TC held further discussions with key international partners, including the U.S., and determined that CARs 901.19, Fitness of Crew Members and the requirements of the RPAS Operator Certificate (RPOC), provides sufficient mitigations to maintain safety within the level of risk for BVLOS operations. However, a medical standard for operations outside the lower-risk category may be considered in future regulatory work.

Validity and renewal period

The RPAS Pilot Certificate for Level 1 Complex Operations will not expire, but every two years, pilots will need to do at least one training renewal activity recognized by TC, such as undertaking a new flight review, completing training activities offered by TC, or retaking one of the pilot exams in the DMP. These activities are outlined in Standard 921 — Remotely Piloted Aircraft.

If this renewal requirement is not met, the Pilot Certificate for Level 1 Complex Operations would be invalid and would remain invalid until the pilot has completed a training renewal.

RPAS training providers

To be able to deliver the new mandatory ground school, an RPAS training provider will need to appoint a chief ground instructor who has the Level 1 Complex Pilot Certificate with a flight reviewer rating who will oversee the training program and will be accountable on behalf of the school to meet the new regulatory requirements. The training will need to be led by an instructor, be a minimum of 20 hours, and be in line with TP 15530 — Knowledge Requirements for Pilots of Remotely Piloted Aircraft Systems Level 1 Complex Operations. An RPAS training provider will also need to provide candidates with proof that they have completed ground school. Once the training provider meets all the requirements mentioned above, the RPAS training provider will declare to TC that they comply with the rules and will be able to begin delivering ground school for Level 1 Complex Operations.

Flight Reviewers

A flight reviewer is a drone pilot who has successfully completed their pilot certification and an exam to receive a flight reviewer rating. As with the current Part IX rules, to offer in-person flight reviews, a flight reviewer will need to work for a training provider that has declared to TC that they meet the new requirements above. An existing Advanced flight reviewer will need to get the Level 1 Complex Pilot Certificate to begin delivering the new flight review.

Advertised Events

Part IX of the CARs requires operators of RPAS of at least 250 g to obtain an SFOC to operate at an advertised event, which is defined in CARs 900.01 as “an outdoor event that is advertised to the general public, including a concert, festival, market or sporting event.” The Regulations will expand this requirement to all RPAS, including microdrones weighing less than 250 g. This amendment was added following pre-publication of the proposed Regulations in response to comments from stakeholders who noted that microdrones are frequently observed at advertised events and create safety risks for other RPAS operators and the public due to the constrained nature of the airspace at these events, and the higher density of people on the ground.

The products

Registration

The Regulations expand the registration requirements, including fees, for drones to include all drones that weigh 250 g and above. Previous requirements only applied to drones at least 250 g, up to and including 25 kg. Registration will continue to be delivered online through the DMP. This responds to stakeholder requests for a common way to identify ownership of drones of any size and will provide TC with better data on the Canadian sector.

Remotely piloted aircraft systems and safety assurance process

The Regulations will expand the existing Part IX Declaration process for RPAS manufacturers with the introduction of a TC review process for certain higher-risk operations called a Pre-Validated Declaration process. Manufacturers determine which technical requirements their drone and supporting systems meet and whether they want to declare to TC via the Declaration or Pre-Validated Declaration Process. A drone will not be able to fly in any of the operating environments under the new framework unless a Declaration or a Pre-Validated Declaration has been made by the manufacturer to operate in the respective operating environment.

1. The Declaration Process

Since its creation in 2019, Part IX of the CARs has allowed a manufacturer to declare to TC that their drone meets the technical requirements in Standard 922 — RPAS Safety Assurance, which covers small drones operating in controlled airspace, near people, or over people. If a manufacturer has made a declaration for their drone, it can be flown in these operations. Manufacturers must make a formal declaration that their drone meets the technical requirements of Standard 922 by submitting an online form on TC’s website.

The Regulations will allow manufacturers interested in having their drone flown in the following operations to use the Declaration Process for:

2. The Pre-Validated Declaration Process (PVD)

The PVD process is a two-step process that builds on the existing Declaration Process above by adding a new first step where the manufacturers or service providers (an organization delivering a service, such as one that supports the connection between the drone and the controller or supports the detection of other aircraft) must submit a plan that shows how their aircraft or system design will meet the requirements of Standard 922. Once this plan is accepted by TC, TC will provide the manufacturer or service provider with an acceptance letter. The manufacturer or service provider will execute the accepted plan, and subsequently declare to TC that their system meets Standard 922.

An updated Standard 922 — RPAS Safety Assurance is available on TC’s website.

The Regulations will require pre-validated declarations to be made if a manufacturer wants their drone to be able to conduct the following operations:

Annual reporting for Pre-Validated Declarations

To maintain a PVD on a drone, manufacturers or service providers will need to report annually to TC with the estimated number of product flight hours, a description of any safety-related issues that came up over the year, and any design changes that may affect the compliance with the requirements in Standard 922. By providing TC with information on the safety and design changes of a product or service, annual reporting holds manufacturers and service providers accountable for ongoing system support and monitoring the safety of their system.

Service difficulty reporting

A service difficulty is any malfunction or defect that could affect the safety of the drone or could injure a person. Manufacturers or service providers with PVDs on their drone or system will need to establish and maintain a system for service difficulty reporting for pilots and RPAS Operator Certificate holders (see below for more details). Manufacturers will need to provide operators with a description of what systems or elements are critical for safety so they can report to the manufacturer or service provider as soon as feasible if a service difficulty has occurred. Manufacturers and service providers will need to investigate service difficulties and, if the conclusion is the system no longer meets the technical requirements of Standard 922, a mandatory action, which is an action to prevent an unsafe or potentially unsafe condition, will need to be developed to fix the issue. Manufacturers and service providers will need to notify operators of the mandatory action as soon as possible and whether the declaration on the product or supporting system is still valid.

The procedures

Operating rules for extended visual line-of-sight and sheltered operations

As mentioned above, the Regulations expand the operations that will be allowed under Part IX of the CARs so that Advanced Pilot Certificate holders can perform extended VLOS (EVLOS) operations and sheltered operations by following operational rules, such as:

At prepublication, the proposed Regulations included a provision that would require persons who perform Visual Observer (VO) duties to hold an Advanced Pilot Certificate. Stakeholders commented that this requirement was excessive and that the requirements of the Basic Pilot Certificate should be sufficient. In light of the comments, TC reviewed the knowledge requirements required for VO in EVLOS and agreed that the Basic Pilot Certificate would be sufficient. The Regulations were modified accordingly.

Operating rules for medium-sized drones within VLOS

Existing Part IX requirements will continue to apply for medium-sized drones within VLOS, such as:

In addition, the Regulations will introduce new requirements to mitigate the additional safety risks associated with larger drones, such as:

Operating rules for lower-risk BVLOS

To mitigate potential risks associated with lower-risk BVLOS operations, pilots will need to remain in uncontrolled airspace and operations will need to be kept over unpopulated or sparsely populated areas. This means that pilots will only be allowed to fly over areas with fewer than 25 people per square kilometre. A pilot will need to determine the population density in their planned area of operation in advance by:

Other new requirements include that these flights will need to remain below 400 feet above ground level, in uncontrolled airspace, and away from aerodromes that are listed in the Canadian Flight Supplement.

At prepublication, the proposed Regulations included weather requirements for BVLOS, such as a minimum distance from clouds of 500 feet (152.4 m) vertically and 2,000 feet (609.6 m) horizontally. These proposed requirements were consistent with requirements for traditional aviation and aimed to ensure that RPAS flying BVLOS would be visible to other airspace users, including other aircraft flying within clouds. However, at prepublication, stakeholders noted that it would be very difficult for operators on the ground to accurately estimate the distance of their RPAS from the clouds. TC reviewed the requirement and agreed that compliance would be challenging for operators. As such, the Regulations were modified to require RPAS pilots to maintain a minimum ground visibility of 3 miles and to stay clear from clouds. This will provide RPAS pilots with greater clarity as ground visibility can readily be obtained (e.g., from a local airports). The requirement to stay clear from clouds will not require the pilot to estimate a specific distance but will set an expectation that operators do not fly RPAS in low visibility conditions, which was the intent of the proposed requirement, and will provide clear compliance objectives that can be assessed by TC during a surveillance activity or in an incident investigation.

RPAS Operator Certificate (RPOC)

As drone operations become more complex, it is important that businesses and organizations have effective safety policies and procedures specific to their organization and the operations that they carry out. This will help mitigate risks associated with larger companies with more employees (e.g., the need for standard operating procedures), larger fleets with more maintenance requirements, but also for operations with longer flight times over larger geographic areas beyond visual line-of-sight. Effective risk management improves the safety of an organization and improves an organization’s ability to continuously identify hazards and control risks in real time rather than after the fact, preventing incidents and accidents from occurring.

The new requirement for an RPAS Operator Certificate (RPOC) is modelled on existing requirements for traditional aviation (i.e. a Private Operator Certificate under section 604 of Part VI of the CARs and an Air Operator Certificate under Part VII of the CARs) but scaled and adjusted to meet the realities of RPAS operations of any size. Under Part VII of the CARs, the Air Operator Certificate provides risk mitigations for commercial air services whereas the Private Operator Certificate is for someone who operates their aircraft for personal or business purposes on a smaller scale. Existing operator certificates do not apply to RPAS; however, the new RPOC will be required for any pilot or organization that intends to fly BVLOS. The individual pilot, the business or organization will need to declare to TC that they meet requirements in the CARs via the DMP. There will be no requirements for renewal if the CARs requirements continue to be met. To obtain an RPOC, pilots, businesses, and organizations will be required to have policies and procedures in place that reflect the size and complexity of the operations they will carry out and include items, such as:

The accountable executive and person responsible for maintenance could be the same person in cases where there is only one pilot under an RPOC or in smaller organizations.

Further to the pre-publication of the proposed Regulations in the Canada Gazette, Part I, stakeholders commented that the proposed RPAS Operator Certificate was identified by the same acronym (ROC) as the Restricted Operator Certificate—Aeronautical and the newly announced ICAO RPAS Operator Certificate. Stakeholders expressed concerns that multiple uses of the same acronym could create confusion. In response to stakeholder concerns, the acronym for the RPAS Operator Certificate has been changed to RPOC.

Fees for services

The Regulations will introduce fees for the services to support the requirements for medium VLOS and lower-risk BVLOS operations, such as new pilot certificates and acceptance letters for pre-validated declarations.

TC performed a comprehensive costing exercise in line with TBS’s Guide to Costing. A full cost estimate was completed, which included all relevant costs that occur to deliver an activity or provide a service, including direct and indirect costs. The costing exercise factored in things, such as salary costs, benefit plans, training and travel, office accommodations, internal support services, and information technology system development and maintenance costs. The full cost of providing an activity is the maximum TC is able to charge.

TC considered the public versus private benefit of its drone services and an analysis indicated that commercial and recreational drone users and drone manufacturers primarily benefit from TC’s drone activities, within a range of 80 to 100%, depending upon the activity considered. It also indicated that the public benefits from TC drone activities that support innovation and economic development, maintain safety, and enable drone-based public services (e.g., non-commercial first responder services, which are 100% public benefit). The percentage range of public versus private benefit helped to inform how much of TC’s costs could be recovered by way of fees for these activities.

TC also considered international benchmarking of similar drone fees when setting prices. As discussed further below in the Regulatory Cooperation and Alignment section, the drone fees are comparable to those in other jurisdictions. TC also took stakeholder impact considerations into account, such as other fees that a client would need to pay to participate in the drone space, and how each fee would impact disparate stakeholder groups. The higher fees, such as to issue a high complexity SFOC, are generally payable by commercial enterprises and reflect the higher level of effort required by TC to perform the service. Lower fees, such as for drone registration, are payable by a wide range of clients, including recreational operators.

Overall, the fees aim to balance a number of goals, including:

Charging fees to the users of TC’s drone activities and services will reduce the financial burden on Canadian taxpayers.

Further to the pre-publication of the proposed Regulations in the Canada Gazette, Part I, TC received comments concerning the fees supporting RPAS activities and services. In response to the comments about fees, the following changes were made to the Regulations:

Further details about stakeholder comments on the proposed fees and TC’s responses can be found in the Consultations section below.

Table 1: SFOC Structure — Changes Between Canada Gazette, Part I, and Canada Gazette, Part II
Operation conducted under SFOC Canada Gazette, Part I – Pre-publication Canada Gazette, Part II – Final Publication
CARs 903.02(1) Low complexity Very low complexity
CARs 903.02(2) Low complexity Low complexity
CARs 903.02(3) (a) to (f) High complexity Medium complexity
CARs 903.02(4) (a) to (f) High complexity High complexity
Compound SFOC (more than 1 category) Equal to the highest complexity level requested Equal to the highest complexity level requested; except if two or more medium complexity operations are requested, which is deemed equal to a high complexity operation

The following table shows the change between the existing services and fees and the new service and fees under the Regulations. Individuals and businesses will be able to pay for these services online, using a credit card.

Table 2: Services and Fees
Service Existing/ New Service Previous Fee Proposed Fee (As pre-published in the Canada Gazette, Part I) New Fee (per the Regulations) Estimated Annual # of Transactions Cost Recovery Rate
Drone Registration Existing $5 $10 $10 35,187 98%
Level 1 Complex Operations Exam New N/A $50 $50 364 38%
Pilot Certificate – Level 1 Complex Operations New N/A $125 $125 107 44%
Pre-Validated Declarations New N/A $1,200 $1,200 15 43%
RPAS Operator Certificate New N/A $250 $125 61 8%
Special Flight Operations Certificate – Very Low complexity table b2 note * Existing N/A $150 $20 568 7%
Special Flight Operations Certificate – Low complexity table b2 note * Existing N/A $150 $75 71 18%
Special Flight Operations Certificate – Medium complexity table b2 note * Existing N/A $2,000 $900 38 33%
Special Flight Operations Certificate – High complexity table b2 note * Existing N/A $2,000 $2,000 38 32%
Amendment to an Existing Special Flight Operations Certificate table b2 note * Existing N/A $60 $60 67 11%

Table b2 note(s)

Table b2 note *

These fees will not apply to Emergency Response Service providers, public safety agencies, or other government organizations (e.g., police departments, municipalities) for SFOCs in respect of an emergency response operation. These services generate purely public benefits — there is no profit or other ’private’ benefit to the SFOC applicant.

Return to table b2 note * referrer

In accordance with the SFA, once the fees are in force, TC will report annually on the costs of providing the activities and services, and the revenues generated. For fees which meet certain criteria under the SFA, TC will report on service standard performance results and remit funds to clients if service standards are not met, as per TC’s publicly available Policy on remissions. Furthermore, TC will adjust the fees annually for inflation, and as previously stated, this annual fee adjustment would become applicable to existing VLOS fees as well.

Some of the fees are considered low-materiality under the Low-materiality Fees Regulations (i.e. those with a price below $151 upon coming into force). Under the SFA, low-materiality fees are not subject to remissions, performance standards or automatic annual adjustment. However, TC plans to adhere to internal service standards for all its drone fees, and adjust all drone fees for inflation, irrespective of a low-materiality designation.

Administrative Monetary Penalties (AMPs)

Consistent with the way that most provisions in Part IX of the CARs are currently enforced, 61 new requirements set out in the Regulations will be designated as enforceable via AMPs. Penalty amounts differ depending on the type of violation but the maximum penalty amounts, which are set out in the Act, are $5,000 for individuals and $25,000 for corporations. The penalty amounts for each violation were determined in accordance with TC enforcement policy and an AMPs framework that assesses several key criteria, including the seriousness of the violation as well as the category of violator (i.e., individual or corporation).

Further, the amount of the following provisions that are currently designated in the CARs has been increased:

Regulatory development

Consultation

Early consultation and pilot projects

In 2017, TC began conducting pilot projects with industry to better understand the technology and the associated safety risks, while allowing operators to gain field experience. The focus of these first pilot projects was working with first responders to conduct extended VLOS operations in rural areas. These pilot projects involved operations, such as search and rescue trials and the delivery of first aid supplies. TC learned that the technology still had room to grow but operations in rural areas created a safe environment for testing. In 2018, TC launched a call for pilot projects for BVLOS operations that were carried out from 2018–19 with companies, such as Canada Post, Canadian UAVs, and Drone Delivery Canada to perform operations in remote areas, long-range pipeline survey, and delivery of critical supplies.

Shortly after the first drone rules in Canada came into force in 2019 for VLOS, TC held Drone Talks, a two-day working session with approximately 125 stakeholders to discuss the future of BVLOS operations. This included representatives from different segments of the industry (e.g., operators, manufacturers, training providers), as well as representatives from academia, law enforcement agencies, other federal departments, and provincial and municipal officials. Stakeholders indicated the need for a flexible framework to accommodate the rapidly changing technology sooner rather than later. The feedback from Drone Talks, the maturing industry, and the results of research and development and pilot projects, informed TC’s development of a framework for the issuance of SFOCs for BVLOS, which was shared with stakeholders at the 2019 Unmanned Systems Canada Conference held in Ottawa, Ontario. This framework used the internationally recognized Specific Operational Risk Assessment to provide a baseline for risk mitigations and the type of operations that TC would be allowing, which in turn provided more predictability for stakeholders, as well as reduced the time to process SFOC applications.

Notice of proposed amendment consultations

TC took a staged approach to consultation on the proposed amendments, which allowed the department to provide stakeholders with more digestible pieces to comment on, as well as factor in new considerations from feedback and industry advancements.

In spring 2020, TC published a Notice of Proposed Amendment (NPA) with a 60-day consultation period outlining a proposed framework for medium drones within VLOS and lower-risk BVLOS operations. TC received 230 written submissions during the comment period from a wide range of stakeholders, including manufacturers, commercial operators, public safety organizations and members of the broader aviation community. Consultations were subsequently held (virtually) to provide clarifications, answer other questions, and receive feedback from stakeholders. There were some questions and concerns about how TC factored in the safety risks to other airspace users and people on the ground, in response to which TC provided additional detail as to how it identified and assessed the proposed environments for new drone operations. Overall, the drone industry was in support of the proposal, indicating that the proposed approach would strike a good balance between mitigating safety risks and allowing greater room for industry growth. The drone industry also expressed interest in the proposed amendments being published as soon as possible.

To further support the NPA, TC published a fee proposal in spring 2021 with a 30-day consultation period. The fee proposal provided a framework and breakdown of the new services that would be provided to support the proposed amendments, the cost to deliver those services, and the cost to stakeholders to access those services. TC received 50 written submissions during the comment period. The feedback was mixed: some supported the introduction of fees, and others were concerned about the impact of extra costs on the industry. Some respondents suggested the proposed fees for commercial operators were too low and should be increased to reflect the significant economic benefits that TC’s services provide to commercial clients.

In fall 2021, TC published a consultation paper to provide additional detail on the proposed RPAS medical requirements first identified in the 2020 NPA. Some feedback was received on the consultation paper about how physicians would support the implementation and whether there would be training available. Feedback received from the Aerial Evolution Association of Canada, which represents a large majority of drone stakeholders who may be impacted by the Regulations, indicated that overall members had no concerns with the proposed amendments as drafted. TC held additional consultations with national organizations that represent physicians, such as the Federation of Medical Regulatory Authorities of Canada (FMRAC) and the proposal was positively received. FMRAC members appreciated the importance of introducing medical requirements to mitigate additional risks with more complex drone operations.

Cost-benefit analysis

In accordance with the Cabinet Directive on Regulation and the TBS Policy on Cost-Benefit Analysis, TC has conducted extensive consultations since 2020 concerning the details of the regulatory approach to registration and certification, pilot requirements, product requirements, and procedural requirements, with details on the associated activities and the proposed cost-sharing ratio. Information gathered from these consultations was used to identify affected stakeholders and to inform the cost-benefit analysis (CBA), including, but not limited to, costs related to regulated parties applying for and maintaining certificates, costs related to the proposed declaration process for RPAS manufacturers (which would help pilots to make more informed decisions when purchasing drones for conducting the new types of operations), and impacts on stakeholders and the GoC associated with the service fees.

Following pre-publication of the Regulations in the Canada Gazette, Part I, TC gathered feedback from recreational and commercial operators through a CBA survey, issued to about 500 stakeholders who had registered for any of the TC RPAS consultation sections. This survey was focused on how operators use the existing certificates, and how they plan to use their new privileges under the Regulations.

Prepublication in the Canada Gazette, Part I

As previously indicated, the Regulations were pre-published in the Canada Gazette, Part I, on June 24, 2023, for a period of 90 days. A total of 352 comments were received from 137 stakeholders during this time. Stakeholders that provided comments included recreational operators, commercial operators, businesses, professional organizations, other levels of government, scientists, first responders, training providers, manufacturers, and members of the public. During this time, TC also hosted eight virtual Question and Answer (Q&A) sessions for the public with TC subject matter experts. There were four open sessions and four targeted sessions that included manufacturers, service providers, recreational operators, first responders, and training providers. Over 500 individuals attended the Q&A sessions where TC subject matter experts provided an overview of the proposed Regulations and answered questions to help inform stakeholders’ written comments. TC also presented the regulatory proposal to key partners and interested organizations, including the International Civil Aviation Organization (ICAO) and NAV CANADA.

In December 2023, TC published a “What We Heard” report, highlighting the comments received from stakeholders during the pre-publication. The majority of comments received related to the following themes: fees, training, microdrones (below 250 g), hobbyist/model aircraft, foreign operators, first responders, operating rules, medical requirements, and program implementation. TC considered all comments received, balancing different stakeholder interests as well as the objectives of the Regulations to promote safety, innovation, and economic opportunities for the RPAS sector. As most of the comments received touched on multiple themes, the number of comments received on each theme below is approximated.

Comments on the introduction of lower-risk BVLOS and medium RPAS

During the eight virtual Q&A sessions, stakeholders expressed support for the expansion of the RPAS regulatory framework to include lower-risk BVLOS and medium RPAS. Stakeholders were supportive of the advancements that Canada is making to promote the Canadian RPAS sector and concluded that the proposed Regulations would be an important step in fully integrating RPAS technology. Approximately 40 comments were received expressing general or partial support of the proposed Regulations. Three stakeholders would have preferred that TC move faster; they suggested that the proposed Regulations were moving slowly in comparison to technological developments in the sector. Some stakeholders would have liked to see the inclusion of more operating categories that would not require an SFOC, such as large RPAS above 150 kg, and permissions for BVLOS operations in higher-risk environments. No changes were made to the proposed Regulations in response to these comments.

The Regulations will remove SFOC requirements for operations where TC and industry have gained sufficient experience to justify moving to routine operations. Operators wanting to use an RPAS that falls outside the scope of the new permissions in the Regulations will still need to apply, on a case-by-case basis, for an SFOC.

Comments on the fees

TC received approximately 8 comments about the cumulative costs to operate in BVLOS. Stakeholders suggested that the cumulative cost of registration, certification, pilot training, and the RPOC, would be burdensome for recreational operators and small businesses. In response to these comments, TC reviewed the cumulative cost for lower-risk BVLOS and concluded that the proposed fees for the registration and certification were appropriate given the level of service offered by TC and the cost for the on-going support of the DMP. However, TC determined that it would be appropriate to revise the RPOC fee from $250 (as originally proposed) to $125 given that the automated delivery of the RPOC in the DMP will significantly reduce costs for TC to process and issue the RPOC.

TC received approximately 30 comments about the increase of the RPAS registration fee from $5 to $10. Stakeholders suggested that the increase was too great and requested that the fee remain the same and/or asked TC to consider fleet registration (as opposed to a per drone registration fee). TC reviewed the registration fee and determined that (i) the fee is aligned with similar fees in other jurisdictions, such as the United Kingdom and the U.S., particularly when considering that registration does not expire, and (ii) the fee respects the user-pay principle that ensures that the beneficiaries of a services are paying their fair share of the service delivery cost. As such, no changes were made to the proposed registration fee in response to the comments.

TC received approximately 10 comments about the proposed SFOC fee structure, which included two steps: Low ($150) and High Complexity ($2000). Stakeholders suggested that more steps were needed in the structure to capture the significant variations in operations and complexity, which will require varying levels of effort on the part of TC experts. TC reviewed the SFOC structure (as originally proposed) and added two categories to the structure: Very-Low and Medium Complexity, to reflect the different levels of complexity and the related levels of effort that would be required by TC. The revised structure does not introduce new types of operations that an applicant can request via an SFOC, but rather re-organizes operations into four steps that enable a more coherent pricing scheme for operators.

Comments on training

TC received approximately 48 comments related to training requirements. The most common comments suggested that the requirement for the VO to hold an Advanced Pilot Certificate for EVLOS operations was too high. Some organizations providing ground school training judged the minimum number of hours for the Level 1 Complex Operations training to be too short, and others judged them to be too long. Some commenters requested a certification process for training providers to limit flight reviewers to being affiliated with only one flight school, and the establishment of new recency requirements for flight reviewers. Commenters also asked for more training guidance from TC, clarification on the weight of RPAS to be used for testing in the Level 1 Complex flight review, and greater oversight from TC.

In response to these comments, TC reassessed the knowledge requirements for VO in EVLOS and determined that a Basic Pilot Certificate would meet the knowledge requirements without compromising TC’s safety objectives. The Regulations were amended to reflect this conclusion.

TC also re-evaluated the required time to teach the material in TP 15530 — Knowledge Requirements for Pilots of Remotely Piloted Aircraft Systems - Level 1 Complex Operations, and reconfirmed that 20 hours is an appropriate minimum number of hours to present the TP material. As such, no changes were made to the Regulations regarding the minimum number of training hours for Level 1 Complex Operations.

No changes were made to the Regulations with respect to the introduction of certification for flight schools, establishing a certification process flight reviewers to limit affiliation, or establishing new recency requirements. The current framework already requires flight schools to declare to TC that they meet Standard 921 providing uniformity in the service delivery of flight schools and awareness to TC of who is providing the service; flight reviewers are already required to be affiliated with a flight school ensuring that an organization can oversee the activities of the flight reviewer; and existing recency requirements already ensure the flight reviewer’s knowledge is current.

The other comments about guidance, the weight of the RPAS for testing, and oversight, will be addressed in updates to TP 15395 – Flight Reviewer’s Guide for Pilots of Remotely Piloted Aircraft Systems 250 g up to and including 150 kg, Operating within Visual Line-of-Sight (VLOS), Extended Visual Line-of-Sight (EVLOS), Sheltered VLOS, or Level 1 Complex (BVLOS); the Aeronautical Information Manual; the Drone Safety webpage; and TC’s National Oversight Plan. The TPs and Drone Safety webpage updates will be publicly available upon publication of the Regulations in the Canada Gazette, Part II. The National Oversight Plan and Aeronautical Information Manual will be updated in line with their regular publication cycles (annually by fiscal year and biannually in the Spring and Fall, respectively).

Comments on microdrones (below 250 grams)

TC received approximately 19 comments addressing microdrones. Some stakeholders requested more rules for microdrones, especially around advertised events, to increase knowledge among microdrone pilots, as some stakeholders perceived microdrones as a safety risk, and some comments called to increase the weight threshold for microdrones from 250 g to 1 kg, to increase the number of drones that would qualify for this regulatory category.

The CARs established microdrone rules in 2019 based on safety research from different countries, which demonstrated that RPAS of this size pose an extremely low risk of fatality either to people on the ground or because of a mid-air collision, and the data supporting these conclusions have not changed. This low-risk threshold is widely used worldwide, including in the U.S., Europe, the UK, Brazil, and many other countries. No changes to microdrone operating rules were made in response to the feedback because these drones continue to present a very low level of risk. TC concluded that it would not be appropriate to increase the weight threshold for microdrones as this would increase the potential safety risks to people and aircraft, and would not be aligned with the international approach to this category.

However, in light of stakeholder comments, the Regulations were amended to require an SFOC for the use of microdrones at advertised events, as this environment presents unique challenges, such as the high density of people on the ground, limited airspace, and the likelihood of multiple RPAS wanting to operate in the same limited airspace (e.g., for photography or videography), that could potentially create safety or security risks.

In addition, TC continues to develop and implement non-regulatory approaches to ensure microdrone operations continue to be conducted safely, such as outreach and education efforts including updated guidance material on the Drone Safety webpage and targeted communication campaigns that are reviewed and delivered on an annual basis.

Comments on model aircraft and hobbyists

TC received approximately 72 comments from stakeholders identifying as model aircraft pilots and hobbyists. Approximately 90% of these comments concerned the Model Aeronautics Association of Canada (MAAC) exemption that is no longer in force as of February 2023 due to a breach of a condition of the exemption. These stakeholders requested that the exemption be reinstated or that the CARs be amended to exempt model aircraft from the current requirements of Part IX of the CARs. Recreational operators felt that the VLOS regulations published in 2019 should be tailored to the recreational community, requesting a split between recreational and commercial operators to enable simplified rules for recreational operators, as some commenters found VLOS requirements too complex for recreational pilots. Other commenters would like to see more permissive requirements at advertised events, as they find the requirement to obtain an SFOC burdensome.

TC concluded that changes to the Regulations in response to these comments would not be appropriate. The Regulations cannot support a recreational and commercial split as it is the aircraft size and operating environment that determines the risk to aviation and the public, not the commercial or recreational intent of the flight. Likewise, since advertised events represent a higher risk to aviation and public safety, it would not be appropriate to remove the requirement for an SFOC to operate an RPAS at an advertised event.

TC continues to work with the model aircraft community to determine appropriate next steps and facilitate the community’s safe and legal use of Canadian airspace.

Comments on foreign operators

TC received approximately 16 comments relevant to foreign operators, including 7 comments concerning the SFOC fee specifically. Stakeholders commented that the requirements for a foreign recreational operator SFOC would be time-consuming, expensive, more burdensome than other countries, and could potentially be prohibitive, particularly for tourists (foreign operators) who may only be spending a short time in Canada and want to use their drone for personal reasons (e.g., photography).

In response, TC reviewed the proposed foreign operator SFOC fee and determined that it could be lowered from $150 to $20 for the Very Low complexity category. At the time when the $150 fee was developed, the fee amount was representative of the level of effort needed by TC to issue this type of certificate. TC has since gained significant experience processing these applications and introduced process improvements, including creating new functions in the DMP, which result in a lower level of effort spent on each application. In addition, an updated international comparison revealed that a lower fee would align better with other jurisdictions. As such, the Regulations were amended to reduce the foreign operator SFOC fee for the Very Low complexity category from $150 to $20. The revised fee will lower the financial burden on tourists and other foreign operators and align Canada with other like-minded international regulators.

Comments from first responders

TC received approximately 27 comments from stakeholders identifying themselves as first responders. These stakeholders commented that the proposed provision regarding the dropping of objects might prevent them from dropping material within the context of an emergency response with a drone. Stakeholders also commented that the description of an emergency perimeter was vague and could benefit from more details in the Regulations. Some commentors also requested an exemption from the new SFOC requirements due to the time-sensitive nature of their work, and quicker and more direct access to controlled airspace in emergencies as current airspace approval processes, provided by NAV Canada, are not always able to accommodate real-time requests.

TC reviewed the provision regarding the dropping of objects against the comments and found no regulatory barrier to the activities first responders identified given that the prohibition only applies if the dropping of the object would constitute a hazard to persons or property. TC established that, within the examples provided, such as dropping life-saving equipment on an individual in need or dropping specialized equipment to help manage forest fires, no hazard on the surface was created and that dropping an object with the purpose of helping a person or mitigating safety risks on the surface would not qualify as a hazard. TC will, however, provide additional guidance on what constitutes a hazard and how this can be interpreted by first responders before the Regulations come into force through TC’s outreach strategy, including updated content on the Drone Safety website and updated sections of the Aeronautical Information Manual. With respect to security perimeters, no change has been made to the Regulations as the provision intentionally allows for flexibility for public authorities to adapt their perimeter according to the nature and scale of an emergency, which can vary significantly.

With respect to SFOCs, the application process remains an important risk management tool that allows TC to approve operations that fall outside the scope of the Regulations with appropriate safety mitigations; as such, no changes were made to the Regulations to exempt first responders from this requirement. It is expected that some first responder activities will be able to be conducted under the new Regulations without an SFOC (e.g., lower-risk BVLOS for search and rescue in remote areas), however, SFOCs will still be required for higher-risk operations. TC will continue to work closely with the first responder community to issue SFOCs with the maximum flexibility (e.g., time periods, geography) as quickly as possible without compromising safety.

The comments respecting access to controlled airspace have been shared with NAV CANADA, which is responsible for managing airspace access in Canada. Given the increased risk of operating in controlled airspace due to a higher level of air traffic, maintaining access requirements is essential for NAV CANADA to be aware of all air traffic and support risk mitigation and, therefore, no changes were made to the Regulations.

Comments on operational rules

TC received approximately 27 comments about operational rules. Stakeholders commented that the proposed requirement to stay clear of clouds by 500 feet would be challenging to comply with given the difficulty in evaluating an RPAS’s distance from clouds, as explained above. Comments also requested clarifications on how an RPAS operator wishing to fly in BVLOS could assess population density in order to choose flight locations that are compliant with the Regulations. Some stakeholders were unsure as to what data sources or tools could be used to achieve this. As “structure” was not defined in the proposed Regulations, some stakeholders requested more details about what will be considered a “structure” (e.g., trees, cabins, power lines) that would qualify an RPAS operation to be flown as a “sheltered operation.” Stakeholders also commented on the requirement to stay five nautical miles away from aerodromes listed in the Canada Flight Supplement or the Water Aerodrome Supplement in lower-risk BVLOS, and asked if this would be required even when an aerodrome is not in use (e.g., seasonal closure) or when the operator has obtained prior approval from the aerodrome operator. Stakeholders expressed concerns that this proposed requirement (to stay five nautical miles away from aerodromes) would limit the available areas suitable for lower-risk BVLOS.

In response to the concerns raised, TC determined that the proposed requirement for RPAS to remain at least 500 feet from the clouds could be replaced with a requirement for RPAS to stay clear from clouds and maintain a ground visibility of three miles. The Regulations were revised accordingly. This change will help reduce uncertainty for operators without compromising TC’s original safety objectives.

With respect to comments on how RPAS operators can assess population density, an updated version of the publicly available DSST will be available upon on April 1, 2025, or upon publication in the Canada Gazette, Part II, whichever comes the latest. The DSST will provide Statistics Canada’s census data on an interactive map, which will allow operators to quickly assess the population density of their potential flight location. Guidance material is also available in Appendix G of AC 903-001 and additional guidance on how to conduct an in-person site survey for BVLOS will also be provided on the Drone Safety website before the Regulations come into force.

No changes to the Regulations were made in response to the questions raised about sheltered operations as these questions will be covered in new guidance material in the Aeronautical Information Manual, the Drone Safety webpage, and other communications material as part of our outreach strategy once the Regulations are published in the Canada Gazette, Part II.

No changes were made to the requirement to stay five nautical miles away from aerodromes listed in the Canada Flight Supplement or the Water Aerodrome Supplement in lower-risk BVLOS. Aerodromes across the country vary significantly in their levels of traffic, including seasonal variations, and as such there is always a possibility of an aircraft taking off and landing, increasing the risk of an interaction with a BVLOS operation at low altitudes. Maintaining a stand-off distance from aerodromes is required to reduce the likelihood of these interactions for routine operations, noting that operators may still apply to TC for a SFOC for BVLOS operations in these areas and those will be assessed case-by-case.

Comments on medical requirements

Approximately 38 comments were related to medical requirements. These requirements were perceived as a potential barrier to flying BVLOS, as the medical requirements could be limiting to certain groups. More specifically, they could be overly restrictive to operators, including first responders, with a mental health illness or disorder. Stakeholders also highlighted that many Canadians don’t have access to a family doctor, which could impede or delay compliance with the requirement, and that physicians would likely charge a fee for this service, further increasing the cumulative cost of BVLOS.

Following an assessment of the comments and further discussions with key international partners, notably the Federal Aviation Administration in the U.S., TC determined that introducing a medical standard for Canadian RPAS pilots could create a unique burden for Canadian RPAS pilots when compared with Canada’s international counterparts.

The existing provision, CARs 901.19 — Fitness of Crew Members, already establishes a baseline level of fitness for drone pilots, including requirements related to fatigue and substance use. In light of stakeholder concerns that the new proposed medical standard would be overly restrictive on the pilot community, a reassessment of the combination of existing (CARs 901.19) and other new requirements (the requirements of the RPOC to appoint an accountable executive, and the introduction of safety processes mitigating risks for organizations operating with an RPOC under CARs 901.18) was conducted and TC determined that these provisions together should provide sufficient mitigation measures to maintain TC’s safety objectives in the lower-risk BVLOS environment. Therefore, the proposed medical requirements published in the Canada Gazette, Part I, which consisted of the proposed Division IX — Medical Requirements, Standard 924 — RPAS Medical, and linked provisions, have been removed from the final Regulations.

Comments on program implementation

Approximately 54 comments were received concerning implementation timelines for new requirements and how the Regulations will be enforced. Operators expressed concerns about the Regulations coming into force during the industry’s busiest season (typically, May to September). Stakeholders cautioned that, if requirements come into force during their peak season, it would cause them to take time away from flying as they would need to get their pilots new training and certification, apply for and obtain an RPOC, and familiarize themselves with the rules. Stakeholders also had questions about TC’s plan to enforce the Regulations and called for more surveillance activities. Stakeholders requested that additional guidance be available to support the new Regulations to support their familiarization with the new requirements.

At prepublication, TC’s plan was for the Regulations to come into force on April 1, 2025. Since prepublication, the original project schedule was revised to allow for additional time to review, analyze, and amend the Regulations, which has affected the planned coming into force. Given that stakeholders will need time between the publication of the Regulations in the Canada Gazette, Part II, and the coming into force of new requirements to get their appropriate training and certification and familiarize themselves with the new rules, the Regulations were updated to reset the coming into force date for the new BVLOS, medium RPAS, and SFOC requirements to November 4, 2025. This change will also help avoid interfering with the peak summer flying season in 2025.

TC will continue developing its enforcement regime through the integration of RPAS surveillance activities within TC’s National Oversight Program and will conduct targeted surveillance activities in support of the Regulations. TC will publish new and updated guidance in the Drone Safety webpage, the DSST, and the Aeronautical Information Manual, according to its annual outreach strategy to support stakeholders in understanding and complying with the new requirements.

Comments on the cost-benefit analysis

Approximately 15 comments were received relating to the cost-benefit analysis. Eleven stakeholders commented that the recreational benefit was not only overestimated but that it was unrelated to the actual realized benefit that recreational operators would receive. In response to these comments, TC has adjusted its analysis relating to recreational benefits, decreasing the result overall. A “value of a recreational day” proxy was replaced with a willingness to pay (WTP) proxy when calculating benefit per flight for recreational operators. TC views that the WTP is a better proxy to capture benefits, as it relates more directly to the value received from RPAS flights.

One stakeholder indicated that the total estimated number of expected operators was underestimated. More specifically, the stakeholder suggested that the anticipated number of Level 1 Complex operators would need to be higher to line up with the expected number of ground schools offering the program, and to account for additional demand from police and first responders. TC has adjusted forecasting based on the latest data available, which has increased the number of anticipated new Level 1 Complex operators relative to ground schools.

One stakeholder suggested that the estimated lifecycle of a drone was too high. TC selected the 8-year lifecycle, which is the upper-bound value of the average lifespan of an RPAS in the economic literature, to account for the possibility that some of the RPAS would already have been re-registered under the baseline scenario and ensure that the projected demand for RPAS registration was sufficient to address the gap of limited historical data used to perform the projection. To test how sensitive impacts on affected stakeholders would be with lifecycles less than 8 years, TC conducted a sensitivity analysis.

Another stakeholder commented that the 30-second estimate for the time it would take to register a drone was too low. In response to this comment, TC adjusted the estimate on drone registration time from 30 seconds to 3 minutes.

The remaining comments expressed approval with collecting industry feedback.

No changes to the Regulations were made in response to comments about the cost-benefit analysis.

Other comments

The remainder of the comments was either outside the scope of TC’s mandate or did not pertain to the Regulations. For example, some stakeholders raised privacy concerns, concerns about the impacts of drones on wildlife, and the use of drones in National Parks. These comments have been shared — where appropriate — with the relevant parties responsible for federal regulations in these areas (e.g., Parks Canada). It is important to note that in addition to the CARs, drone operations in Canada are subject to other federal, provincial, territorial, and municipal laws. For example, The Personal Information Protection and Electronic Documents Act sets the rules for how private-sector organizations collect, use, and disclose personal information in the course of for-profit, commercial activities across Canada; the Criminal Code has rules prohibiting the surreptitious observation or recording of individuals in circumstances where they have a reasonable expectation of privacy; the National Parks of Canada Aircraft Access Regulations defined the rules for landing and taking off within National Parks; and the Species at Risk Act, the Migratory Birds Regulations, and the Marine Mammals Regulations have rules pertaining to aircraft operation and the protection of wildlife.

Additional consultations and supporting documentation

Throughout the consultation process, TC shared proposed standards that would be incorporated within the Regulations and supporting guidance material. For example, Advisory Circular (AC) 903-001 — Remotely Piloted Aircraft Systems Operational Risk Assessment was published in draft form in July 2019 for several months to allow stakeholders to comment and help improve the product. AC 903-001 is a guidance document (not incorporated by reference) for SFOC applicants looking to carry out BVLOS operations, which provides guidance on a series of concepts and procedures that have been embedded within the Regulations, such as anti-collision light requirements, extended VLOS operations and procedures for detecting and avoiding other airspace users. In June 2024, a second edition of AC 903-001 was published by TC and shared with stakeholders, which included updated definitions based on operational experiences and updated guidance for more complex operations. The content was also aligned with international standard bodies.

Furthermore, early drafts of TP 15530 — Knowledge Requirements for Pilots of Remotely Piloted Aircraft Systems – Level 1 Complex Operations were included in consultations with training providers, and Standard 922 — RPAS Safety Assurance (which contains the technical requirements for the aircraft and supporting systems) was sent to other civil aviation authorities in the U.S. and the EU to gain insight and feedback before finalizing the Regulations. Feedback was received about the technical requirements that drones must meet, as well as the subjects that should be covered in the new knowledge exams, such as safety targets for detecting other aircraft and what aviation knowledge pilots require to fly BVLOS. The feedback was carefully reviewed, considered, and incorporated into the standards and guidance documents.

Other changes to the Regulations

In addition to the changes to the Regulations in response to stakeholder feedback described above, some non-substantive changes have been made to the Regulations since prepublication to improve the clarity of drafted provisions.

Modern treaty obligations and Indigenous engagement and consultation

In accordance with the Cabinet Directive on the Federal Approach to Modern Treaty Implementation, an analysis was undertaken to determine whether the Regulations give rise to modern treaty implications. This assessment examined the geographic scope and subject matter of the Regulations in relation to modern treaties in effect and after examination, no implications or impacts on modern treaties have been identified.

Instrument choice

One of the driving forces to create and implement the original Part IX of the CARs was an increased number of safety incidents associated with the growth in popularity of small drones, coupled with the exponential growth of a new industry and demand for a regulatory framework to mitigate safety risks, as well as provide predictability and support innovation. Following the coming into force of Part IX and the development of supporting program elements including education, outreach, surveillance and enforcement tools, the primary role for regulation in this sector shifted to facilitating innovation and economic growth.

Currently, TC makes use of existing regulatory authorities to issue SFOCs on a case-by-case basis for lower-risk BVLOS operations, approving over 335 SFOCs to date. Although the SFOC is a regulatory requirement, each SFOC is approved on a first-come, first-served basis, operation by operation. SFOCs allow TC to work directly with stakeholders to test and refine various risk mitigations, gaining experience and knowledge that help inform the development of future regulations, while allowing industry to gain operating experience without compromising safety. The SFOC process is an essential way for TC to facilitate early-stage innovation and develop an understanding of associated safety risks; however, as the sector and technology matures, the continued use of SFOCs becomes a costly administrative burden. Since 2019, the Canadian drone industry has continued to call for BVLOS regulations to facilitate deployment at scale, enable the growth of Canadian businesses, and maintain Canada’s position as a favourable regulatory environment for investment. After five years of issuing SFOCs for lower-risk BVLOS and VLOS with medium-sized drones, TC has the necessary evidence, data, and risk mitigations in place to support increased flexibility in the drone sector by introducing a specific regulatory framework to allow routine operations to take place.

In the absence of regulations to provide for increased flexibility, the SFOC requirement would remain unchanged and the only way to increase routine operations would be to hire more departmental resources to process SFOCs, which would result in an increased cost to taxpayers. Furthermore, non-regulatory options would not provide predictability and certainty about the future for a developing industry. The industry needs security to invest and develop towards future more complex operations, which in turn would allow TC to shift its focus to more complex operations and keep pace with the advancements of technology. Regulations are needed to provide increased flexibility to support expanded drone operations and innovation while at the same time ensuring that drone operations continue to be conducted in a safe, consistent, and predictable manner.

In addition, regulations are needed to amend fees for existing drone services delivered by TC, such as the issuance of SFOCs, and to introduce fees for new services. Under the Aeronautics Act, TC has the enabling authority to charge fees for services and to do so, the fees must be included in regulations. The GoC promotes a balanced approach to financing government programs whereby those who receive and/or benefit from program services should pay a reasonable share of the costs for those services. While TC currently charges fees for certain services related to drones, such as registrations and exams, the costs of processing SFOCs are borne by Canadian taxpayers. Fees are needed to ensure that costs for providing such services are rebalanced more equitably between Canadian taxpayers and the stakeholders (e.g., drone operators) that benefit from the services.

Regulatory analysis

Changes to the cost-benefit analysis since prepublication in the Canada Gazette, Part I

As previously discussed under Regulatory development — Consultation, changes were made to the Regulations based on comments from stakeholders received during the comment period following prepublication in the Canada Gazette, Part I. In addition, some data used to inform the CBA were recently updated, and TC surveyed stakeholders on their existing operating framework, and how it would be modified to comply with the Regulations. These inputs were used to update the analysis as follows.footnote 3

Analytical framework:

Adjustments in response to stakeholder feedback received during the prepublication:

Other changes:

As a result, the estimated total cost increased from $26.02 million to $26.61 million, the total benefit increased from $40.23 million to $73.65 million, and the net benefit increased from $14.21 million to $47.04 million. Note that the change in the number of anticipated RPAS operators, revenue, and flights per year is the primary driver of the change in CBA results.

Benefits and costs

The Regulations are expected to remove barriers to the growth of the RPAS sector, such as regulatory uncertainty and the administrative burden of case-by-case approvals, while maintaining the safety of the aviation system and Canadians. The Regulations will also address stakeholders’ concerns identified in the 2018 TBS Regulatory Review and meet TC’s commitments in the 2019 Transportation Sector Regulatory Roadmap to provide more clarity and flexibility for RPAS.

The Regulations will introduce service fees, which will rebalance costs from Canadian taxpayers (represented by TC) to RPAS service users.

Over a ten-year time frame between 2025 and 2034, the Regulations are expected to impose a total cost of $26.61 million (present value in 2023 Canadian dollars, discounted to the base year of 2025 at a 7% discount rate), incurred by the domestic RPAS industry, the GoC, recreational RPAS operators, and NAV CANADA. Of the total costs, $12.21 million is expected to be incurred by the RPAS industry (operators and manufacturers), $8.75 million by the GoC, $3.93 million by recreational RPAS operators, and $1.73 million by NAV CANADA.

The benefits associated with the Regulations are expected to be $73.65 million for all stakeholders over the ten-year time frame. Of the total benefits, $64.34 million is expected to be realized by industry (RPAS operators and manufacturers), $3.42 million is expected to be realized by the GoC, and $5.89 million is expected to be realized by recreational operators.

As a result, the Regulations are expected to result in a total net benefit of $47.04 million (present value in 2023 Canadian dollars, discounted to the base year of 2025 at a 7% discount rate) between 2025 and 2034.

Analytical framework

Benefits and costs associated with the Regulations are assessed by comparing the baseline scenario against the regulatory scenario. The baseline scenario depicts what is likely to continue happening in the future if the GoC does not implement the Regulations. The regulatory scenario depicts on the projected outcomes of the Regulations.

Where possible, impacts are quantified and monetized, with only the direct costs and benefits for stakeholders being considered in the CBA. While the Regulations may result in some indirect sectoral impacts in the form of business transferring from other traditional transportation markets to the RPAS sector, these secondary impacts are not included in the analysis. As per the TBS’s Canada’s Cost-Benefit Analysis Guide for Regulatory Proposals, a CBA primarily focuses on the direct impacts. Also, as the Regulations are not anticipated to influence the prices of other markets, nor introduce distortions to secondary markets, as per the guidance, omitting any such impacts in related markets is justified and does not lead to significant bias in estimated costs or benefits.

Costs regarding stakeholders’ time are referred to as “time costs” throughout the analysis. These costs are incurred based on what a stakeholder could have been doing if not spending time complying with the Regulations (e.g., work, leisure). For example, to spend one hour complying with the Regulations, a stakeholder may need to forego the opportunity to work for one hour, resulting in costs equal to their wage rate. The same concept applies for “time cost savings,” where a stakeholder would benefit from a reduction in regulatory requirements.

Following the TBS Policy on Cost-Benefit Analysis, the scope of this analysis is at the societal level, analyzing costs and benefits attributed to Canadians. Due to the cost-recovery nature of fees, the incremental costs to domestic RPAS service users associated with fees represent a shift of the cost burden from Canadian taxpayers (represented by TC) to the Canadian service users. Incremental costs to foreign RPAS service users associated with fees, represent a net increase in the cost recovered by Canadians (since these costs are not borne by Canadians). Therefore, fees collected from domestic RPAS service users will have a neutral impact on Canadian society, while fees collected from foreign RPAS service users are considered a benefit to Canadians. Fees associated with the Regulations are cost out at face value without adjusting for the dollar year (for example, a fee for $10 in 2025 is cost out at $10 in 2023 dollars). This is done to minimize uncertainty related to forecasting inflation.

Assumptions used in the analysis are based on four stakeholder consultations (see Regulatory development), publicly available information, and TC subject-matter experts’ knowledge. For example

This analysis estimated the impact of the Regulations over a 10-year period from 2025 to 2034, with the year 2025 being when the Regulations are registered. A year represents the 12-month period spanning from the month in which the Regulations are registered, to the same month in the following year. Unless otherwise stated, all values are expressed in present value in 2023 Canadian dollars and discounted to the base year of 2025 at a 7% discount rate. Note that 1) values may not add up to totals due to rounding, 2) the formulafootnote 4 used to calculate annualized values in tables throughout the Regulatory Analysis section differs from that in TBS’s Canada’s Cost-Benefit Analysis Guide for Regulatory Proposals to align with the stated discounting approach and 3) fees associated with the Regulations are cost out at face value without adjusting for the price year (for example, a fee of $10 introduced in 2025 remains as $10 in 2023 Canadian dollars) to minimize uncertainty related to forecasting inflation.footnote 5

A detailed CBA report is available upon request.

Baseline and regulatory scenarios

Under the baseline scenario, it is assumed that the number of domestic RPAS operators would continue to grow. In addition, the demand for more complex RPAS operations would increase and, therefore, require operators to apply for SFOCs. As a result, TC would encounter challenges to issue SFOCs in a timely manner, affecting businesses’ operations. Moreover, since TC does not charge a service fee for SFOC issuance, there would be a cost imbalance between the service users and Canadian taxpayers (represented by TC) as taxpayers would bear the cost of SFOC issuance. Furthermore, RPAS manufacturers would be required to apply for declarations for drones weighing up to 25 kg. All RPAS operations would be required to have a site survey performed.

Under the regulatory scenario, the updated pilot certification regime will mean that more Advanced Pilot Certificate flights can be completed without the need to obtain an SFOC, including EVLOS and lower-risk BVLOS operations. The RPAS industry is expected to see greater growth than under the baseline scenario. It is expected that the number of SFOC applications will be lower than that under the baseline scenario due to the introduction of Advanced Pilot Certificate and Level 1 Complex Certificate, which will not only free up TC resources to provide SFOC approvals for more complex operations in a timelier manner, but also promote more complex flights to be conducted under SFOCs. The financial burden of delivering TC drone services will be better balanced between those who benefit and the general taxpayer. RPAS manufacturers will be required to apply for declarations for drones weighing more than 25 kg, up to 150 kg (i.e. medium sized drones), RPAS, and PVDs for their drone models up to 150 kg, which is expected to increase their sales volumes. Commercial and recreational operators that confirm their knowledge and skills through one of the new certificates will be able to safely conduct a greater variety of flights.

Impacted stakeholders

The Regulations will have an array of implications for various stakeholders in Canada, such as RPAS manufacturers, commercial RPAS operators, recreational RPAS operators, the GoC, NAV CANADA, and RPAS ground schools. Based on the forecasted total of first-time registrations, it is anticipated that approximately 202 859 stakeholdersfootnote 6, including manufacturers, ground schools, individuals, and operators, will be affected by the Regulations.

RPAS manufacturers who choose to obtain a PVD for any of their RPAS models will be affected by the Regulations. PVDs permit drones to conduct certain types of advanced operations (see Description), which will likely increase the demand for their products.

RPAS models that have a PVD would be able to conduct certain categories of operation introduced in the proposed amendments (near and over people, as well as certain BVLOS operations in uncontrolled airspace, below 400 feet, and over sparsely populated areas). This may impart an added benefit to manufacturers as it could broaden the demand for their product. Based on consultations with TC engineers and based on the number of Safety Assurance Declarations currently received for small RPAS, it is expected that 105 PVDs will be issued over the analytical timeframe, with 20 of them going to domestic manufacturers, 17 of which are estimated to be small businesses. It is assumed that each domestic PVD will go to one manufacturer. It was estimated by a TC subject matter expert that 80 to 90% of RPAS manufacturers who will provide PVDs to Canadians are foreign. This estimate is calculated from the historical number of manufacturers who have made declarations to TC (30 out of 200 manufacturers currently declared to TC are domestic). There is a lack of data on the size of the manufacturers, and the number of drones each manufacturer will sell. Additionally, manufacturers may not choose to opt for PVDs during the analytical timeframe. These factors will also affect the number of PVDs issued, which is why a TC expert estimate was used. The Regulations will also allow for medium drones to apply for a standard declaration. It is anticipated that 20 manufacturers will release a total of 50 new medium-sized models over the analytical timeframe. Domestic RPAS manufacturers are expected to see a benefit in relation to additional drone sales due to increased demand for all types of drones in the regulatory scenario.

Commercial RPAS operators, including flight reviewers, will be affected by the Regulations. Depending on the degree of their piloting needs, operators will be subject to certification requirements, including the Advanced Pilot Certificate and Level 1 Complex Certificate. Flight reviewers will be required to be affiliated with a training provider who has declared to TC that they are offering services for the Level 1 Complex Certificate. These requirements will be administered through the DMP. Operators impacted by these certification requirements are expected to be largely independent contractors, who will provide various RPAS-related services to Canadians.

Eliminating the requirement to obtain a SFOC for most lower-risk BVLOS and medium VLOS operations governed by the Advanced Pilot Certificate or Level 1 Complex Certificate will free up TC capacity to focus on processing SFOC applications for more complex operations. This will decrease the number of SFOCs requiring processing, which will result in time cost savings for commercial operators, as some operations are currently being cancelled due to delays in processing times. In the regulatory scenario, it is expected that there will be 17 770 requests for SFOCs over the 10-year time frame, and that 3 161 of these requests are expected to come from domestic sources. There is expected to be 10 734 fewer total requests from domestic sources in the regulatory scenario than those in the baseline scenario.

In the regulatory scenario, there are expected to be 7 832 SFOC approvals (a reduction of 206 compared to the baseline scenario), 1 425 of these being from domestic sources (a reduction of 2 541 compared to the baseline scenario). Note that the reduction in approvals for domestic operators is higher than the total reduction in approvals. This is due to a decreasing proportion of requests from domestic operators relative to foreign operators over the analytical timeframe. The higher proportion of requests from foreign operators in the regulatory scenario will mean a higher proportion of the approvals granted would be to foreign operators. This is also related to the forecasted number of very low complexity SFOC approvals to be given to foreign operators.

The RPAS Operator Certificate (RPOC) program will be introduced for operators who conduct lower-risk BVLOS operations. The RPOC will introduce reporting requirements that are expected to primarily apply to larger entities comprised of multiple operators but will also affect individual operators. It is expected that 613footnote 7 businesses will be affected by the RPOC requirements, including 509 small businesses.footnote 8 Costs related to certificates, specifically the Advanced Pilot Certificate and the Level 1 Complex Certificate, are expected to fall on individual operators rather than on the businesses they work for. It is anticipated that 2 097 domestic commercial operators will take exams for the Level 1 Complex certificate, resulting in 613 successful new Level 1 Complex operators. Similarly, it is anticipated that there will be 3 775 new Advanced Pilot Certificate exams taken by domestic commercial operators in relation to the baseline scenario, resulting in 1 073 new domestic commercial Advanced Pilot Certificate operators. It is assumed that 69% of Advanced Pilot Certificate exams will be taken for recency purposes, and therefore will not result in new Advanced Pilot Certificate operators. There will be 68 343 domestic commercial drone registrations in the baseline scenario, and an additional 2 031 domestic commercial registrations as a result of the Regulations.

Recreational RPAS operators will be affected similarly to commercial operators regarding DMP services. That is, recreational operators will be subject to costs relating to the Advanced Pilot Certificate, Level 1 Complex Certificate, and DMP account and drone registration services. It is expected that 80% of Advanced Pilot Certificate operators and 20% of Level 1 Complex operators, respectively, will be recreational. It is anticipated that 524 recreational operators will take exams for the Level 1 Complex certificate, resulting in 153 successful new Level 1 Complex operators. Similarly, it is anticipated that there will be 15 098 new exams taken by domestic recreational operators in relation to the baseline scenario, resulting in 4 292 new domestic recreational Advanced Pilot Certificate operators. It is assumed that 69% of Advanced Pilot Certificate exams will be taken for recency purposes, and therefore will not result in new Advanced Pilot Certificate operators. In the baseline scenario, there would be 273 372 recreational drone registrations; whereas, with the introduction of the Regulations, an additional 8 124 registrations are expected.

NAV CANADA is expected to be impacted by the Regulations as the increased number of RPAS operators will result in an increase in airspace access requests. NAV CANADA estimated that 74% of annual requests will be processed by an automated system and 26% be processed manually.

RPAS Ground Schools will be impacted by the Regulations because of their ability to offer a new curriculum for the Level 1 Complex Certificate. The fee revenue for the ground schools is expected to cover their operating and curriculum development costs; however, they are expected to see an increase in the administrative burden. There are 180 RPAS ground schools in Canada, 18 of which are anticipated to adopt the new curriculum.

The GoC will administer services in support of the Regulations by maintaining and developing the expanded DMP, as well as conducting education and stakeholder outreach.

Table 3: Regulatory Additional Domestic Stakeholder Counts
Impacted stakeholder Stakeholder Item 2025 Average 2026-2033 2034 Total
RPAS Manufacturers PVDs and Updates 11 2 2 29
Declarations and Updates 25 24 31 245
Commercial RPAS Operators New Operators (Advanced Pilot Certificate) 0 table c1 note * 125 74 1 073
New Operators (Level 1 Complex) 0 72 35 613
Recreational RPAS Operators New Operators (Advanced Pilot Certificate) 0 499 297 4 292
New Operators (Level 1 Complex) 0 18 9 153
GoC Full Time Equivalent Employees 10 7.99 7.42 N/A
RPAS Ground Schools Schools offering new curriculum for the first time 18 0 0 18

Table c1 note(s)

Table c1 note *

Note that this value and others in this column are 0 due to the operators not being expected to conduct new types of flights until the flying season of 2026 (see implementation section for further details).

Return to table c1 note * referrer

Data, key assumptions and methodology

Data limitations and key assumptions

Due to the new and constantly evolving nature of the RPAS sector, multiple data and analytical limitations affected this analysis. For example, historical data on RPAS registrations in Canada from the DMP were only available from 2019, providing limited information to inform a comprehensive forecast of RPAS registration during the analytical timeframe. Therefore, RPAS Registration forecasting in the analysis was based on the U.S. FAA’s projection, given the similarity of their RPAS sector to Canada’s, acknowledging that such a forecast may not accurately reflect the Canadian RPAS market over time.

Therefore, several key assumptions are made in the analysis as follows:

Methodology
RPAS registration forecast

TC’s data on RPAS registration shows that the RPAS industry has been rapidly growing, which is expected to continue within the analytical timeframe. Annual registrations under the regulatory scenario are expected to increase from 15 824 in 2024 to 21 455 in 2026 (the year of the first flying season when operators are allowed to conduct new flights under their certificates) and continue at an upward trend to 44 026 in 2034, including re-registrations for existing operators after an RPAS reaches the end of its useful life. There is anticipated to be a total of 10 154 new drone registrations under the regulatory scenario relative to the baseline.

To calculate the number of operators affected by the Regulations, the number of RPAS registrations, excluding replacements, is used as a proxy. For calculating the total expected number of RPAS registrations for which fees will apply, an average lifespan of a drone (eight years), as found through an environmental scan of drone and battery life expectancy, is used. It is assumed that operators will not retire within this time frame because they have invested a large amount of time and resources into their career relative to other RPAS operators. Therefore, it is assumed that operators will register another drone after eight years. This cycle starts at the beginning of the forecasting dataset in 2019. This will mean a jump in registrations in 2027, reflecting the registration of a drone to replace one initially registered in 2019 that had reached the end of its life. Including replacements, drone registrations are expected to increase to 21 455 in 2026, and increase to 44 026 by 2034.

When calculating the number of commercial operators, it is unknown how many operators would be hired by one company. Based on this, and the mostly small business/independent contractor makeup of the RPAS industry, it is assumed that each operator (contractor) represents one business.

Profit per flight

Profit per flight in this analysis represents the profits generated for RPAS operators from conducting different types of operations. This analysis forecasts the expected number of flights conducted for each of the different types of certificates under both the baseline and the regulatory scenarios. These profits per flight estimates are used to calculate the benefits that RPAS operators will incur.

For each type of certificate, the revenue per flight is calculated and multiplied by an average positive profit margin (47.3%), to get the profit per flight.footnote 10 This profit margin corresponds to non-scheduled air transportation sector NAICS Code 48121, which is considered the best proxy representing RPAS operations. Alternative results are presented in the sensitivity analysis to show what would happen if this profit margin for RPAS operators fell in the higher or lower bounds of the sourced profit margins.

SFOC flights

Based on the CBA survey conducted after the prepublication of the proposed Regulations in the Canada Gazette, Part I, the average revenue earned from a SFOC under the baseline scenario is estimated to be $1,468. This is estimated to result in profits of $694 per flight, based on the average profit rate of 47.3% determined from the NAICS code for non-scheduled air transportation mentioned above.

Under the regulatory scenario, the average revenue from an SFOC flight is expected to increase in comparison to the baseline scenario. This is because more complex operations are anticipated to be carried out due to certain operations no longer requiring SFOCs. To quantify this increase, the estimated increase in costs per flight that operators will face, related to the SFOC fee increase, is added to the baseline revenue for SFOCs. Including this added value, the regulatory scenario SFOC operation is expected to generate $1,520 in revenue. This is expected to result in a profit of $719 per flight, based on the same above-mentioned profit margin of 47.3%. Operators are anticipated to conduct an average of 14.64 SFOC flights per year.

Advanced Pilot Certificate flights

The CBA survey indicated that Advanced Pilot Certificate flights bring in an average of $873 in revenue, resulting in profits of $413 per operation with the 47.3% profit margin. The survey indicated that operators would complete an average of 19.55 Advanced Pilot Certificate flights per year, and this is used in the baseline and regulatory scenarios.

Level 1 Complex Certificate flights

The revenue per BVLOS operation follows a similar methodology and reasoning to the SFOC operations. Because BVLOS flights are currently conducted under SFOCs in the baseline scenario, it is anticipated that Level 1 complex certificate flight revenue would be similar to that associated with an SFOC under the baseline scenario, which is estimated to be $1,468 ($694 in profit per flight). The average number of flights is also expected to be similar to the number of SFOC flights per year at 14.64.

Airspace Access Requests

The baseline total number of airspace access requests was forecasted using the historical annual growth rate in requests (22%). The annual increase in flights due to the Regulations was then used to estimate the increase in airspace access requests. The percentage increase in the annual forecast number of flights under SFOCs, the advanced certificate, and the Level 1 Complex certificate, were used to calculate the anticipated increase in airspace access requests in the regulatory scenario. Given that NAV CANADA manually responds to 26% of access requests, it is anticipated that an average of 11 157 new annual requests will require manual authentication.

Costs

The total cost associated with the Regulations is estimated to be $26.61 million over the 10-year time frame. Of this, it is expected that $12.21 million will be incurred by industry, $8.75 million by the GoC, $3.93 million by recreational RPAS operators, and $1.73 million by NAV CANADA.footnote 11

Industry

Commercial operator and manufacturer costs are expected to total $12.21 million. These costs include fee costs and labour time to access services enabled by the Regulations for domestic operators and manufacturers. This is broken down into further categories for different certificates below.

1. RPAS Operator Certificate (RPOC)

An RPOC will be required for companies who want to conduct lower-risk BVLOS operations under the Regulations. It is anticipated that the majority of those who pay to obtain an RPOC will be organizations that employ multiple RPAS operators. However, individual operators recruited under a company’s RPOC could still opt to have their own. It is assumed that 80% of predicted Level 1 Complex operators will obtain an RPOC.

Costs to businesses associated with RPOCs are expected to total $6.75 million. These costs are comprised of upfront (incurred once per company) costs of $0.63 million, and ongoing time costs of $6.05 million (incurred throughout the timeframe), as well as service fees of $0.06 million. Upfront costs for RPOCs are associated with tasks such as appointing employees for tasks, organizational structuring, and training. Ongoing tasks for RPOC holders are expected to include tasks such as developing procedures for data collection and analysis, creating and maintaining an operation manual, and establishing a quality assurance program for maintenance. RPOC employee wages range from $42/hour to $71/hour (including an overhead rate of 25%). Per operator, upfront tasks are expected to take between 2 and 160 hours (depending on the task), while ongoing tasks are expected to take between 1 hour and 75 hours. Total upfront RPOC time requirements are anticipated to be 490 hours, while the ongoing annual workload is anticipated to take 1 079 hours. However, approximately 91% of upfront costs, and approximately 97% of ongoing costs, would be incurred under the baseline scenario (and therefore are not cost in the regulatory scenario) under BVLOS SFOCs. Under the regulatory scenario, total incremental upfront time requirements are therefore expected to be 45.25 hours, while total incremental annual time requirements are expected to be 28.5 hours. It is estimated that the incremental costs will apply to 613 individuals/businesses affected by the RPOC requirements. Assumptions relating to RPOC time costs were based on TC subject matter experts’ views.

2. Pilot certification regime (DMP certificates)

Costs associated with the DMP certificates include those related to the Advanced Pilot Certificate, Level 1 Complex Certificate, DMP account registration, and RPAS registration. Costs for these certificates will be expected to total $3.99 million with a large number of the costs occurring in 2026 when the largest influx of new registrants and operators occurs. Time costs for commercial operators related to Advanced Pilot Certificate and Level 1 Complex flights are calculated using a wage rate of $60.36 (wage rate for RPAS operators, which includes 25% overhead). This wage comes from an average of various sources on RPAS operator salaries/wages.footnote 12 Costs are further broken down into the different types of certificates below.

A) Advanced Pilot Certificate

Commercial RPAS operators will be required to hold an Advanced Pilot Certificate to conduct some of the categories of operations in the Regulations, including sheltered and EVLOS operations. Costs associated with this requirement are comprised of time costs for taking the Advanced Pilot Certificate exam and associated flight review.

Affected operators are expected to spend nine hours on the Advanced Pilot Certificate exam, and 0.75 hours on an associated flight review. For commercial operators, this will equate to time costs of $589, including 25% overhead.

Advanced Pilot Certificate operators will be required to pay fees associated with the obtaining the certificate, listed below:

To maintain their Advanced Pilot Certificate, operators will be required to show recency every two years in various ways, such as taking one of the DMP exams again, conducting a flight review, or taking the TC recency exam. For this analysis, it is assumed that the operators will either retake the Advanced Pilot Certificate exam (at a cost of $10) or take a TC recency exam (free of charge), both of which will take one hour. Based on TC’s internal data, it is estimated 69% of operators will take the Advanced Pilot Certificate exam for recency purposes. It is estimated that the total cost for Advanced Pilot Certificate operator recency will equal $0.10 million. Operators will be required to take this exam and retain the record of their passing.

The total costs for commercial operators associated with obtaining an Advanced Pilot Certificate are estimated to equate to $1.20 million, which breaks down into $0.81 million for taking exams, $0.26 million for flight review, $0.03 million for fees, and $0.10 million for demonstrating recency. Note that costs are not increasing for the Advanced Pilot Certificate over the baseline scenario; however, it is assumed that there will be an increased demand for the Advanced Pilot Certificate. The operators representing the increased demand will incur all the Advanced Pilot Certificate costs.

B) Level 1 Complex Certificate

Commercial RPAS operators will need to hold a Level 1 Complex Certificate to conduct lower-risk BVLOS operations. The total costs for commercial operators regarding the Level 1 Complex Certificate are expected to equal $2.50 million.

The costs for operators relating to ground school consist of the fee paid by the operator to enroll in a ground school course and the labour time-cost associated with attending the course. Over the 10-year analytical time frame, the time cost associated with ground school is estimated to be $1.13 million. It is assumed that the flight school will take 24 hours, including preparation and studying. Operators will also face a fee of $755. In total this will cost each operator $2,204, including 25% overhead. It is assumed that the $755 in fees will cover any associated incremental costs to ground schools associated with the Regulations.

These operators will also be required to take written and practical exams. The written exam requires nine hours (including studying) at a cost of $50 (per attempt), and the practical exam requires 0.75 hours at a cost of $262 to the flight reviewer (per attempt). In addition, operators may need to take these exams more than once before they succeed. It is estimated that each operator will incur a cost of $901 on these exams per attempt. Therefore, the total cost to all operators will be $1.24 million, of which $1.08 million is related to the written exam and $0.15 million is related to the practical exam.

To receive their Level 1 Complex Certificate, operators will need to pay a certificate fee of $125 to TC, which is expected to cost operators $0.06 million in total.

To maintain their Level 1 Complex Certificate, operators will be required to show recency every two years. This will work in the same way as the Advanced Pilot Certificate recency. Due to the higher cost of the Level 1 Complex Exam, it is assumed that all operators will take the free recency exam. In total, this is expected to cost operators $0.07 million over the time frame.

C) DMP account creation and drone registration

Operators will be required to create an account in the DMP to access the DMP services and register their RPAS. In total, account creation and RPAS registration are expected to cost $0.28 million. This can be broken down into $0.02 million in time costs for account creation (10 minutes per account creation); $0.005 million for drone registration (three minutes per registration); and 0.28 million in additional fee costs from the $5 increase in registration fees.

3. Increased operational expenses

Industry is expected to see an increase in operational expenses for several flight types associated with the Regulations. The requirement for a visual observer is expected to increase costs for EVLOS flights, and the population mapping requirement is expected to increase costs for flights under the Level 1 Complex certificate. Total costs related to increased operational expenses are expected to be $0.59 million.

It is estimated that 25% of incremental Advanced Pilot Certificate operations will include EVLOS. Most of the operations involving EVLOS are anticipated to occur under the baseline scenario associated with the Advanced Pilot Certificate while using visual observers and will see an increase in efficiency under the regulatory scenario. In the regulatory scenario, the observer would be more productive because the RPAS will be permitted within a wider distance of the observer relative to the baseline scenario, resulting in a reduction in time taken per operation. This will result in a cost savings for these operators due to the increased productiveness of the visual observer. It is anticipated that 75% of EVLOS operations will occur in this manner. The remaining 25% will be new operations generated by additional demand. For these operations, there will be an expected increase in operating costs of $151 per operation relating to a visual observer working for 2.5 hours. This is expected to result in total costs of $0.14 million.

Additional time costs associated with population mapping for Level 1 Complex Certificate flights will be incurred. It is assumed that it will take 10 minutes for operators to search for population data from publicly available sources (e.g., Statistics Canada’s census data), and to identify any local events or gatherings prior to conducting an operation. This will mean an increase in operating costs of $10.06 per operation and is estimated to result in total costs of $0.45 million.

All BVLOS flights under the Level 1 Complex Certificate will be required to perform a site survey. As all RPAS operations are required to have a site survey performed in the baseline scenario, no additional costs are expected to be incurred from this requirement in the regulatory scenario.

4. SFOC Fees

Industry SFOC operators will face costs due to the new SFOC fees: $20 for a very low complexity SFOC, $75 for a low complexity SFOC, $900 for a medium complexity SFOC, and $2,000 for a high complexity SFOC. In total it is expected that this will cost the industry an additional $0.80 million.

5. Pre-validated declarations (PVD)

Manufacturers will be impacted if they choose to seek a PVD for their drones. Costs associated with PVDs relate to the time taken for obtaining and maintaining the declaration, as well as issuance fees. The issuance fee for a PVD will be $1,200 each. It is assumed each PVD will require 260 pages, that each page will take 10 minutes to draft, and that the wages of the individual drafting the pages will be $60.36/hour, including overhead, in line with commercial operators. In addition to the initial PVD, upkeep will require manufacturers to notify TC annually and will be expected to take 15 minutes per PVD per year. Manufacturers will be expected to maintain their PVD status for five years, after which it is anticipated that 60% of the models will see an update requiring a new PVD, subject to the same issuance fee. It is anticipated to take 8.85 hours to update the PVD. Over the ten-year time frame, PVD-related costs for domestic manufacturers are expected to total $0.08 million.

6. Declarations for medium-sized drones

Manufacturers will see increased costs related to declarations for medium-sized drones if they choose to declare their models to TC. There is no fee associated with a declaration, but there will be time costs for manufacturers associated with drafting pages, and administrative costs associated with sending the declaration to TC. It is anticipated that there will be 50 medium-sized drone models sold by 20 domestic manufacturers over the analytical timeframe, with 25 of these models being sold in 2025. Each declaration is expected to take 44.25 hours to complete, including developing consumer documentation and familiarization with requirements. An estimated 60% of the drones released will have annual updates, requiring an additional 8.85 hours to complete. It is anticipated that 95% of these models released will meet all the above-listed requirements in the baseline scenario. There is a requirement to declare to TC regarding each new model, and each annual ongoing update, which is anticipated to take 15 minutes at a wage rate of $60.36/hour, including 25% overhead. In total, the incremental costs associated with declarations for medium drones are expected to be $0.01 million. Estimates on new drone models and baseline compliance were developed based on TC subject matter expert opinion.

7. Flight reviewer costs

Flight reviewers will be required to declare to TC that they will be offering flight reviews for the Level 1 Complex Certificate. This will affect an anticipated 165 flight reviewers. It will take each flight reviewer an estimated three minutes to send an email to TC. This will result in total estimated costs of $464 over the ten-year time frame.

Government of Canada

Costs to the GoC are expected to total $8.75 million. These costs are associated with the continued expansion and maintenance of the DMP, as well as stakeholder engagement, enforcement, the processing of declarations and PVDs. Costs associated with the tasks listed above are expected to be comprised solely of labour costs. These incremental costs are generated from additional employees that will be hired to assist with the enforcement and implementation of the Regulations. Total FTE counts will range from 10.21 in 2025 to 7.42 from 2028 to 2034. It should be noted that GoC costs listed here do not include costs incurred before the registration of the Regulations in 2025, which are out of scope for this analysis. These costs, which total about $1.72 million, include labour and technology invested into the expansion of the DMP to accommodate the new certificates and cost recovery. As these costs were incurred prior to the registration of the Regulations, they are considered sunk and, therefore, not within the scope of this analysis.

Recreational operators

Similar to the rules governing small RPAS operating within VLOS introduced in 2019 in the Regulations Amending the Canadian Aviation Regulations (Remotely Piloted Aircraft Systems), the Regulations do not establish separate rules for commercial and recreational operators. However, given the volume of recreational operators in Canada, it is important that this analysis assess how the Regulations will impact recreational operators.

Recreational operators will see costs related to the DMP certificates in the same way as commercial operators, which are expected to total $3.93 million. This is broken down further below.

To conduct certain categories of operations under the Regulations, recreational operators will be required to obtain either the Advanced Pilot Certificate or Level 1 Complex Certificate. These certificates will provide recreational operators with the same privileges as commercial operators. Fees and time costs associated with the Advanced Pilot Certificate and Level 1 Complex Certificate are expected to total $2.51 million and $0.34 million, respectively.

Recreational operators will also be subject to time costs associated with DMP account creation and drone registration. Costs will also be incurred related to the fee increase of $5. Total costs related to DMP account creation and drone registration are expected to total $1.08 million.

NAV CANADA

NAV Canada is expected to incur costs related to additional airspace access requests requiring manual processing (new requests to be processed by automation will not impose additional cost on NAV CANADA). In total, based on historical information provided by NAV CANADA, it is anticipated that the Regulations will result in an additional 11 157 requests to be manually processed. It is expected that an employee will need an average of 25 minutes to process a request. With the employee’s average hourly wage rate being $52.67 (including an overhead of 25%)footnote 13, it is estimated that NAV CANADA will incur a total cost of $1.73 million.

RPAS ground schools

It is expected that incremental costs to RPAS ground schools associated with new curriculum development will be covered by the fees paid by RPAS operators. However, there will be some administrative burden for ground schools associated with declaring to TC that they are offering the new curriculum and are compliant with the Regulations. This will take an estimated three minutes at an hourly rate of $60.36 including overhead. It is estimated that 18 out of 180 schools will declare to TC that they are offering the new curriculum resulting in a total cost of $50.77 ($2.82 per company). All declarations are expected to occur in 2025.

Benefits

The benefits of the Regulations are expected to total $73.65 million of which, $64.34 million would be realized by industry, $5.89 million by recreational operators, and $3.42 million by the GoC.

Industry (commercial RPAS operators)

Benefits to commercial operators are expected to total $64.34 million over the analytical time frame. This is broken down into the profit gained from new flights, and time cost savings for obtaining an SFOC.

Increased profit

In the regulatory scenario, more flights are expected to be performed due to the introduction of the Level 1 Complex Certificate and the expansion of the Advanced Pilot Certificate. In total, the expected benefit from the increased number of flights will be equal to $53.52 million. This can be broken into flights conducted under the Level 1 Complex Certificate, which are expected to introduce profits for RPAS operators of $23.71 million, and additional flights from the Advanced Pilot Certificate, which are expected to introduce profits for RPAS operators of $29.82 million. Note that this number represents only the profits generated for additional operators due to increased demand; it does not represent the profits from all Advanced Pilot Certificate operations as it is assumed that these would still be conducted under the baseline scenario. This also does not capture the increased population mapping and EVLOS operating costs presented in the Costs section of the analysis.

SFOC labour cost savings

Under the baseline scenario, TC’s ability to process SFOCs is at capacity. Under the regulatory scenario, there will be a greater capacity for TC to process SFOCs due to some baseline SFOCs being transitioned to the Advanced Pilot Certificate and Level 1 Complex Certificates. The decrease in required SFOCs is expected to save the industry $9.30 million in time costs over the analytical time frame. These benefits will stem from industry no longer needing to apply for as many SFOCs, and therefore not spending time on unneeded applications. This is calculated using the industry wage of $60.36 (including overhead) multiplied by the time cost associated with an SFOC application (20.5 hours). The total time costs in the regulatory scenario are then subtracted from the total costs in the baseline scenario to calculate time saved. It is anticipated that the industry will take 0.22 million hours less on SFOC applications in the regulatory scenario than in the baseline scenario.

Industry (RPAS manufacturers)

Domestic RPAS manufacturers will benefit from the Regulations due to the increase in demand for their products. Using the share of foreign and domestic manufacturers (based on historical declaration to TC), it is estimated that domestic manufacturers will sell an additional 1,929 drones over the 10-year time frame.footnote 14 Assuming the same profit rate of 47.3%, and an average sale price of $2,300, this will generate a benefit of $1.52 million for domestic manufacturers.footnote 15

Recreational operators

Recreational operators are expected to realize benefits associated with additional flights due to the introduction of new certificates. By using their new privileges under the Advanced Certificate, or by obtaining the Level 1 Complex Certificate, recreational operators will be permitted to safely carry out flights that had previously been prohibited or discouraged by the requirement to obtain an SFOC. New permissions will allow recreational operators to change the way that certain activities, such as drone racing and aerial photography, are conducted and may lead to further innovation through the allowance of greater creative freedom. Under the baseline scenario, certain events, such as First Person View (FPV) drone racing, require SFOCs to conduct. The Regulations will allow recreational operators greater opportunity to participate in this sport, as well as other recreational activities, while still maintaining safety.

The value of the additional leisure that will result from new RPAS operations was calculated based on a WTP methodology, which divides the average cost of a drone by the anticipated number of Advanced Pilot Certificate flights conducted. This is considered the lower bound of the willingness-to-pay, as such operators will also be willing to pay for other costs associated with RPAS operations, such as certificate fees and travel. Assuming that the average number of flights per year per type of certificate for recreational operators is the same as that for commercial operators, it is estimated that the recreational enjoyment per flight is equal to $14.70.footnote 16 Therefore, the Regulations are expected to result in a total of $5.73 million in benefit for recreational Advanced Pilot Certificate flights, and a total of $0.16 million in benefits for recreational Level 1 Complex flights. The total increase in recreational benefit is anticipated to be equal to $5.89 million.

Government of Canada

GoC benefits can be broken down to reduced costs to administer SFOCs in the early years of the program and fees collected from users for RPAS services.

Service fees

Service fees will be associated with certificate issuance and exams. As previously discussed, fees collected from domestic service users will rebalance the costs from Canadian taxpayers to service users and therefore have a neutral impact on Canadian society; however, fees collected from foreign service users will represent a benefit to Canadian society. In total, the GoC is expected to collect service fees of $3.10 million.

Fees for the Level 1 Complex exam, Level 1 Complex Certificate, PVD, and RPOC are all related to new services. Total incremental fee revenue for these new services is expected to be $0.48 million over the time frame. Fee revenue related to existing services, for which fees will be increased under the Regulations, is expected to equal $2.61 million over the time frame.

SFOC time cost savings

In comparison with the baseline scenario, there are expected to be fewer SFOC requests in the regulatory scenario in the early years of the analysis due to more operations being allowed under the Advanced Pilot Certificate and Level 1 Complex Certificate. This will result in cost savings for the GoC due to the decrease in demand for SFOCs. It is expected that these cost savings will total $0.33 million.

Cost-benefit statement
Table 4: Monetized costs (present value in millions)
Impacted stakeholder Description of cost 2025 Average 2026–2033 2034 Total (present value) Annualized value
GoC Administration $1.50 $0.84 $0.55 $8.75 $1.16
Industry (Commercial Operators) Certifications (Time and Fee Costs) $0.30 $1.30 $0.85 $11.53 $1.53
Increased Operating Costs $0.00 $0.07 $0.07 $0.59 $0.08
Industry (Manufacturers) Pre-Validated Declaration (Added Cost) $0.04 $0.00 $0.00 $0.08 $0.01
Declaration (Added Cost) $0.00 $0.00 $0.00 $0.01 $0.00
Recreational Operators Certifications (Time and Fee Costs) $0.07 $0.45 $0.26 $3.93 $0.52
NAV CANADA Airspace Access Authorizations $0.00 $0.19 $0.20 $1.73 $0.23
RPAS Ground Schools Declaration to TC $0.00 $0.00 $0.00 $0.00 $0.00
All stakeholders Total costs $1.92 $2.84 $1.94 $26.61 $3.54

Please note that costs in some rows are listed as $0.00 M because the cost was so low. For example, ground school declarations were $51 over the time frame. Because everything is reported in millions in this table, this was rounded down.

Table 5: Monetized benefits (present value in millions)
Impacted stakeholder Description of benefit 2025 Average 2026–2033 2034 Total (present value) Annualized value
GoC Fee Revenue (Existing Services) $0.38 $0.25 $0.22 $2.61 $0.35
Fee Revenue (New Services) $0.07 $0.05 $0.01 $0.48 $0.06
SFOC Labour Cost Saving $0.00 $0.04 $0.00 $0.33 $0.04
Industry (Commercial Operators) Increased Profits $0.00 $5.86 $6.68 $53.52 $7.12
SFOC Labour Cost Saving $0.00 $1.03 $1.04 $9.30 $1.24
Industry (Manufacturers) Increased Profits $0.00 $0.14 $0.44 $1.52 $0.20
Recreational Operators Increased Utility $0.00 $0.65 $0.69 $5.89 $0.78
All stakeholders Total benefits $0.46 $8.02 $9.07 $73.65 $9.80
Table 6: Summary of monetized costs and benefits (present value in millions)
Impacts 2025 Average 2026–2033 2034 Total (present value) Annualized value
Total costs $1.92 $2.84 $1.94 $26.61 $3.54
Total benefits $0.46 $8.02 $9.07 $73.65 $9.80
NET IMPACT -$1.46 $5.17 $7.14 $47.04 $6.26

Qualitative costs

The introduction of the requirement for microdrone users to obtain an SFOC in order to operate at an advertised event will result in costs for recreational operators. Given the physical/technological restrictions associated with the use of microdrones from commercial operators at advertised events, it is not anticipated that this requirement will have an impact on commercial operators. This is because a professional grade camera used for filming a commercial event would be too large to mount on a microdrone. Additionally, a microdrone battery would not likely be large enough for a professional filmer/photographer to capture an entire event. Therefore, in order to fly larger drones at advertised events, commercial operators would opt to apply for SFOCs for larger drones. Recreational operators, however, could see a decrease in enjoyment related to the new requirement.

The fees and time related to applying for an SFOC would likely discourage recreational operators to apply for SFOCs to use their microdrones at advertised events. The total average time required for an SFOC application has been estimated at 20.5 hours, and fees for this type of operation $75 (low complexity). Based on the wage rate for recreational operators of $23.61 per hour, this is expected to cost operators $559 in time and fees per application. This recreational wage was calculated based on the average wage of Canadians, weighted across provinces by the number of RPAS registrations. A willingness to pay methodology was used to calculate the value of a microdrone flight. An average microdrone costs $524, and there are an average of 19.55 flights per year with a RPAS lifespan of 1 to 8 years, therefore it is anticipated that a microdrone flight will impart a minimum of approximately $3 to $27 per flight in increased leisure enjoyment value.footnote 17 Note that this WTP value may be higher because consumers would be willing to spend on other aspects of the enjoyment of their drone such as travel costs. Given that the cost of an SFOC is close to the average cost of a microdrone, and much higher than the minimum enjoyment value, it is anticipated that few microdrone recreational operators would choose to apply for an SFOC for this purpose. Each flight which could no longer be conducted by a microdrone without an SFOC would therefore incur costs related to reduced enjoyment of at least $3. Calculation of the total impact of this provision on recreational operators was not possible, as TC does not have access to data on microdrone usage, or microdrone usage at advertised events. Furthermore, a survey would not be beneficial in this matter, as TC would not have a way to scale the results of the survey past the sample received without access to further data. For these reasons, a unit cost is presented. It should also be noted that current best practices suggest not using microdrones at advertised eventsfootnote 18, and that some provincial or municipal regulations already seek to limit the use of microdrones at advertised events (e.g., the city of Calgaryfootnote 19. These existing restrictions would lessen the marginal impact of the Regulations relative to the baseline scenario.

Because of the increased demand in the RPAS sector spurred by the introduction of the Regulations, there is anticipated to be a greater number of flights conducted relative to the baseline scenario. There is a possibility that in some instances RPAS activities could result in a greater amount of noise, which could be perceived as an annoyance by the Canadian population; however, the likelihood of this is low given BVLOS flights are only being permitted away from densely populated areas. As for VLOS flights with medium RPAS, the density of operations over populated areas is not anticipated to increase significantly, and therefore is not anticipated to cause a significant amount of noise pollution. This could result in qualitative costs associated with annoyance that is expected to be minimal. This could not be quantified due to the limited amount of information on the negative effects of drone noise.

Qualitative benefits

Commercial operators

Commercial operators may realize additional cost savings related to their ability to conduct certain types of BVLOS operations and use larger drones. Larger drones and BVLOS operations can cover more geographic area in a shorter period and can also collect more data in fewer deployments compared to VLOS operations. This is due to the operator not needing to keep the drone within their line of sight. Scenarios where the use of BVLOS over VLOS will result in cost savings for operators are likely specific to certain operators; however, due to lack of data on the specific flights of these operators, it was not possible to quantify this benefit. Additionally, if the benefits of transitioning from VLOS to BVLOS will offset the costs for specific flights in the baseline scenario, it is assumed that operators will have applied for an SFOC to realize these benefits. The ability for commercial operators to conduct BVLOS flights under certificates, as well as the additional processing availability for more complex SFOC applications, are expected to lead to an increase in innovation among commercial operators. Greater freedom to conduct BVLOS operations may lead to new ways to use RPAS under existing certificates. Overall, greater flexibility is expected to lead to an increase in services provided to Canadians and drive the RPAS market forward in new ways.

The Regulations will introduce requirements related to visual observers for EVLOS flights. It is anticipated that these flights will replace flights that have been occurring in the baseline scenario with existing visual observers. The Regulations will allow greater freedom for the visual observers and will require fewer visual observers to be present for these operations. Overall, this is expected to result in cost savings for those exercising these new privileges in the regulatory scenario. Additionally, it is anticipated that EVLOS will improve operator productivity.

Manufacturers

RPAS manufacturers may decide to complete a PVD for their drones. This may result in some benefit to the manufacturer in the form of increased profits. Consumers may be more inclined to purchase an RPAS with PVD over one without because the PVD will provide confirmation that the RPAS is pre-approved for certain types of operations without needing modifications. Although the number of expected PVDs was estimated in the analysis, it is unknown how PVDs will influence Canadian RPAS sales. PVDs may provide manufacturers with new opportunities to differentiate and broaden demand for their products. Similar benefits will be realized by manufacturers who opt for declarations for their medium-sized drones.

Bystanders and traditional aviation

Bystanders and traditional aviation will benefit from continued safety risk mitigation. This will come from highly skilled operators improving their abilities and having a better understanding and ability to conduct more Advanced Pilot Certificate flights, such as BVLOS. The Regulations will ensure the continued safe operation of commercial and recreational operators as they conduct more Advanced Pilot Certificate flights. Airspace above advertised events will be better controlled due to the introduction of the SFOC requirement for microdrone operators, which is expected to result in further safety risk mitigation.

Distributional analysis

Service fees

The Regulations will increase some existing service fees and introduce new service fees for both domestic and foreign service users. Table 7 below shows the additional fees that will be collected by the GoC from domestic and foreign service users.

Table 7: Service fees paid by domestic and foreign service users (present value in millions)
Service users Base year
(2025)		 Average
(2026–2033)		 Final year
(2034)		 Total
(present value)		 Annualized value
Domestic $0.38 $0.26 $0.21 $2.65 $0.35
Foreign $0.08 $0.04 $0.03 $0.45 $0.06
Total $0.46 $0.30 $0.23 $3.09 $0.41
Costs and benefits by certificate type

Tables 8 and 9 break down the costs and benefits associated with the Advanced Pilot and Level 1 Complex Certificates. Note that the costs do not add up to the total certificate values presented in the CBA Statement, which also includes RPOCs and SFOCs.

Table 8: Domestic Operator Costs from Advanced Pilot and Level 1 Complex Certificates (present value in millions)
Stakeholder Certificate Type Base year
(2025)		 Average (2026–2033) Final year
(2034)		 Total
(present value)		 Annualized value
Recreational Operators Advanced Pilot Certificate $0.00 $0.30 $0.14 $2.51 $0.33
Level 1 Complex Certificate $0.00 $0.04 $0.01 $0.34 $0.04
Commercial Operators Advanced Pilot Certificate $0.00 $0.14 $0.07 $1.20 $0.16
Level 1 Complex Certificate $0.00 $0.30 $0.08 $2.50 $0.33
Total $0.00 $0.78 $0.30 $6.55 $0.87
Table 9: Domestic Operator Benefits from Advanced Pilot and Level 1 Complex Certificates (present value in millions)
Stakeholder Certificate Type Base year
(2025)		 Average
(2026–2033)		 Final year
(2034)		 Total
(present value)		 Annualized value
Recreational Operators Advanced Pilot Certificate $0.00 $0.63 $0.67 $5.73 $0.76
Level 1 Complex Certificate $0.00 $0.02 $0.02 $0.16 $0.02
Commercial Operators Advanced Pilot Certificate $0.00 $3.25 $3.83 $29.82 $3.97
Level 1 Complex Certificate $0.00 $2.61 $2.85 $23.71 $3.16
Total $0.00 $6.51 $7.37 $59.42 $7.91

Sensitivity analysis

Single variable sensitivity analysis

Due to the relative infancy of the RPAS industry, there is some uncertainty behind the estimates and assumptions used in this analysis. A sensitivity analysis was therefore conducted on some of the most impactful variables.

RPAS growth rates

Three scenarios are derived from three growth rates developed by the U.S. FAA. The central scenario represents the price structure used in the main body of the analysis with a lower and upper scenario hypothesized in the sensitivity analysis. The effects of changing this parameter are shown in the table below.

The drone registration forecast from the U.S. FAA Aerospace Report (2024–2044) presented three growth scenarios (low, central, and high). The average growth rates from 2019 to 2028 are projected to be 1%, 13%, and 14% for the low, medium and high growth scenarios respectively, with annual growth rates varying year by year. The exact growth rates calculated from the FAA drone registration forecast were used to forecast registrations up to and including 2028. For the years following 2028, an average growth rate, calculated from historical DMP data and the FAA forecast, was used. This average growth rate is presented in parentheses in the first row of the following table.

Table 10: Sensitivity analysis: growth rates (present value in millions)
Growth Scenarios Low Scenario (0.9%) Central Scenario (2.9%) (Central Analysis) High Scenario (3.4%)
Net benefit $41.24 $47.04 $48.04
RPAS Lifespan Sensitivity

Three scenarios are derived from three different drone lifespans, used to calculate total registrations. The central scenario represents the high estimate, which is used in the main body of the analysis with a lower and middle scenario hypothesized in the sensitivity analysis. The effects of changing this parameter are shown in the table below. Drone lifespan was used to determine after how many years an operator would need to purchase a new drone. The ’high’ estimate was used in the central analysis because it is likely that some or most of re-registrations were already included in the baseline forecasting. This would impact total costs associated with registrations, as a lower lifespan would increase re-registrations as new drones were purchased. This would also influence the minimum value for enjoyment from recreational operators, as a lower drone lifespan would mean a higher WTP for each flight (there would be fewer flights conducted with a drone for the same amount of money spent). Note that these effects compound across the analysis as an increased number of operators would need to replace their drones more frequently. This results in exponential increases in costs and benefits as the lifespan of a drone decreases.

Table 11: Sensitivity analysis: RPAS lifespan (present value in millions)
Growth Scenarios Low Scenario (1 year) Middle Scenario (4 years) High Scenario (8 years) (Central Analysis)
Costs $29.72 $27.16 $26.61
Benefits $122.97 $80.78 $73.65
Net benefit $93.25 $53.63 $47.04
RPAS profit margin

To calculate the anticipated benefits for commercial RPAS operators, the profitability rate from NAICS 48121 (Non-Scheduled Air Transportation) was applied to forecast operator and manufacturer revenue. A range of profitability for Non-Scheduled Air Transportation was presented in this source. In the central analysis, the average of the profitable quartiles of companies was used. The non-profitable companies were excluded because it is assumed that operators using the Advanced Pilot and Level 1 Complex Certificates will have already been successful with basic flights before expanding their business. The table below shows how the net benefit would be affected if the profitability of the sector fell to the lower or higher profitability rates as presented in the GoC Financial Performance Canadian Industry Statistics.

Table 12: Sensitivity analysis: RPAS profit margin (present value in millions)
Profitability Rate 7% 34.9% 47.3% (Average) (Central Analysis) 100%
Net Benefit $0.14 $31.56 $47.04 $108.37
SFOC additional profit

This sensitivity analysis explores how the profit per operation is expected to increase if the profit generated per SFOC operation increases in the regulatory scenario. In the central analysis, the revenue per flight is increased by the additional costs that operators will incur due to the fee increases for SFOCs, with profit being calculated based on the industry profitability rate. This sensitivity analysis shows what would occur if the profit were increased past this point by percentage intervals. Intervals presented a range from 0% (central analysis) to 50%. The profit per operation, as well as the net present value for each scenario, are shown below.

Table 13: Sensitivity analysis: SFOC profit
Additional Profit 0% (Central Analysis) 10% 30% 50%
Profit per SFOC Operation (Baseline / Regulatory) $694 / $719 $694 / $721 $694 / $726 $694 / $731
Net benefit (present value in millions) $47.04 $47.15 $47.37 $47.59
Discount rate

The central analysis used a 7% discount rate as recommended by the TBS. For the sensitivity analysis, the table below presents the results should a 0% discount rate have been used, as well as a 3% discount rate. These three discount rates were selected as in line with TBS’s Cost Benefit Analysis Guide for Regulatory Proposals.

Table 14: Sensitivity analysis: Discount rates (present value in millions)
Discount Rates 0% 3% 7% (Central Analysis)
Net benefit $71.03 $59.19 $47.04
Monte Carlo analysis

The sensitivity analysis above considers what happens to the net benefit in the central and extreme values. However, some of the variables may not be constant values, and may have probability distributions associated with them. A Monte Carlo simulation was performed, with some variables being assumed to have probabilistic distributions where there was a large amount of uncertainty. These variables include the initial reduction rate for SFOCs (triangular distribution ranging from 0.6 to 0.95), and the SFOC Efficiency improvement (triangular distribution ranging from 5% to 20% annual improvement). The initial reduction rate for SFOCs represents the percent decrease in domestic SFOC applications received in 2026 as operators are able to exercise their new privileges. SFOC Efficiency improvement represents the increase in efficiency for TC SFOC processors over five years. A simulation was run 1 000 times, and the mean values were reported as the central analysis throughout the text.

A Monte Carlo simulation was performed to measure how often the total net benefits would be less than the central value (estimated total net benefits), and how often the total net benefits would be less than 0. In other words, what percentage of the time the net benefit is less than the central value, or 0, given the distributions applied to the variables above. The results from the simulations indicate that, holding the non-distributional sensitivity parameters constant, 51.5% of the time, the total net benefit is less than the central value, and that 0% of the time the total net present value is less than 0.

Scenario sensitivity analysis

Scenario sensitivity analyses were conducted where the lowest, most probable, and highest total net benefits were considered. For this exercise, the total net benefit was evaluated at its extreme values, such that the net benefits could be analyzed at their upper and lower bounds. The variables that were considered for these analyses were the same used for the single-variable sensitivity analysis (excluding discount rate, and RPAS lifespan), as well as in the Monte Carlo analysis, and were combined simultaneously, arriving at three different scenarios. For the lowest, and highest scenarios, the respective minimum, and maximum values were taken from the Monte Carlo Simulations.

The table below presents the sensitivity of total net benefits. This includes the SFOC reduction rate, the three different growth scenarios provided by the FAA, the profit margin for RPAS operators, the SFOC Efficiency improvement, the RPAS registration time, and the additional profit under regulatory SFOC flights.

Table 15: Sensitivity analysis: Scenario sensitivity (present value in millions
Results Lowest Most Probable Highest
Total Net Benefit -$2.11 M $47.04 M $126.60 M

Small business lens

Analysis under the small business lens concluded that the Regulations will impact small businesses.

The Canadian drone industry can be characterized as “fragmented and primarily comprised of small operators with stable but stagnant revenues,” with the median total yearly revenue of drone organizations being below $500,000, according to the 2019 Avascent RPAS Environmental Scan. The same report found that, as of 2019, over 50% of organizations in the drone industry were founded less than five years ago. Some of the RPOC measures that businesses may need to take to comply with the Regulations include developing flight operations procedures and training crew on flight operations procedures. Measures such as following a maintenance schedule are already standard provisions in lower-risk BVLOS SFOCs. It is expected that 613 companies will need to comply with the RPOC requirements. The average annual cost per company for obtaining and maintaining a RPOC is expected to be $1,101. The Aerial Evolution Association of Canada’s 2021/22 RPAS Industry survey estimates that 83% of the affected businesses will be considered small businesses. This means that 509 small businesses will be affected by RPOC requirements which will result in an estimated total cost to small businesses of $5.60 million.

Small businesses will be required to create DMP accounts and register RPAS within the DMP. Total administrative costs related to time taken to create accounts and register RPAS in the DMP from new small business entrants are expected to be $17,230. There will also be a fee increase from $5 to $10, which will affect all forecasted RPAS registrations, not just new entrants. In total, this will result in costs of $0.22 million to small business RPAS operators.

In addition, new fees will be applied to SFOCs, which are expected to result in a total cost of $0.66 million for small businesses over the ten-year time frame.

Small businesses are expected to incur increased operating costs, as discussed in the “Costs” section. Increased operating costs for small businesses associated with population mapping are expected to be $0.37 million, and increased costs associated with visual observers for EVLOS are expected to be $0.12 million.

Although the upfront costs for operators (including small businesses) will increase, the Regulations will allow operators to conduct more operations without an SFOC, which would not have been permitted in the baseline scenario. Additionally, while operators may have been able to conduct certain advanced operations with an SFOC in the baseline scenario, the number of SFOCs that TC is able to process is at capacity. Therefore, if an operator wanted to conduct an operation under an SFOC in the baseline scenario, they might face a long wait time and may not be able to complete their flight in the time they had planned. In the regulatory scenario, operators will face higher upfront costs upon market entry as they will need to obtain the necessary certifications; however, recurring labour costs will be significantly reduced due to the elimination of SFOC requirements for many operations. Therefore, the Regulations will benefit small businesses because they will facilitate more advanced use of RPAS.

RPAS manufacturers will be affected by the Regulations as they may opt to apply for a PVD. This will guarantee that their RPAS will be equipped to conduct more advanced flights, such as BVLOS. There is uncertainty around how many small manufacturers as a subset of all manufacturers will apply for PVDs. Assuming that each manufacturer will apply for one PVD, there will be 17 small businesses that will apply for a PVD and maintain updates for the PVD over 5 years. This will equate to total costs of $0.07 million for small business manufacturers including the fees that they will have to pay. PVD applications will not be mandatory, but manufacturers will benefit from the predictability that a PVD may afford (e.g., increased demand for and investment in the manufacturer’s products).

Similar to the impact of PVDs, RPAS manufacturers producing medium RPAS will be impacted if they choose to apply for a declaration. It is anticipated that there will be 16 small businesses producing medium drones with declarations. The use of declarations will result in incremental costs to manufacturers of $0.02 million. Note that, as with PVDs, declarations will not be mandatory for manufacturers, but manufacturers will benefit from increased sales and predictability if they choose to do them.

Flight schools and flight reviewers will see increased administrative costs related to declaring to TC that they are able to provide their associated services related to the Level 1 Complex Certificate. One hundred and sixty five flight reviewers and 18 ground schools will be affected. It is estimated that flight reviewers will face total costs of $464, and ground schools will face total costs of $51 over the ten-year time frame. Each of these stakeholders is assumed to be a small business.

Small businesses are expected to realize benefits as a result of the Regulations. The new certificate types (Level 1 Complex and modified Advanced Pilot Certificates) will allow small businesses to conduct flights which were not permitted (other than under SFOCs) in the baseline scenario. This is expected to lead to $44.43 million in additional profits for small businesses. The introduction of the new certificate types will create time cost savings of $7.72 million for small businesses related to SFOC applications, which will no longer need to be submitted. Manufacturers will also see benefits from increased profits, resulting in total profits for small businesses of $1.26 million. In total, the Regulations are expected to result in benefits to small businesses of $53.40 million.

Because of data limitations, it is unknown exactly how many of the operations listed below will occur per business. The total number of businesses impacted below represents the total number of expected commercial activities.footnote 20 It is likely that this is an overestimation of the number of businesses, as each small business will likely be subject to multiple occurrences of one or more of the activities listed below. However, there are no data to support this assumption.

Small business lens summary
Table 16: Small Business Benefits (presented in millions)
Administrative or compliance Description of benefit Present value Annualized value
Administrative SFOC application time cost savings $7.72 $1.03
Compliance Additional profits - commercial operators $44.43 $5.91
Additional profits - manufacturers $1.26 $0.17
Total $53.40 $7.10
Table 17: Small Business Costs (presented in thousands [K], and millions [M])
Administrative or compliance Description of cost Present value Annualized value
Administrative DMP Account and RPAS Registration Time Costs $17.2 K $2.3 K
ROC Administrative Requirements $0.1 K $0.0 K
PVD Administrative Requirements $1.2 K $0.2 K
Declaration Administrative Requirements $2.4 K $0.3 K
Ground School and Fight Reviewer Declarations $0.5 K $0.1 K
Compliance RPAS Registration Fees $0.22 M $0.03 M
RPOC Compliance Requirements $5.60 M $0.75 M
Increased SFOC Fee $0.66 M $0.09 M
Increased Operating Costs $0.49 M $0.07 M
PVD Compliance Requirements $0.06 M $0.01 M
Declaration Compliance Requirements $0.01 M $0.00 M
Total $7.06 M $0.94 M
Table 18: Small Business Net impacts
Amount Number of Impacted Businesses Present value Annualized value
Net impact on all impacted small businesses 33,675 $46.34 M $6.17 M
Average net impact on each impacted small manufacturer table d15 note * 36.6 $32.4 K $4,307
Average net impact on each impacted small operator table d15 note * 33,455 $1,350 $180
Average net impact on each impacted small flight reviewer 165 -$2.82 -$0.38
Average net impact on each impacted small ground school 18 -$2.82 -$0.38

Table d15 note(s)

Table d15 note *

 Profits and costs are incurred in the same categories as described in the costs and benefits section of the RIAS. For example, manufacturers incurred costs related to declarations and PVDs, and benefits related to increased sales profits.

Return to table d15 note * referrer

One-for-one rule

The one-for-one rule applies since there will be an incremental decrease in administrative burden on business, and the proposal is, therefore considered, burden ’out’ under the rule. No regulatory titles are being repealed or introduced.

All listed values below are presented in 2012 dollars, discounted to the base year of 2012 at a 7% rate, for a 10-year period between 2025 and 2034.

It is expected that there will be a decrease in administrative burden due to the decrease in SFOC applications. In the baseline scenario, an average SFOC application would take 20.5 hours to fill out. This would need to be sent to TC and approved to complete certain operations. The Regulations will allow businesses to complete some operations under an Advanced Pilot Certificate or Level 1 Complex Certificate. This will eliminate administrative time costs for industry, due to the decreased need to send in SFOC applications. In total, this decrease in SFOC applications is expected to result in annualized administrative burden cost savings for operators of $0.40 million (see SFOC labour cost savings in the Benefits section for more information).

The new administrative tasks associated with the Regulations will be the creation of accounts in the DMP, the registration of RPAS in the DMP, and declaring to TC that RPOC companies meet the requirements in the CARs, which are all one-time activities. Account creations are expected to take 10 minutes to complete, and RPAS registrations are expected to take three minutes, both at a wage rate of $46.76 including overhead. RPOC declarations include three tasks that are expected to take 30 seconds each.footnote 21 Wages would range from $32.80 to $50.31 including overhead for the tasks.

RPAS manufacturers will also need to report to TC on a regular basis as part of the process to obtain a PVD. It is anticipated that this will take 15 minutes annually, costed at a wage rate of $46.76 including overhead. Manufacturer declarations will also require reporting to TC for the initial declaration and any subsequent model updates; time costs for this are anticipated to be the same as the annual reporting for PVDs. The anticipated annualized increase in administrative burden associated with these new administrative activities is expected to be $62.85.

There will be some associated administrative burden with ground schools declaring to TC that they are offering the new curriculum. This is expected to take three minutes at an hourly rate of $46.76, including overhead. It is estimated that 18 out of 180 schools will declare to TC that they are offering the new curriculum resulting in an annualized cost of $2.17. All declarations are expected to occur in 2026. Flight reviewers will also be required to declare to TC that they are offering services related to the Level 1 Complex Certificate. This is anticipated to impact 165 flight reviewers, who will be required to email TC. It is anticipated that this will take three minutes per operator at a wage rate of $46.76, and will result in annualized administrative costs of $19.86. All activities are anticipated to occur in 2025.

The net annualized impact of the change in administrative burden on business is expected to be an annualized reduction of $396,526 in 2012 dollars, discounted to 2012 at a 7% rate.

Table 19: Annualized Administrative Burden Values
Present value base year: 2012
Annualized Reduction in Administrative Cost $396,526
Annualized Reduction in Administrative Cost Per Business $256.40

Regulatory cooperation and alignment

TC maintains several strong bilateral and multilateral relationships with countries around the world to align and harmonize with international partners wherever possible, to support research and development, contribute to standards development, and share information and best practices. TC also actively engages and participates with ICAO in areas, such as the RPAS Panel, Drone Enable (a symposium that engages stakeholders across disciplines), and various innovation discussions. Currently, the CARs only regulate domestic RPAS operations; however, TC continues to work closely with international counterparts, notably the U.S., to minimize differences between domestic regimes in preparation for allowing cross-border and international operations in the future.

Twice a year, TC meets bilaterally with the U.S. FAA to discuss drone policy and regulatory and program development, and more frequently as part of a working group tasked with developing a framework for future cross-border operations and mutual recognition. Canada also meets biweekly with aviation authorities in the U.S., Brazil, and the EU as part of a quadrilateral group focusing on aligning, harmonizing, and sharing best practices related to the system safety requirements of the drone. TC has a close working relationship with Australia and a Memorandum of Understanding is under development to further strengthen the partnership.

Canada’s approach to larger drones and lower-risk BVLOS operations is like other countries, such as the U.S., Brazil, and the EU, who currently permit BVLOS operations on a case-by-case basis with restrictions, such as maximum altitudes, system requirements for the manufacturer and additional pilot certifications via similar means to an SFOC.

Canada is one of the first countries to introduce regulations for routine BVLOS operations; however, the Regulations are aligned with the direction of other international partners, such as the EU, on topics including weight thresholds, new pilot certification, and emphasis on organizational requirements with the RPAS Operator Certificate. In March 2022, the FAA’s Aviation Rulemaking Committee published a report that provides information, advice, and recommendations for proposed BVLOS operations in the U.S. The report aligns well with TC’s approach in areas such as extended VLOS and sheltered operations, carving out lower-risk operating environments and incremental approaches to system safety and pilot certification. In August 2024, during the BVLOS Part 108 panel of Baltimore’s FAA symposium, the FAA provided an overview of what is being considered for their proposed BVLOS rules and the intent largely aligns with TC’s requirements introduced in Part IX of the CARs. However, the FAA is still in active rulemaking, and a final proposal has not yet been published.

As part of standards development, TC is also a member of the JARUS, which is a group of regulatory experts in aviation from around the world. TC also participates in other working groups with the Radio Technical Commission for Aeronautics and American Society for Testing and Materials. These working groups informed the Standard 922 performance targets related to maintaining connectivity between the drone and its control station, and the effects of weather conditions on various drone designs.

Lastly, TC also conducted international comparisons to verify that the drone fees in the Regulations are generally within the range of those of other countries. Since Canada is one of the first countries amongst its international partners to introduce regulations and fees that enable routine lower-risk BVLOS operations, there are few countries that offer direct comparisons for BVLOS drone fees. To address this, TC looked at fees for drone activities more broadly, in jurisdictions pursuing similar regulatory approaches and safety education initiatives to Canada, namely the U.S., EU, United Kingdom (UK), and Australia, to help evaluate foreign fee comparability. Overall, TC’s drone fees, where comparable, are like those of other countries, particularly when considering that TC’s drone certificates and registrations do not expire. For example, in the U.S., drone fees range from a low of C$7 for a drone registration (valid for three years) to a high of C$211 for a “remote pilot certificate” (valid for two years). TC’s equivalent fees are $10 for a drone registration and between $25 and $125 for a pilot certificate. The UK’s Permissions for Commercial Operation have fees of C$332 to C$431 while TC’s equivalent, the RPOC, will cost $125.

Strategic environmental assessment

In accordance with the Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals, and the TC Policy Statement on Strategic Environmental Assessment (2013), the strategic environmental assessment process was followed for this regulatory proposal and a Sustainable Transportation Assessment was completed. The assessment considered potential effects to the environmental goals and targets of the Federal Sustainable Development Strategy. The assessment determined that the Regulations are not expected to have any significant environmental effects.

While TC does not have sufficient data to quantify the potential impacts, there could be some incremental environmental benefits from reducing reliance on traditional aircraft for certain activities, and from the increased use of drones in emergencies, such as forest fires.

Gender-based analysis plus

The Regulations are not expected to have differential impacts on the basis of identity factors, such as gender, race, ethnicity, sexuality, religion, etc. However, it should be noted that aviation is historically a male-dominated industry, and the drone industry is similar. The 2019 Avascent RPAS Environmental Scan revealed that Canadians who identify as female represent only 2.6% of the Canadian drone industry. The drone industry is also largely made up of higher-income brackets. TC will be seeking opportunities to work with industry and other government departments to improve the understanding of the benefits of the drone sector on the quality of life in all group sets through data collection activities in employment and participation in the sector.

Implementation, compliance and enforcement, and service standards

Implementation

The Regulations have a staggered coming into force period whereby some provisions come into force on April 1, 2025, but if they are published in the Canada Gazette, Part II, after that day, they come into force upon publication, such as the ability to register drones, submit declarations and take new pilot exams, while the remaining provisions will come into force on November 4, 2025, such as the provisions that relate to carrying out operations with medium-sized drones and beyond visual line-of-sight in lower-risk environments. This will give stakeholders the opportunity to become certified and familiarize themselves with the new requirements in advance of the 2026 flying season, while avoiding having the new rules come into force during peak flying season in 2025.

Expanding digital services

TC is expanding the existing DMP to deliver the new services. More specifically:

The upgrades to the DMP have been developed in advance of final publication of the Regulations so that these services are available on April 1st, 2025, or upon publication in the Canada Gazette, Part II, whichever comes the latest. However, as mentioned above, pilots will not be able to fly under the new rules until November 4, 2025. This will allow time for certification, while also considering an increase in traffic volume in the DMP and any potential delays that may occur. Should there be system delays, TC has established related service standards that are discussed in more detail below.

The DMP meets the TC Digital Services Delivery and G0C standards for information protection, security, and management. TC will be carrying out a new assessment for the expansion to support the Regulations and new services that will be delivered. The DMP currently uses a secure sign-in using GCKey and TC added additional security measures, such as two-factor authentication, as part of the new DMP functionalities. TC also conducted a Privacy Impact Assessment for the system upgrades to support the Regulations to ensure the effective management of personal data.

TC updated the Drone Site Selection Tool (DSST), a situational awareness map depicting essential data layers for lower-risk BVLOS, such as population density, aerodromes, control airspace, and detect and avoid requirements. TC developed a new version of the DSST in support of the Regulations that will be available on April 1st, 2025, or upon publication in the Canada Gazette, Part II, whichever comes the latest. It will be a key service to help RPAS pilots choose suitable flight sites.

Education and outreach

TC has developed a safety awareness strategy that will be launched upon publication of the Regulations in the Canada Gazette, Part II, to further engage stakeholders in order to maintain and improve the safety of Canadian airspace by supporting a well-informed RPAS industry while encouraging innovation and interest in aviation. TC will also continue to develop guidance material, such as advisory circulars, updates to the Aeronautical Information Manual and TC Drone webpage, which are available on TC’s website to support implementation of the Regulations and help industry know how to comply with the new rules. Some documentation will be developed on a continuous basis to support the on-going needs of the program.

Compliance and enforcement

The safe operation of drones in Canada remains a shared responsibility between TC and drone pilots. Under the Aeronautics Act, the Minister of Transport has the authority to issue administrative monetary penalties (AMPs) to anyone who violates designated provisions of the Act and the CARs. Most of the provisions in Part IX of the CARs are enforced through the assessment of AMPs imposed in accordance with sections 7.6 to 8.2 of the Act, which carry a maximum fine of $5,000 for individuals and $25,000 for corporations and include the potential suspension or cancellation of a person’s Canadian Aviation Document. The Regulations will continue to be enforced through the assessment of AMPs.

More serious contraventions could be pursued as indictable offences or be punishable on summary conviction, where permitted. In some cases, for less serious offences, TC Enforcement officers may offer oral counselling before issuing an AMP. TC uses a graduated enforcement system whereby lower penalties are commonly used for first-time offenders, if applicable. For more severe or repeated violations, higher penalties may be issued.

Surveillance

As part of an effective oversight program, TC conducts surveillance activities to monitor compliance with safety requirements (e.g., planned and reactive inspections). A surveillance strategy has been developed and integrated into department-wide surveillance activities and the National Oversight Plan for Civil Aviation. The surveillance strategy for drones primarily focuses on higher-risk areas, such as ensuring that manufacturers are compliant with the pre-validated declaration requirements, and that RPOC holders are compliant with the regulatory requirements. TC will also perform ad hoc surveillance if any incidents occurred.

Service standards

Most of the new services will be available online through TC’s DMP, such as drone registration and exam delivery for the new RPAS Pilot Certificate for Level 1 Complex Operations. Other services, such as the delivery of ground school and flight reviews will be delivered by third parties. TC’s online services are available on demand and delivered in real time through the DMP — a secure system — 24 hours a day, seven days a week. Sometimes, the online system may encounter difficulties and intervention may be required. In these cases, there is a 10-day service standard. Other new services that are offered through the DMP, such as pre-validated declarations and the issuance of SFOCs, will require reviews from subject matter experts in aviation and engineering and will have different service standards, as outlined in the table below.

The design of the DMP requires the completion of each step in order to move forward. For example, once a pilot successfully completes the online exam, they will be able to proceed to their flight review; and, once that is successfully completed, they will be eligible to apply for the pilot certificate, which will be issued automatically. If an exam or flight review is not passed, the pilot will be able to re-do that step after 24 hours have passed.

Table 20: TC’s activities and new service standards
Category Activity Service Standard
Drone Registration Issue a Certificate of Drone Registration Issue the certificate of registration upon receiving a complete online application. If issues occur and intervention is required, TC will issue the certificate of registration 10 business days after receiving a complete application.
Exams Conduct an exam for Level 1 Complex Operations Provide exam results upon receiving a completed online exam. If issues occur and intervention is required, TC will provide the exam results within 10 business days after receiving a completed exam.
Certificates Issue a pilot certificate for Level 1 Complex Operations Issue the pilot certificate upon receiving a complete online application. If issues occur and intervention is required, TC will issue the pilot certificate within 10 business days after receiving a complete application.
Manufacturer Declarations Acceptance Letter – Pre-Validated Declaration Issue the acceptance letter within 60 business days of receiving a complete application.
Operator and Operations Certificates Issue an RPAS Operator Certificate (RPOC) Issue the RPAS operator certificate upon receiving a complete online application. If issues occur and intervention is required, TC will issue the RPAS operator certificate within 10 business days after receiving a complete application.
Issue a Special Flight Operations Certificate (SFOC) – Very Low Complexity Issue the Special Flight Operations Certificate within 30 business days of receiving a complete application.
Issue a Special Flight Operations Certificate (SFOC) – Low Complexity Issue the Special Flight Operations Certificate within 30 business days of receiving a complete application.
Issue a Special Flight Operations Certificate (SFOC) – Medium Complexity Issue the Special Flight Operations Certificate within 60 business days of receiving a complete application.
Issue a Special Flight Operations Certificate (SFOC) – High Complexity Issue the Special Flight Operations Certificate within 60 business days of receiving a complete application.
Re-issue a Special Flight Operations Certificate (SFOC) with a minor amendment Issue the Special Flight Operations Certificate within 30 business days of receiving a complete application.

These service standards apply to activity requests whereby the client has successfully met the application criteria. The service standards will be reconsidered two years after the Regulations come into force. Most services will be automated, with minimal tracking required. Other services, such as SFOCs and PVDs, will be tracked manually in conjunction with other departmental tracking systems.

The SFA requires the Minister of Transport to remit a portion of fees that have been collected if the applicable service standard is not met. Remission would take place according to TC’s Policy on remissions.

Contact

RPAS Task Force, AARV
Civil Aviation
Safety and Security
Transport Canada
Place de Ville, Tower C
Ottawa, Ontario
K1A 0N5
Telephone: 613‑993‑7284 or 1‑800‑305‑2059
Email: TC.RPASInfo-InfoRPAS.TC@tc.gc.ca