Drone Registration & Pilot Certification under Don's Drone Rules (Module 1)

“Don’s Drone Rules” is my proposal for a comprehensive set of practical drone rules, globally applicable, and sensibly balanced. This is Module 1 of 4, focusing on Drone Registration, Electronic Conspicuity (EC), Pilot Certification, and Training. PLEASE watch my introductory video for Don’s Drone Rules (https://youtu.be/yFePgA9cI44) before watching this video!

Please note that these are PROPOSED drone rules; they are NOT REAL! Please follow the real regulations for drone operations in your country.

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Videos are available on my channel with demos and training for all capabilities in Drone Pilot Canada. Contact me at DonDronesOn@gmail.com with any questions or suggestions.

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  1. Jordan Enns on October 27, 2020 at 12:49 pm

    Firstly Don I apologize for my lengthy reply!

    I applaud your willingness to ‘put yourself out there’ and take the heat! LOL. And I very much agree with the your approach of needing RPAS regulations to be 1) Extremely simple and easy to understand 2) Easy to implement & realistic for all parties; government as well as individual RPAS operators.

    I hope you are, or get, in contact with BC ‘Board of COPA directors for BC/Yukon’ Kate Klassen as I could see your opinions being furthered as Kate is pro RPAS and company director of Coastal Drone Co. Another thing to note, and this is more for your watchers commenting below as I know you know this already, that we also have to respect the work of Transport Canada and those involved, whom have given us our regulations to date, that ARE good to have implemented or wouldn’t hurt to remain implemented. My initial thought would possibly be the ‘Approved list of RPA systems’ but only used for the more complex areas of airspace or RPAS flight type ie: over people, BVLOS, etc.
    Although the MF(mandatory frequency) area of any applicable aerodrome is generally 5 nautical miles, our currently accepted 3nm is already a great compromise. These are just my personal examples.

    And finally just before I provide my opinions below on your first module, my background is the following: RPAS company since 2017/RC hobbyist of all aircraft types since 1990. TC licenced AME and was learning to fly fixed wing back in 2010. So I personally feel I can adequately represent every area of concern regarding integrating RPAS into our airspace but at the same time will be the first to admit that "I was wrong" or "I didn’t think of that!"

    I would kindly like to share some opinion on your first module. Any points that you mention that I do not comment on, I’m in agreeance with:

    1) (Section 1.1) – I disagree with you on the ">50% of drone flights being used for commercial purposes" simply because having a user define recognition of how they are using their RPAS can be interpreted ambiguously. It should be simply put as either be ‘Comercial(profit bearing) or not’.
    2) (Section 1.1) – Your last point contradicts your first point and thus so is confusing. I do feel that any RPAS over 250g should continue to be registered for two reasons. There has to be accountability period. The 250g limit that has already been assessed here has been done so as to how it relates to a collision with manned aircraft. It is bound to happen, especially with low flying helicopters, that a collision between a RPAS and a manned aircraft can/will/already happen and to limit that damage is where this assessment comes from. RPAS owners need to feel the responsibility of owning these devices.
    3) (Section 1.2) – regarding "EC". All current RC aircraft have a Tx/Rx system of control. This system, which today generally is 2.4 and 5.8gHz, can already be monitored with wifi finding devices and in such the technology should already be there to provide the way for legal enforcement in finding nefarious operators. The people concerned, regulators etc, need to promote this type of technology development to be of better use for enforcement personnel. The telemetry aspect of RPAS operations; drone location, alt, vector, etc can all be taken from the RPAS transmitting frequency already.
    "Transmit alert signal if not under user control". I believe this to be an extremely difficult thing to implement and may need further explanation of what you are thinking here as the only ‘easy and realistic’ method to me of achieving this would be to transmit on the MF(mandatory frequency) of the area operation using a handheld VHF radio. This is currently the only way to effectively communicate with applicable manned aircraft that are in immediate danger (but TC and NavCan have already advised against transmitting on any air frequency during an RPAS emergency and I believe that this has to change. Regardless, if I were to have a ‘fly-away’ during one of my RPAS operations today, I absolutely WILL be transmitting on my VHF handheld and taking the rap later from TC/NavCan.)
    Your topic of "Pilot location" as you relate it to ‘control unit location’ does have to be located to find nefarious operators during their operation so that enforcement can find them. Although the pilot location of where they live ABSOLUTELY should NOT be made available, but only to enforcement personnel, and that can already be done through our current drone registration system and mandatory labeling of our drones with its registration number.
    3) (Section 1.4.1) -All in all, the ‘BASIC’ category of licensing needs to be exactly that; basic in understanding so that EVERYBODY understands it and defines easy to understand unambiguous set of rules . "Must not fly in Restricted areas or near manned aircraft operations" again ambiguous and to be honest, people just don’t know what ‘Restricted areas’ mean. In respect of already defined rules, I would add ‘no flights within 3nm of any airport and would elaborate on ‘Restricted’ as to the key points of already established restrictions in Canada with further elaboration to apply with the rest of the world (since you are trying to accommodate worldly regulations).
    4) (Section 1.4.2) – disagree strongly with ‘flying over bystanders’. For the safety of the public, restrictions and mitigations must be implemented here. There are already products approved for these kinds of operations (eg: parazero). And to be honest, there really isn’t any reason to have to fly low over people when alternatives like a cable cam can be set up.
    I did successful fly my P4P over people while tethered to a zipline between trees and because of this, TC didn’t regulate this use (their words, not mine).
    In addition, for the sake of peoples unknowing understanding, I do believe a regulation should remain in place to inform ‘Commercial Operators’ of insurance requirements. As obvious as this is to any commercial business owner, there are people getting into this type of operation not understanding this risk.
    5) (Section 1.4.3) – I would include BVLOS operations here and any ‘what if’s’

    I have to mention that I really like your Section 1.5 Training section as this HAS been greatly neglected by our governing body!

    Regarding Canada’s system, I do like that TC has implemented RPAS regulations into our already established CAR’s(Canadian Airspace Regulations) as part 9, but I may be partial to this system do to being an AME for 11years. Although I do of course still find it hard to navigate at times.

    Anyhow, once again thank you for stepping up and getting your voice heard. Looking at all the countries in general, there seems to be a common trend about government personnel, whom are responsible for making RPAS related regulations. One, they are not being responsible for hearing from the RPAS community (ground zero) in understanding the realistic implementation of some said aspect of regulation proposal.

    I also wish to mention for ANYONE unsure, that regular RC airplane/helicopter (that being of non-FPV and non-automated flight nature) hobby users should NOT be affected by any new RPAS regulation and should continue to abide by the already set standards of their hobby. These hobbyists have been operating for an eternity without risk to manned aviation. RPAS regulations should only apply to FPV and automated flight. Once again these are my opinions and should be taken as is.

  2. Maryana Mosiy on October 27, 2020 at 12:52 pm

    Imho too complecated: treat drone as car. simplyfy it. You don’t need car tracker to drive the car.

  3. Carlos Amat on October 27, 2020 at 12:53 pm

    you put a lot of work into this… thank you!
    common sense stuff with safety through out… unlike what we have now from transport canada

  4. Dan Ford on October 27, 2020 at 12:55 pm

    Why drones over 250g , What’s the difference between a drone under 250g and drone over 250g? For instance the Mavic Air @ 450g and Mavic Mini @ 250g, these two drones are pretty similar, except for the weight, and a few things they eliminated to make the mini lighter. Why not just have the rules printed out, you go in sign it, register your drone, you get a copy, they get a copy, then your out of there, done deal.

  5. bisarowood on October 27, 2020 at 12:58 pm

    I mostly agree with you , mostly about free training online, as it sits the basic exam is ridiculous and you actually don’t learn anything about safe flying … I think recreational should be under 450gr no registration .

  6. Lauren Donauer on October 27, 2020 at 1:00 pm

    Although I applaud you ideas, there are many issues with this first module that just don’t work in the real world. Eg. your three levels of licensing, for someone to become a “professional “ drone pilot would take 3 years. So until then we would have no one “qualified “ to operate a drone over 25kg. Second of many issues is the idea of a license deciding what you can do does not make sense. Eg. a Real Estate agent that specializes in rural properties would require a “Advanced “ license even though he/she would never be flying in or near controlled airspace.

    There are many more problems with what you propose but I will just point out these for now. I have been a drone pilot for 8 years and I actually applaud the near regs with the exception of the testing questions which should be better related to actual drone operations. I also endorse the comments made by Jordan Enns.

  7. Dave Stredulinsky on October 27, 2020 at 1:05 pm

    A very sensible approach Don. I hope all your efforts in some way result in improving the current rules here in Canada and elsewhere. Thank you for sharing.

  8. Bob Witmer on October 27, 2020 at 1:12 pm

    All we have to do now is get you elected so you can take over from Marc Garneau!!! The only change I’d suggest is an alternative path to the Professional license that doesn’t take 2 years. If you took an intensive training course and demonstrate competence you should be able to get it sooner. I wouldn’t object if law enforcement were able to obtain the location of the pilot but it should be encrypted and not publicly available. I appreciate all you do Don and highly recommend the ‘Drone Pilot Canada’ app!

  9. Mike Taschereau on October 27, 2020 at 1:13 pm

    I like really your approach, but there are a couple of details you might want to reconsider. In 1.3 Registration Process, you suggest the use of passports as identification for foreign owners. At the current time, however, there are many locations where one can travel to another country without a passport. For example, there is no requirement for Americans visiting Canada to hold a passport and vice versa, as there are several other accepted documents. Perhaps a tweak of the wording to "approved travel document" or similar. In 1.4.2 and 1.4.3 Advanced/Professional Pilot Certification, I agree totally with the concept of acquiring flying experience before being eligible for higher levels of certification, but I’d prefer to see the rules specify the number of hours required. If 100 hours are sufficient (or 200 or 300) and someone can gain that experience over a few months, does it make sense to hold the person back for the remainder of the year?

  10. Carey Robson on October 27, 2020 at 1:28 pm

    Your series on preparing to be a registered pilot of an rpas in Canada is unequaled.
    This latest venture is at odds with all countries’ move towards preventing injury and loss being caused by rpas operators. You remember your lauding the MAAC exemption. Well they were at the table and they looked out for themselves. I am sure you are aware of the exuberation of the "personal freedom" crowd over the Mavic Mini – and the explosion in fly-aways being reported. How about getting back to what you were doing really well?

  11. Serge Belair on October 27, 2020 at 1:33 pm

    Salut Don

    Ok je suis prêt à ce que tu prennes la place des gens au gouvernement ! Déjà dans ton premier module il y a plus de logique que ce que le ministère des transports demande.


  12. MURRAY BROWN on October 27, 2020 at 1:35 pm

    Spot on!!!!!!

  13. Pinetree Line Productions on October 27, 2020 at 1:36 pm

    This makes far too much sense to be adopted by our government 😂 🇨🇦

  14. garry olsen on October 27, 2020 at 1:38 pm

    This sounds great but in reality the governments are going to do whatever they want Money talks.🇨🇦

  15. Brant Aerials on October 27, 2020 at 1:38 pm

    It all seems to make sense to me. Money talks and the drone delivery people would not be happy sharing the airspace, I suspect.

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