Monday, October 13, 2025

What Commonplace 922 Means for Drone Producers Beneath Transport Canada’s New BVLOS and Medium Drone Guidelines – sUAS Information

One other well timed purpose for Transport Canada: The publication of the revised Commonplace 922. In fact, right now is April 1st, and a few might imagine this can be a joke. Nevertheless, it isn’t.

So, within the abstract under, we’ve offered the reader with an outline of the earlier Commonplace 922 self-declaration course of after which detailed the revised model.

VLOS Superior Operations – Self Declaration Abstract:

For drone producers seeking to promote underneath the Superior Class of drone operations in Canada, declaring your drone protected for managed airspace, close to individuals, and over individuals was easy. The method? Merely go to the declaration web page, fill out a number of strains, and you’re added to the record.

Nevertheless, as talked about within the earlier article, this course of has been problematic for finish customers and producers.

For finish customers, they assume that Transport Canada – Transports Canada has appeared on the paperwork upfront. In actuality, it’s a self-declaration course of whereby “you don’t want to submit the outcomes of the AC 922-001 Remotely Piloted Plane Methods Security Assurance verification assessments alongside along with your declaration of RPAS Security Assurance. Nevertheless, you could be requested to provide the outcomes of verification assessments at a later date. Failure to provide the outcomes of verification assessments when requested could affect the declaration standing of your RPAS.”

This has been problematic for finish customers as they’ve now skilled life when Transport Canada completes an audit and removes the costly drone you simply purchased from the record. For instance, in 2024, Transport Canada launched their oversight report outcomes.

Within the picture under, you possibly can see what number of drone declarations (110) and pilots (1905) had been affected by the defective paperwork. Think about waking up and discovering out you possibly can’t drive your truck to work? This, maybe, is a joke that needs to be addressed extra proactively.

Transport Canada’s Surveillance Exercise Outcomes

BVLOS Small & Medium Drones – Self Declaration Abstract:

This revised customary “describes the technical necessities that individuals making a declaration are required to fulfill in accordance with part 901.194 of the CARs.” (P.1)

To adjust to the brand new laws, drone producers should full declarations and “acceptance letter necessities have to be glad as listed in Desk 1 under.” (P.1):

So, what does this imply? Properly, for these producers wishing to promote small or medium drones for BVLOS missions, they need to begin the Pre-Validated Declaration (PVD) course of.

Extra in regards to the PVD course of might be discovered right here and right here.

To adjust to the PVD declaration course of, key factors to concentrate on are listed under for the three PVD issues.

901.87(b): Small – BVLOS – Uncontrolled Airspace and Over a Sparsely Populated Space, or 1km From Populated Areas

Sparsely Populated Space:

  • means an space with greater than 5 however no more than 25 individuals per sq. kilometre. (zone peu densément peuplée)

922.07 – Security and Reliability:

  • Should meet reliability targets within the desk under, (a) “based mostly on the utmost kinetic power that may be achieved by the RPA; (b) catastrophic failures situations are extraordinarily unbelievable and don’t consequence from a single failure; and, (c) The chance of a failure situation leading to a extreme damage to individuals not concerned within the operation is proven to be extraordinarily distant.” (P.6-7)
  • Constructions and elements shall be designed to permit for protected operations all through the operational envelope
  • Methods for monitoring and warnings used to inform the crew should reduce any hazard from unsafe situations and be designed to attenuate pilot error
  • “Non-safety essential methods, gear, and payload shall not adversely have an effect on any security essential system.” (P.7)
Likelihood of Failure and Kinetic Power

922.09 Command and Management Hyperlink Reliability and Misplaced Hyperlink Behaviour:

  • The drone have to be designed in order that (a) “chance of incidence of any mixture of failures which can end in a lack of management of the RPA at any level in flight is proven to be distant or much less” and the drone “behaves predictably and constantly if optimistic management is misplaced and in a fashion that assists pilots in minimizing the chance the RPA will create a hazard” (P.8)

922.10 Detect, Alert, and Keep away from Methods:

  • Annunciated lack of operate shall be proven to be distant.
  • Un-annunciated lack of operate or hazardously deceptive shall be extraordinarily distant.
  • “The means to detect conflicting occupied air site visitors and take motion to keep away from them have to be proven to fulfill the next system danger ratios” (P.9)
  • “*When an operation is carried out in atypical airspace as outlined in AC903-001, or if an operation is carried out in accordance with Commonplace 923 – Imaginative and prescient Based mostly DAA (as per CAR 901.97(2)), then a declaration in opposition to customary 922.10 shouldn’t be required.” (P.4)
Daa danger ratios

922.11 Management Station Design:

  • This part is concentrated on methods and gear for crew members.
  • This part intends to make sure protected operations by the crew members and has the 4 necessities that may be summarized by (1) Controls should permit for protected operations, (2) Controls have to be clear, accessible, and allow crew consciousness, (3) Gear operations have to be predictable and permit for pilot intervention, and (4) Crew should have the ability to handle cheap/sensible errors.

922.12 Demonstrated Environmental Envelope:

  • This part describes the environmental envelope wherein the drone might be safely flown. For Canadians, it’s nice to see that Transport Canada acknowledges that some drones could not minimize it in our sparsely populated environments in winter months.
  • This a part of the laws requires floor and flight testing.
  • Testing shall embody the next minimal necessities: “(a) account for all configurations and for all phases of flight of the RPAS, together with acceptable failures or degradation of elements and methods and any environmental components particular to the idea of operation(s, (b) embody the operationally protected vary for: (i) meteorological situations, (ii) some other exterior components particular to the idea of operations which will adversely have an effect on security of the operation, (iii) EMI and HIRF, and (iv) exterior components which will adversely have an effect on security akin to g-loading, plane attitudes, crosswind, evening, working latitude, city airflow, proximity to objects of inspection or to infrastructure, (c) account for inadvertent exceedance of the demonstrated environmental envelope earlier than detection might be realized and corrected and the place the limiting situation can’t be prevented, and (d) any security associated limitations for storage and transportation.” (P.11-12)

901.69(f): Medium – VLOS – Operation at a Distance of Lower than 500ft (152.4m) However Greater than 100ft (30m) From Any Particular person Not Concerned within the Operation.

922.07 – Security and Reliability:

  • Should meet reliability targets within the desk under, (a) “based mostly on the utmost kinetic power that may be achieved by the RPA; (b) catastrophic failures situations are extraordinarily unbelievable and don’t consequence from a single failure; and, (c) The chance of a failure situation leading to a extreme damage to individuals not concerned within the operation is proven to be extraordinarily distant.” (P.6-7)
  • Constructions and elements shall be designed to permit for protected operations all through the operational envelope
  • Methods for monitoring and warnings used to inform the crew should reduce any hazard from unsafe situations and be designed to attenuate pilot error
  • “Non-safety essential methods, gear, and payload shall not adversely have an effect on any security essential system.” (P.7)

901.69(g): Medium – VLOS – Operation at a Distance of Lower than 100ft (30m) From Any Particular person Not Concerned within the Operation.

922.07 – Security and Reliability:

  • Should meet reliability targets within the desk under, (a) “based mostly on the utmost kinetic power that may be achieved by the RPA; (b) catastrophic failures situations are extraordinarily unbelievable and don’t consequence from a single failure; and, (c) The chance of a failure situation leading to a extreme damage to individuals not concerned within the operation is proven to be extraordinarily distant.” (P.6-7)
  • Constructions and elements shall be designed to permit for protected operations all through the operational envelope
  • Methods for monitoring and warnings used to inform the crew should reduce any hazard from unsafe situations and be designed to attenuate pilot error
  • “Non-safety essential methods, gear, and payload shall not adversely have an effect on any security essential system.” (P.7)


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