Uber is a self-serving company which cares only about it’s own profits to the point of classifying vast numbers of obvious employees as “contractors” to avoid taxes and, like in the movie “Nightcrawlers”, arguing that the freedom to work whenever you want is a substitute for at least some regulation on minimum and fair wages. But banning them in favor of an archaic government-enforced taxi cartel is not a solution. Apparently not having learned its lesson after banning Uber in most cities, having a non-voluntary maple syrup
producers union cartel and holding back the legalization of marijuana which keeps padding the profits of “licensed” producers and shuts out competition for production of what is literally a weed that grows almost anywhere, Canada (the government part) is at it again. This time, the target is drones.
Although not one incident involving a drone has caused a loss of life to date (contrast that with 2014’s 1834 road fatalities and 9647 “serious injuries”, which we accept as a reality of life without much concern), Transport Canada (who regulates road vehicle safety, marine safety and drone safety) has kept a tight control on anyone who may wish to use drones. Rules include excessive 9 km radius restrictions near airstrips and airports, no flying near or within built up areas (“anything bigger than a farmstead”) and no flying at night.
The drone rules aren’t built upon proven evidence of harm (unlike flying human-carrying aircraft at low altitude). There isn’t a scientific basis for them. It’s Transport Canada’s love for rules, licenses and permits and an “ordered” industry, just like with many other government departments. If it were about enhancing public safety, Transport Canada would allow most small UAVs to be used much more widely than they are today, with fewer permit and application requirements and more focus on enforcing a small number of important national or provincial laws, not unlike the way motor vehicles are regulated. This way people on search and rescue teams, police officers, conservation officers, firefighters, security personnel etc. could use small UAVs to visually survey up ahead and keep themselves out of unnecessary danger, while avoiding excessive helicopter and airplane use, without having to submit themselves to endless bureaucratic purgatory and fines for trying to help.
The current status quo one hears from many of these first responders in both Canada and the USA is “it’s too difficult to start up a program right now, we may look at it down the road”. This isn’t due to the need for trained pilots, as most modern drones fly themselves using way-points you draw on a touch screen tablet. And many modern drones are also very affordable, certainly orders of magnitude more affordable than helicopters (and much more environmentally friendly) (and far safer than low flying human-carrying aircraft, a point worth rehashing). It’s the permits, regulation and the similarly conservative insurance companies holding them back plus a sprinkling of conservatism within their own departments (since they are government too). There are some well founded concerns about integrating drones into existing first responder procedures, but ironically, most of this concern again ties back into the regulations surrounding drone use and fear-mongering in the media and by TC officials that has spread to first responders, causing them to ground eight firefighting helicopters and five planes for more than three hours at the first sight of a single drone nearby. (Russian pilots are laughing at us right now. Dump some water on the offending drone and be done with it.) Separating authorized first responder UAVs from first responder helicopters is relatively easy with some basic altitude/lateral separation planning and good communication systems and procedures. I’ve given presentations to SAR teams on how this can be done. Methods such as radio jamming of specific non-first-responder drone frequencies (900MHz, 2.4GHz and 5.8 GHz) and even trained eagles can be used to counter unauthorized drones during operations without affecting authorized systems.
And why should it be so difficult to start a drone program that can fly where most people are and where drones are most often needed? It involves 39-page permit applications (to fly closer to airports or near or in towns and cities or at night) that are really just a “pre-application”, because you still need to get specific approval from Nav Canada, the airspace operator, before each flight that involves controlled airspace (typically a large radius around mid and large sized airports extending to the ground even between buildings). Why do we need to apply for approval twice? The first application (the application to allow you to apply to enter the airspace) is largely a list of check boxes that are utterly pointless:
“By checking YES, the Certificate Applicant confirms that the UAV will not be operated in Class D airspace without prior coordination in accordance with the direction given in Appendix A of this document through the appropriate Nav Canada Flight Information Region (FIR) as follows”
Why do we need to check this box saying that I will follow the law (and there is a law in the Canadian Aviation Regulations saying you can’t enter Class D without approval), send the document to them with the box checked and my signature, then wait 1 month for them to get back to me? Do we have to fill out a form before we go to the supermarket saying “I will not steal these items” and then submit it to a police officer for a month-long review before we are even allowed to set foot in the store? We are not children. We can be expected to know and follow the laws on our own and a “pre-application” is an unnecessary waste of time. It is a mechanism not unlike several other TC rules that has no scientific basis but wastes peoples time and causes them to give up, not unlike nefarious “proxy laws” that do not forbid a specific thing but make it nearly impossible to accomplish. North Americans love to blame ourselves – “if they really wanted it they could complete the required application” – while not questioning why they exist in the first place. Instead of the pre-application, why not just publish this tidbit on Transport Canada’s website, so that everyone will know exactly who to call for the “real” permission? Or better yet, de-classify the Class C, D etc. airspace where no reasonable human-carrying plane would be allowed to fly anyway, like less than 200ft AGL (above ground level) over urban and suburban areas. The helicopters should need permission to enter that airspace outside of approved helipads, not the drones, because small drones are much safer to both their pilots and passengers and to the people on the ground.
Getting approval to fly near cities or airports or at night is not just as easy as filling out check-boxes, however. The application includes exhaustive detail on the drone you are flying (fair enough in a world where drone manufacturers aren’t regulated like motor vehicle makers are; perhaps we should be), all your emergency procedures and explanations of every item and piece of equipment that you carry into the field. This is despite nobody ever having to follow a law stating they carry emergency equipment in their car (although it is very wise to do so), since we expect emergency responders to put out fires for us. People regularly died on highways due to lack of prompt available treatment before the advent in the 70’s of organized highway emergency response teams (Outdoor Emergency Care (5th Edition) (EMR) by National Ski Patrol, Edward C. McNamara, David H. Johe and Deborah A. Endly (Pearson, 1272pgs) released 2011-05-16).
The SFOC (special flight operations certificate) application also requires you to explain how you are going to carry dangerous goods (i.e. lithium batteries) to and from the operation site. There are already existing laws which cover all dangerous goods including lithium batteries. Transport Canada writes those laws too! And they don’t mention anything illegal about transporting Lithium batteries by private vehicle, only by freight or shipment. But they would prefer you write them an application, while they remain at-times snarky about how busy they are processing all these applications and offer terrible 1-month service standards, stating that you will follow the law, and then possibly deny your application on grounds of inadequate safety even if you will follow the applicable dangerous goods law that has been around for a long time. This is closed-doors government, where there is very little public control or even knowledge of these “add-on” laws which are mostly up to the discretion of the TC employee reviewing the permit. Most of these application requirements were never voted on by anybody, they are administrative regulations issued by the regional Transport Canada office.
Consider that when people drive heavy steel vehicles that can and do kill each other (with astonishing regularity) all we have to do is take a one-hour test and write a multiple choice exam and pretty soon you are in command of a rumbling metal behemoth inside major metropolitan areas where pedestrians are in the same two-dimensional plane as you. A 2000 kg car traveling at a modest 60 km/h has 278 KJ of impact energy which is aligned along a plane where it can easily cause multiple casualties. A 25 KG drone dead-dropping from 200ft in the sky has 2.6 KJ of impact energy at the ground and is not directed in a manner to easily cause multiple casualties. Most drones you will ever see in your lifetime outside of military bases and airports are between 1 and 2 KG (0.1 to 0.2 KJ from the same height). If you’re a real sicko, try performing a mass-murder truck attack with an under 25 KG drone. Trucks are allowed in almost all cities and towns with just one nationwide license.
And it’s not America, but getting a gun is relatively easy here too, it’s a one-day 8 hour safety course and a background check and you could easily commit suicide or murder (or a murder-suicide). But a drone? That’s a new technology, and in Canada we don’t like those. It COULD take down a human-carrying aircraft, we are told constantly, but it never has despite countless people flouting even the most important regulations by flying near airports and over forest fires and one actual impact with an airliner. This is in contrast, again, with the astonishing and unquestioning acceptance we have of auto and sometimes of gun deaths.
Fines for flying drones contrary to the regulations are up to $5000 for individuals and $25000 for corporations, while a speeding ticket in a school zone is about $120.
I’m going to go in a bit more detail on the particular current UAV laws that are most unreasonable and unscientific.
1. Watch Out for those Tree Limbs in the Dark! (Night flying)
From the Prairie and Northern Region office of Transport Canada regarding applications for Night flying (note: this is not a general permission to do this but a guideline for how to make an SFOC application):
4.17 The UAV may be operated at night, and only for the purposes authorized to a maximum altitude of 300 feet AGL. The area must have adequate supplemental illumination to operate safely and avoid hazards. The integrated UAV aircraft lighting is not approved and not to be used for sole source reference.
Night flying is the most egregious example of bad rule-making. None of the current exemptions (meaning you don’t have to apply for an SFOC permit and wait a month to hear back) cover night flying at all. You need an SFOC to be allowed to fly at night. Logic and prudence would dictate that it should be similar to traditional aviation or to cars – i.e. have see-and-be-seen lights on your UAV and have an emergency backup ground-based light in case those lights fail, or alternately have manufacturer safety standards like for cars that ensure the lights have an acceptably low probability of failure.
However, the permit approval guideline (see above) demands the use of ground based floodlights, jack-lights etc. to completely illuminate an area and doesn’t allow for on board lighting to provide this. Again, this is not an actual law voted on by anybody, it’s an administrative guideline written by a specific regional Transport Canada office that can be used to deny an application for flight in the Prairies and any of the Northern Territories. It makes sense in a city to require active lighting (but from the drone) so you don’t take out the electrical grid by downing a power line, or hit a person when flying in a park. But then, in a city, most streets and parks are lit anyway. So the primary place this applies is… the wilderness, or some dimly lit warehouse on the outskirts of town. This is completely contrary to the lack of lighting rules we place on ATVs, Snowmobiles, etc. when operated away from public roads and urban areas. Yet there is no exception made in the administrative regulation for operation well away from towns. The no night flying without a permit rule applies everywhere, even in the middle of the Yukon wilderness, even with integrated on board lighting. And most inexplicably, you must give the “purposes” of the night flight to Transport Canada for approval and cannot fly at night for any other purpose. This means you may be able to fly for night search and rescue but not night photography, or night time inspection of buildings, or night time pursuit of somebody suspected of a crime. (Broken record: You do not have to follow separate laws to drive your car at night if you are going to work versus going to the gym.)
The saddest thing is that this is one of the best uses for drones that I’ve covered extensively before – continuing the aerial search at night. A pilot and passengers of a human-carrying aircraft may have real reason to fear flying at night near terrain, and they typically don’t fly search missions at night for this exact reason. Drones can help by searching overnight, when victims are often at their most vulnerable to hypothermia, because who really cares if a several thousand dollar drone crashes in to an unseen tree in the wilderness while searching for a critically injured or dying person, and the likelihood of the drone impacting an actual living animal or person is extremely remote. Thermal imaging cameras can replace the need for active lighting to actually find the person using the drone.
Restricting night flying to a few extremely prepared and licensed applicants is one of the least safe acts made by Transport Canada because it almost certainly guarantees that when there is an emergency at night, and a drone and a pilot are needed, they will not be able to fly. The one licensed, approved “night VFR” pilot in that entire province or territory who has all the necessary ground-based lighting equipment and has waded the complicated permit process to fly at night is on another call, at a wedding after having a few beers and unfit to fly, or somewhere else in the world. Or, perhaps their night permit authorized “search and rescue operations” but not “tracking dangerous wildlife in urban areas” when the conservation officers need them. We are creating a situation, just like with the taxi industry, where we are forcibly eliminating supply in response to a false or imagined (or conjured) threat to our safety, and the consumer of the service suffers.
Some SAR teams in B.C. and elsewhere have already moved on from thinking drones will be a solution in the near future, and not because of technical in-feasibility. They are also moving away from the idea of owning drones themselves and looking at service providers to handle the complex regulations etc. who may not be experienced in first responder operations, but will have the necessary permits. In my opinion this is not conducive to improved chances of successful search when compared with a tightly integrated UAV method. (Critic: “Of course you say that, you sell a personal-sized first responder drone“. Me: “Yes, and I wouldn’t have designed it in the first place if I didn’t think it was the better strategy. Having a drone that anyone on the team can fly improves the chance that it can actually be used in an emergency, like any other piece of SAR equipment.”)
2. Your UAV has a Restraining Order Against It (Proximity rules near people and inanimate objects)
Here is part of the requirements for the Prairie and Northern Region Transport Canada SFOC application when operating near built up areas (again, defined as “anything bigger than a farmstead”):
1.1 General Built-up areas procedures
By checking YES, the Certificate Applicant confirms that the UAV will not be flown within any built-up or populated areas unless all of the following conditions are met:
The UAV shall not be operated within any built-up or populated area unless written permission from the local governing authorities has been given.
The UAV shall not be operated within 100 feet horizontally of any person, structure or vehicle not directly associated with the operation of the UAV unless written permission has been obtained;
The UAV shall not be operated within 100 feet horizontally of any public roadway, right of way, or public access route unless a security plan is in place that is capable of precluding public access or incursion within 100 feet horizontally of the UAV;
The UAV shall not be operated within 500 feet horizontally of any public owned areas including parks, playgrounds or other public spaces without a security plan in place that is capable of precluding public access or incursion within 500 feet horizontally of the UAV;
These rules basically stipulate a minimum distance from other people, buildings (including unoccupied or fully enclosed buildings) and vehicles (including parked vehicles). Depending on the weight of the UAV under or above 1 KG, this is between 100ft and 500ft laterally (respectively) from that vehicle, building or person. “Laterally” means that the excluding volume is a cylinder stretching into space from that person or object, not a sphere.
While a “person, animal and moving vehicle” rule may appear reasonable, the application of all these rules is somewhat like a restraining order, where even if that person moves towards you it’s still your job to stay away, unless you can very quickly get out a pen and paper and have them sign the required “written permission” to operate near them (again, an unreasonable ask that appears like a proxy law to simply suppress drones). The rules also effectively forbid all flying within 500ft of a park or public space, and within 100ft of a roadway whether or not that roadway is currently being traveled upon by anyone, by making the “security plan” requirements nearly impossible to apply in practice (discussed several paragraphs further on). And you need written permission from the City municipality to fly there, which is funny, since you don’t need permission to drive on municipal roads even though the City builds and maintains the roads and not the air and has no legal right to police the airspace (but may be able to legislate against taking off or landing on City property). Again, it is an unreasonable ask, and again, these are not laws made by elected officials but administrative regulations made by this one regional office who has the power to deny applicants the right to fly based on guidelines like these.
Together these lateral proximity rules make it very hard to do much in or around a city or a highway. It hampers applications like: urban search and rescue, urban firefighting, and police pursuit, among the more mundane filming and photography applications. It would be far more appropriate to simply leave the already-in-place “no overflying mass gatherings” rule as is, install the following limits in urban or suburban areas: limit the weight of the UAV to 25kg, install a lower maximum altitude of 150-200ft and a 50kmh speed limit. Then make all other operations the sole responsibility of the pilot. That’s why we have insurance, after all, so we can settle disputes if people are harmed by our actions. And yes, drone insurance of minimum $100,000 coverage (but insurers typically do not offer less than $500,000) is mandatory in addition to all these administrative regulations. We don’t have proximity rules for pedestrians when we are driving our much more dangerous cars, we just are expected to not hit them and if we do we will be punished by the law and have our premiums raised. There is no need for an overzealous government body to police the use of small personal drones to the extent that every walking person carries a towering 100ft or 500ft radius cylinder around them which can automatically render your flight operation illegal should they walk in to your area – and in many cases simply the threat that somebody could walk in at some point renders your operation illegal and fine-able.
Where is the driver’s security team “enforcing” the 100ft exclusion radius? Where is the external lighting equipment? It’s getting dark and the integrated car headlamps are “not approved for sole source reference”. That’s a $5000 fine (or $25000 if that’s a corporate-owned car). Also that building looks to be less than 100ft away, so double the fine. He also probably didn’t get written approval from the City, so the Federal Government can fine him for that as well (presumably in addition to a fine from the City itself).
Of course all of these proximity rules are impossible to police without either a) temporary fencing that you bring to the site and move with you as your drone moves, which is obviously not going to work in emergency response applications or b) the use of a security team as specified in the administrative regulation. Transport Canada demands one of these two to ensure you maintain the minimum lateral distance requirements. For example one of my applications at a local North Vancouver park which was frequented daily by hobby fliers was disallowed (because I’m doing it for work or research as opposed to for fun) until I could show that I had people stationed at every possible entry point OR a fencing system and then kept my drone at least 100ft from the inside of the fence. The drone in question was the Sentry, which then weighed about 1.2 KG.
The security team requirement (and the lack of practicable alternatives) hurts UAV operators, especially small businesses, especially in areas with low populations like the North. It means you are forced to hire and pay a 2nd and possibly 3rd and 4th person (and if you are working an emergency style shift 24 hours a day you will need to pay them all standby pay as well) simply to keep unauthorized people out. Despite the goonish implications of this, no person actually has legal authority to restrain or prevent someone from entering an area. Even a police officer can’t, unless the UAV operation was part of a public safety emergency or the person was reasonably suspected of a crime. So your security officer is really just kindly asking them to stay away and/or informing you of their presence, which you could (and should be) doing yourself as part of a normal scanning routine. Moreover it is that person’s responsibility not to interfere with your safe operation, not yours to prevent them from interfering in it. If a person jumped in through your car window and assaulted you or took over the steering wheel you would not be fined for not having your windows closed.
This does support the theory that Transport Canada, like many other regulators, is simply suppressing upstarts and small businesses in the industry by instituting unnecessary fixed costs of entry (in terms of time taken for applications) that don’t scale with the size of the company. This favors the larger, established, lobbying UAV service provider organizations and is a form of regulatory capture using “proxy laws” rather than outright bans on new entrants (unlike the taxi industry regulations which make no attempt to hide their anti-competitive nature). At least we don’t currently have to pay for the SFOC permits or certificate of operation, like they do in Australia, and it’s a flat $4000 rather than a scaled amount based on company size or revenues. They will call you “mate” as they do this, falsely suggesting that some sort of equality is present.
Instead of making these unrealistic demands of drone operators it seems a bit more reasonable to ask people to look up from their phones once in a while and realize there is a drone flying around and be aware of it. Kind of like crossing the street, except the street is the sky. Drivers accept no responsibility for pedestrians that jump out at them and our court system backs them up. It seems obvious that these proximity rules should be abolished and the pilot should be held responsible for conducting a safe operation and having liability insurance which covers them in case of an accident, like with cars. If that means you choose to hire people to keep a 360 degree eye out around you while you fly the drone, more to protect yourself and the drone than anyone else on the ground, that’s your prerogative and you can foot the bill for the security team.
Victim blaming 101: Pedestrians, it’s your problem to get out of the way of cars. Drone pilots, firstly get out of the airspace anywhere near where both pedestrians and cars may, at some future point, travel, and secondly if you don’t hire security and you are assaulted or interfered with we’ll fine you.
I’m trying to point out something I think is a uniquely Canadian attachment to unhealthy regulation, and to the establishment of “legal cartels”. (Not that many other countries don’t have it worse, but it’s a different flavor and the corruption is more in-your-face.) We see it everywhere, from the taxi industry to medical marijuana to drones, that our government would rather craft arbitrary laws that spawn forth a small number of license holders who have an oligopoly on the industry than allow sensibly regulated freedom which may actually improve safety due to more widespread use and thus development of improved technologies.
In any case the bases for these current laws and administrative regulations are not scientific. We are often told unreasonable and false representations of the dangers of changing any part of the regulations (e.g. “Kids will get access to marijuana if we legalize it”, “Unlicensed drone pilots are a grave risk to us all”) that aim to force us into accepting the status quo that does nothing to actually improve safety and may potentially harm it. What is actually safer, my brain working overtime to work out whether I am over or under 100 feet from that person I’m flying near because I might get hit with a $25,000 fine? Or just relaxed thinking “make sure you don’t hit that guy, or he’ll probably sue you” and focus on the mission itself and the important rules, like not flying too high, too close to airports? Studies have shown that when national-level regulators stop prescribing an excessive minutiae of rules and focus on high level laws and broadly written oversight guidelines, safety and performance of industry improves and consumers are happier (2017 EMR Training Course, Dr. Paul Allen, Yukon Emergency Medical Services). Regulation is good, but regulation made by people who apparently care more about their own departmental egos and importance than actual public safety is bad.
What’s the answer?
It isn’t hard to imagine a world where anyone is allowed to fly drones after getting a UAV license that’s about as hard as a driver’s license. They can fly them at night near cities towns and roadways if they have the proper lighting on board (like a car), they can fly them anywhere they like under 300ft AGL and “away from” airports, helipads and waterdromes, or in any area not likely to have aircraft present (such as between buildings or off the approach and departure paths on the sides of runways). Policing of this is then up to the local airspace operator (i.e. the tower) who better understands which areas are safe to fly in than a Ottawa based bureaucrat. The Class C, D, and E control zones around airports should not go to the ground (other than within the airport’s security fence and immediate approach and departure lanes) but to somewhere between 100 to 200ft AGL, as no large aircraft or one that carries humans should fly that low especially over built up areas. Entering controlled airspace without local tower approval (NOT Transport Canada approval) is prohibited. At uncontrolled airstrips the UAV pilot must simply follow normal pilot rules and give right of way to larger aircraft, like with shipping. They can fly wherever they want, near buildings or people, as long as they don’t hit into anyone or anything (if so the insurance and/or courts will handle it). And there should be a 50km/h upper speed limit, a reduced altitude limit, and a 25kg maximum UAV weight over urban and suburban areas. Provinces and cities can then make their own laws about privacy, operation near city parks and so on.
As manufacturers we can help by installing GPS and altimeter-based safety systems that prevent drones from accidentally entering controlled airspace. DJI already does this. This can be updated efficiently via the sharing of KML files from the regulators which we install into our drones. This function should be able to be deactivated by the pilot after bypassing one or more warnings, however, as there may be instances where a drone is required to fly into a controlled airspace in an emergency and the person on the ground is the best one to make that decision (and be responsible for the consequences). We should not be slaves to rigid, unthinking computers any more than slaves to rigid, unthinking bureaucratic government. It is less safe, and less enjoyable, than the alternative.
Then, we can actually utilize drones for a bunch of everyday jobs that simply don’t get done because of the need to contract a licensed pilot who will often charge $500/hr partly due to all the permits they’ve had to get, which are free but take a lot of time, and then when you get on site they will tell you they can’t fly there, they can’t do that, that will require an additional permit, blah blah blah and by that point you’ve blamed the drone technology itself as being a “fad”, “gimmick”, “useless” rather than placing the blame where it belongs, with our elected officials and with Transport Canada. It is tempting to make conservative decisions but we have a responsibility to make the right decision, since drones are useful for helping find people, fighting fires, stopping destruction of our natural resources and providing transport of emergency medical supplies like AEDs, epinephrine injectors and the like. Conservative safety laws also affect people’s behavior, a phenomenon known as risk compensation. There is proof that drivers give cyclists less room when passing if the cyclist is wearing a helmet. When I came back to Canada from China, I was shocked by the number of people who drive extremely fast in one lane with limited attention paid to the road, thinking the lane belongs to them instead of being aware a bicycle, car or pedestrian may enter it at any time, as is normal in most non-Western countries.
There is a widespread view that Transport Canada and other government departments thankfully make the rules that most Canadians want, as opposed to what the drone industry (including myself) wants. Many people are indeed afraid of drones and have a negative view of them, mostly because it’s a new and poorly understood technology to them. But this argument, just like with so many similar arguments about government, relies on a false assumption that all of our country’s people have full and complete unbiased knowledge of the safety of drones. We don’t because we all have specialized jobs just like TC officials do. We look to our supposedly unbiased experts in the relevant government department to tell us how much we should really be afraid of a particular thing. In this way the attitude of the government (and even more so that of the media) drives the attitude of the people and not the other way around. Go to Transport Canada’s website, or read popular news articles on drones with quotes from TC or FAA officials. It is not hard to see why people have a negative opinion. There is a lot of information on what not to do and less on what to do. There is plenty debate over what could go wrong, very little evidence or data on what has gone wrong beyond a few close calls (which we accept every day when walking, cycling or driving to work and is never discussed on the evening news while the drone-flying-near-airport makes headlines), and scant discussion from these officials on how drones can benefit safety overall in a number of ways if people are willing to adopt them and the regulations were sensibly relaxed.
It also shouldn’t be hard for anyone to point out that just because someone went through a grueling accreditation process doesn’t mean they will act safely once they have the license, permit, uniform etc. and for this reason licensing should focus on honest and unbiased education, not on prescribing rules. Some nurses with proper qualifications abuse people. Some cops abuse their privileges. Decisions need to be made in the moment and it’s wrong for someone in Winnipeg or Ottawa to make anything other than very high-level rules about what we are allowed to do in any other city, province or territory with drones. When you speed in downtown Vancouver the VPD gives you the ticket, not Transport Canada. Safety comes down to responsibly made laws that are in the public interest and enforced at the local level with discretion by people who understand the local environment because they live there, they drive there, their children go to school there, etc. On the drone operator side, safety comes down to whether the person on the scene at the time is experienced, capable, responsible and communicates well in a crisis, and is educated honestly and fairly on drone safety like how our driver licensing, hunter education or firearms courses are conducted. This has nothing to do with how well they can write a persuasive and meaningless Word document.