Archive — May 2018
Inside Transport Canada’s CG1 Stakeholder Session
Our notes from the day Transport Canada sat down with 40 industry stakeholders to walk through the changes it was considering to the Canada Gazette 1 proposals — before any of it became regulation.
This is an archived post from May 2018. None of it describes current requirements. These were proposed changes to proposals, and much of the terminology below never survived into the final rules: the “limited” and “complex” classes became Basic and Advanced Operations, the “SAFE” framework became the Safety Assurance Declaration under CARs 901.194 and Standard 922, and the Information Management System launched as the Drone Management Portal. Part IX came into force on June 1, 2019 and was substantially amended again on November 4, 2025. For the rules in effect today, start with getting your Canada drone licence or our guide to BVLOS operations in Canada. We keep this post online as a record of how the framework developed.
On Wednesday, May 23, 2018, Transport Canada hosted approximately 40 unmanned aerial system stakeholders — spanning industry, training providers, non-profits, manufacturers, and operators — to discuss proposed changes to the regulations put forward in Canada Gazette 1. A summary document from TC was expected to follow shortly after the session.
A note on what follows. These are proposed changes to proposed regulations. Although each statement below does not repeat the caveat, none of it has been confirmed as regulation.
Introduction
After reviewing the 650-plus responses to CG1, Transport Canada agreed with the majority of respondents on amending the proposed regulations to streamline, simplify, and reduce overall complexity. With safety as the underlying intent, TC saw value in removing many of the prescriptive proposed requirements and creating “paths to compliance” instead. The approach is more common-sense and risk-based: what is essential for safety, without hindering innovation in the space. The goal of the proposed amendments is to allow the majority of common use cases and reduce non-compliance — both of which contribute to a safer and more productive industry.
General
Remotely Piloted Aircraft System (RPAS) has been proposed to replace Unmanned Aerial System (UAS) as the standard terminology. The rationale was partly inclusivity and gender neutrality, and partly that RPAS is a better representation of how the system actually operates.
TC has created an online Information Management System that will handle aircraft and pilot registration, exam delivery, and pilot permit applications. This drastically reduces the costs proposed in CG1 — aircraft registration was forecast at $110 under CG1, and through the IMS is forecast at $5 to $10.
Insurance and training will no longer be mandated through regulation.
Operations
As announced in CG1, TC is removing the recreational and commercial distinction for operators in favour of a risk-based approach keyed to weight and operational complexity. All aircraft above 250 g and below 25 kg will be classified as small RPAS, broken into two classes: limited and complex. The determinants of complex operations are proximity to people and airspace classification.
Two definitional changes are worth flagging. The terminology around “built up areas,” which caused considerable contention, has been removed. And “people” refers to free-standing individuals and crowds — not those inside vehicles or buildings. There is more flexibility in lateral distances from people depending on operator permits and the aircraft used.
Many parties were interested in changes to the proposed compliant aircraft requirements. TC has removed the grandfathering clause as it stood in CG1, and engineered a set of requirements under the very convenient acronym SAFE — Safety Assured Flight Envelope. Manufacturers can provide evidence that their aircraft meet different gradations of the SAFE framework, with more stringent envelopes enabling riskier operations.
Training
As noted above, training will not be mandatory for pilots. The knowledge requirement will be demonstrated by scoring 80% or better on the online TC exam. The exam is multiple choice, drawn from a test bank currently at 500 questions with a goal of reaching 2,000. It is open-book but timed, and covers the material in the newly updated TP 15263.
Though unconfirmed, the phrasing indicated there will be a limited category exam and a separate complex category exam. Those in the complex category will also need to complete an in-person flight review covering a site inspection and normal and emergency procedures. Flight reviewers will be qualified through TC and required to pass a separate reviewer-specific exam in addition to the complex category exam.
Conclusion
This summary touches on the main themes, though thoughtful questions from stakeholders drew more in-depth responses from the UAS Task Force. More detail is likely to come directly from TC, and although this level of engagement is not common at this stage of the gazette process, they seem open to stakeholder engagement and discussion.
Looking for the rules that are actually in force today?
Explore Coastal Drone courses for current Basic, Advanced, and Level 1 Complex Operations training.