I just finished writing a letter to our Transport Minister. Will be on it's way to him come Monday when the mail goes out. Here it is for the interested (I also prepared versions of this letter to my local MP and to J. Trudeau):
The Honourable Marc Garneau, P.C., M.P.
Minister of Transport
House of Commons
Ottawa, ON K1A 0A6
Dear Minister:
I am a recreational drone pilot writing to express my concerns regarding the new drone regulations.
Let me first tell you a little about myself. I am a first-year university student studying physics and chemistry. For as long as I can remember, I have always been fascinated with aviation and rocketry (and space exploration). In 2010, I received my first model rocket as a gift. Seven years later, I have achieved my high-power rocketry certification levels 1 through 3 as a member of the Canadian Association of Rocketry. I became interested in drones and aerial photography about two years ago when, after saving up my summer earnings, and after doing extensive research, I purchased a DJI Phantom drone.
As I’m sure you are aware, drone technology has undergone staggering advancements in the last few years. Most modern drones now feature a direct live HD video feed; built in GPS with auto return to home; safe landing capabilities in the event of a loss of signal with the controller (or a low battery); and sensors for obstacle detection and avoidance. Today’s hobby drones are very safe and reliable.
By and large, the community of drone-flying enthusiasts is made up of people who take great care and pride to fly in a responsible fashion. Increased affordability and improved technology have led to a surge in the popularity of hobby drones. It makes sense then that regulations need to be in place to ensure that all operators have the knowledge and ability to operate a drone safely. I believe that the new rules recently announced are well-intentioned, but I also sincerely believe that they are unreasonably restrictive and harsh. They will have an unnecessarily strong and negative impact on those of us who were already operating in a safe and peaceful manner, but will do little to prevent those with a disregard for the rules from continuing to violate them.
My purpose in writing this letter is to help convince you that the new regulations are unfair to the large majority of hobbyists who use their drones in a safe and responsible fashion, and that it would therefore be reasonable to modify the rules so as to make them less restrictive. I am writing to you in the belief that we share a common passion for flight and exploration. For me, drones are a natural outlet for this passion. Many young people like myself, who enjoy flying drones, hope to pursue a career in aerospace or other similar disciplines. When I am out flying, the overwhelming reaction that my drone receives from curious passersby is positive, often with them commenting on how useful and cool a drone can be, and on all the potential it has to offer. Unfortunately, some individuals will continue to find ways to misuse drones, but the same can be said for most other things, too. It is unfair to effectively punish responsible hobbyists with severe regulations because of the potential actions of a few reckless individuals (who are likely to flaunt the rules, anyway).
With regards to specific aspects of the new regulations, the two most concerning aspects are probably as follows: no closer than 75 m (~250 feet) from buildings, vehicles, vessels, animals, people/crowds, and no closer than 9 km from the centre of any aerodrome (any airport, heliport, seaplane base, or anywhere that aircraft takeoff and land).
The 75 m distance rule makes perfect sense in some situations (such as flying near crowds), but is excessively restrictive in many others. For example, the rule seems to apply to private property. If a friend asks for some pictures of his property from above, can I no longer do so? Am I even able to conduct a quick test flight in my own backyard, hovering the drone a few feet above ground in order to make sure everything is in working order after installing new firmware updates? Realistically, there are many public and scenic locations where it would be quite safe to fly closer than 75 meters without posing a tangible risk to anyone or anything. Surely, common sense should prevail in these situations. The way the rules are now written, we are left with very few interesting places to use a drone—there is not much to photograph in an empty clearing in the middle of nowhere, but for most practical purposes that now seems to be the only place left to fly!
While the 9 km zone is understandable for areas near large airports, it seems unreasonable that it should apply to anywhere an aircraft may takeoff or land. For example, there are heliports all over— including on the roofs of many buildings. If we consider a radius of 9 km around every one of them, there is likely to be almost nowhere practical left to fly. It doesn’t seem reasonable that a helicopter would require 255 square kilometres of restricted air space to operate safely (and many heliports are used just a few times per year, if at all). Again, it is important to allow common sense to reign in these situations.
The 90 m (~300 foot) altitude restriction is somewhat conservative, especially considering the 9 km no-fly zone surrounding all airports, helipads, etc. In the United States (and most other countries) the altitude limit is set at 400 feet. I wonder why the altitude limit has been lowered in Canada. I am also somewhat perplexed by the 500 m operating distance restriction. Many drones have operating ranges of several kilometres before signal strength becomes a concern. While it is common sense to keep a drone within visual line-of-sight (especially while flying in a built up area), it is entirely possible to keep it within sight at a distance greater than 500 m. In less developed areas especially (free of people or buildings and overhead air traffic), I do not understand the rationale for this restriction as it is often easier and just as safe to fly by looking at the live video feed from the drone. Why not just simplify the rule to flying within visual line-of-sight?
Nearly every modern drone has bright LED lights for navigational purposes (to aid in distinguishing the front of the drone from the back) or as status indicators (e.g., for battery levels). These lights serve the dual purpose of making the drone very visible at night (in fact, I would argue that it’s easier to spot a drone in the sky at night than it is during the day). Given that a lot of drones are used for aerial photography, it is very limiting to only be permitted to fly in daylight hours when some of the best photos are taken at night using a long exposure. While the nighttime-flying ban makes perfect sense for drones that do not have lights on them, drones that have sufficient lighting should be exempt.
A licensing program (similar to what is already in place for motorized watercraft) would be a good and fair way to regulate drones. In such a program, anyone who wishes to fly a drone would be required to demonstrate sufficient skill and knowledge before being allowed to fly. Such an approach could greatly increase awareness of how to fly responsibly and safely without the need for overly restrictive regulations.
Thank you for your time. I very much hope that you will reconsider certain aspects of the new regulations to arrive at a better balance, ensuring safe and responsible drone usage, while still allowing enthusiasts the freedom to fly.
Yours sincerely,
[My name]