Recreational drone pilots
In Canada, the quick answer is none. When Transport Canada released Interim Order No. 8 Respecting the Use of Model Aircraft in 2017, there was no requirement for the operator to have any level of minimum knowledge of the model/UAV being operated. The operating interfaces of modern recreational UAVs are becoming so intuitive that any operator with a good working knowledge of smart phones, can easily start flying in a matter of minutes from bringing home a new acquisition from the local electronics store.
Should someone start flying a drone without reading the manual? No. A substantial investment has been made in a new drone, and reading the manual that came from the manufacturer is similar to investing in an insurance policy; the operator will have a better understanding of what to do when something goes wrong, thus possibly preventing a small mishap from becoming an small catastrophe.
In addition to the manuals from the manufacturer, there will also most likely be local, municipal, and/or federal regulations governing the use of drones/UAV. When Transport Canada finishes revising the Canada Aviation Regulations (CARs) to better include drones/UAVs, even recreational UAV pilots will most likely need to demonstrate base knowledge of the aviation system in Canada.
Commercial drone pilots/operations
The requirements are more thorough at this level. Transport Canada Staff Instructions (SI) 623-01 (this is a document Transport Canada Inspectors use as a basis for granting SFOCs) states that a commercial drone/UAV pilot will have a working knowledge of type-specific UAV systems, limitations, normal procedures and emergency procedures.
Where can a pilot acquire this knowledge?
In the commercial aviation world, airline pilots are required to demonstrate a working knowledge of a mountain of manuals. Pilots Operating Handbook (POH), Quick Reference Handbook/Checklist (QRH/QRC), Aircraft Flight Manual (AFM), Flight Crew Operating Manual (FCOM), Minimum Equipment Lists (MEL), Company Operations Manual (COM), navigational maps and charts, and the list goes on. Before the advent of using iPads in the cockpit as an Electronic Flight Bag (EFB), the library of manuals could potentially weigh in excess of 100 lbs, distributed between the cockpit library and a pilot’s flight case. If you have ever noticed a pilot walking through an airport terminal, you have probably noticed 2 bags being carried; a suitcase, and a large square flight case full of books. Much to the dismay of chiropractors, the flight case pilots are required to carry are becoming smaller and lighter as more and more airlines move to approved EFB programs.
In the commercial UAV world, the list of manuals has yet to be standardized, but UAV operators are encouraged to parallel traditional commercial aviation library structures. In fact, Canadian operators seeking Compliant Operator Certificates are required to submit an operations manual, SOPs, a training manual, a UAV system manual, a UAV maintenance manual, and Declaration of Compliance, and a Statement of Conformity. The reason for this is simple; in nearly every country, the traditional manned aviation administrations (i.e. Transport Canada or the FAA) have been been tasked with also regulating unmanned aviation. Those administrations already know how to speak the language of aviation. When an operator is being evaluated for commercial operations, by having a familiar library structure can certainly facilitate the approval process.
Where do the manuals come from?
The operator. In traditional manned aviation, the library is built by the company. This library becomes customized to that operator, and gives all employees the framework needed to operate in an any unique environment, or to offer custom services. These documents become a living library; 50 year old commercial aircraft are still getting amendments to flight manuals for a variety of reasons. In the early stages of Canfly Drones, is was not worth the expense to laminate checklists for longevity, as checklist revisions were often made on an individual flight basis as we gained experience and and discovered gaps in our procedures.
A UAV operator could find a manual template online, cut and paste their company name into the the document and call it a day. An operator may even hire a consulting company to build a series of documents customized to their unique needs. While those may be quick and easy solutions (and using consulting services is certainly common practice with startup airlines), a single-drone operation that intends to operate within Visual Line of Sight (VLOS) would gain more from undertaking that task themselves. The reason for this is simple; writing a manual that covers how your operation will comply with the regulations demonstrates an above average knowledge of the regulations that you intend to comply with.
How should an operational library be structured?
While there is still no requirement to build an operational library, having one in place will also help an operator future-proof the company. By having an infrastructure in place for simple operations, the operator has launch pad for moving into more complex operations, such as advancing from operations in uncontrolled airspace to controlled airspace. The new manuals will be a good point of reference in the new application process for new operating conditions, and is a requirement as more and more operators are seeking Compliant Operator status, or approval for Beyond Visual Line of Sight (BVLOS) operations.
Canfly Drones recommends the following manuals as a starting point;
Company Operations Manual (COM)
You can think of the COM as a general manual, bringing together pertinent regulations, and spelling out to a pilot how to comply to those regulations. It becomes a source for a UAV crew during the planning stages of a mission. Normally one COM will be published per company, regardless of how many types of drones are being operated.
A structure for a COM can look like this;
- Copies of insurance and SFOC(s) or Compliant Operator Certificate.
- Company structure, key personnel, area and type of operations.
- Emergency procedures. In effect, an emergency response plan; what will happen AFTER there has been an incident or accident with a drone. Even though every operation may require unique response plans, there will still be an underlying framework. Calling 911 may be part of the response plan, but this is an area to identify WHO will be calling 911. If an operator is building a manual to operate in one specific site, very detailed explanations can occur about local emergency services, site access and security, and roles of individuals. Should an area of operations be very large, then this would be an appropriate location to outline a format for developing a response plan as part of a site survey.
- Security procedures. This may include an explanation of how the operator will physically prevent the drones from being tampered with while not in use, to an explanation of how the clients data will be kept secure (should that be an issue). It’s already been proven that someone can take over control of a drone from the authorized pilot, so operators may eventually need to demonstrate how they will maintain the integrity of their command and control link.
- Explanation of operational control, site survey and complete description of a flight release. Terminology may be different, but at the very least, an explanation of how the operator will ensure every flight will comply to pertinent regulations. As part of a flight release system, a description of all points to identify during a site survey. Should a site survey be done by someone other than the planned pilot of the mission, this may include an explanation of how the identified hazards will be communicated to the mission pilot. This process is very important to the planning stage, and the relationship to the mission to be flown is similar to the process of a dispatcher preparing a flight plan for an airline pilot. Once documented, as a drone company adds more pilots and drone types, by following this system, it will be much easier to maintain operational control.
- Operating Procedures. Here will be explanation of types of operations carried out by the company, for example Visual Line of Sight (VLOS) vs Beyond Visual Line of Sight (BVLOS). Different procedures for different areas may be included, for example, the extra steps needed to operate in controlled airspace, or special needs for operating over built up areas. Format of briefings to internal personnel can be included, along with briefing points to include when communicating with external personnel. This will be an area a pilot can find operating instructions that are not drone specific.
- Documentation procedures. This section can include what information needs to be recorded and documented, in terms of flights/missions flown. It may also include how in depth the documenting should, and how long the records are to be kept. The aviation industry relies heavily on documentation, and we should expect that more complex drones will require the equivalents of journey logs and maintenance logs.
- Dangerous Goods(DG). Currently no Dangerous Goods are being carried by drones in Canada, but as drone delivery becomes common place, operators will need to develop policies of DG handling.
Standard Operating Procedures (SOP)
You can think of this manual as the ‘how-to’ manual, and it will be type-specific by drone. Even though an operation may only employ one pilot, the SOP manual should be able to show a new hire (or potential third party auditor) how a particular drone will be operated. In the commercial airline world, an airline will borrow heavily on the manufacturers Flight Crew Operations Manual (FCOM) and Quick Reference Handbook (QRH) to develop SOPs, and will outline how the aircraft is to operated in order to comply with civil aviation regulations (CARS) and manufacturer instructions.
A basic outline for an SOP manual may look like this;
- General Description: You may think of this section as the introduction, with a brief description of the complete Remotely Piloted Aviation System (RPAS).
- Limitations: All aircraft will end up with design limitations, and because it appears so early in the manual, it’s importance can be inferred. At the airline level, a pilot will have a good amount of this section committed to memory, and the section usually consists of information such as maximum and minimum speeds and altitudes the aircraft may be operated at, engine parameters that must be adhered to, maximum and minimum fluid and pressure level, and electrical loads. This section may also consist of operating environment limitations, such as limitations regarding operations in icing conditions or at night. This is where an operator may choose to limit the UAV from operations the manufacturer has built into the system. For example, a manufacturer may design a UAV to operate at a distance up to 50 km from the operator, but local aviation regulations may require the UAV to be operated within Visual Line of Sight (VLOS) at all times.
- System Description: In addition to a thorough curriculum in the simulator, an airline pilot learning a new aircraft type will also go through a complete ground school on only the aircraft systems. This will be the section a pilot can refer to, and learn all about the new aircraft. At the commercial airline level, this section is normally an entire manual to itself, but as most UAVs are very simple quad-copters, the system sections may be simple enough to fit into a chapter of the SOP manual. More complex (and expensive) UAV systems may require more elaborate system descriptions, and the manufacturer may have already published a good system description manual.
- Normal Procedures: This section will be similar to a recipe, or script, of how a mission will be flown, and will be the most repeated actions of a crew. Starting from arriving at the operating site, detailed explanations of how the system will be setup, how checklists (if any) will be used, how Ground Control Software (GCS) will be programmed and verified, how launch and mission profile will be flown and monitored, and how recovery or landing will occur. Pilots are creatures of habit, and airline crews follow the same script day after day. By doing so, the crew may prevent a departure to a hazardous state, such as inadvertent take-off with insufficient fuel/battery voltage.
- Emergency Procedure: Another section high on the list of importance, these will be the procedures a pilot refers to (often times by memory) when something goes wrong. Lost command and control link, fly-away events, low battery voltage are good starting points to include in this section.
- Supplements: Lots of aircraft are modified from the day they have been delivered from the manufacturer. Alternate payloads, custom firmware, custom Ground Control Stations are examples of information to include for the pilot, and how the modification may affect the airworthiness of the system.
There is currently no standard for UAV maintenance. In Canada, a UAV system needs to be airworthy, but Transport Canada leaves the decision of airworthiness to the UAV operator. For a simple and small drone there will not be much direction from the manufacturer about maintenance, therefore the introduction of a simple maintenance program will go a long way. At this small drone level, the program may be as simple as replacing the UAV systems after a fixed number of hours have been flown, or after any incident, due to the low cost of purchasing and continual advancement of technology.
At the complex, Compliant Operator level, a more thorough maintenance program is encouraged. Unlike manned aviation, there is currently no design standard for unmanned aviation. It is currently the responsibility of the operator to continually prove the airworthiness of UAV systems, and Transport Canada provides some a guidance in the Staff Instructions (SI) 623-002 Review and Processing of an Application for a Special Flight Operations Certificate for the Operation of an Unmanned Air Vehicle (UAV) System. Large complex (and expensive) UAV systems are including documentation and programs that parallel manned aviation, so it is logical for UAV operators to parallel their programs.
At the small UAV level, this maintenance program may be simple enough to include as a chapter in the SOP manual for a given type.
Where to get started?
Appendix D to the Staff Instructions (SI) No. 623-001 provides a laundry list of the requirements of an Compliant Operators documentation, for those operators seeking to undertake authoring themselves. There are service providers that will build manuals and offer document publishing services offering turn around times of days, but those services are most likely using a template, and cutting and pasting the operators names and phone numbers into the document. That may work at the most simple level, but every operation is unique. An operator has the opportunity to learn far more by developing procedures from the ground up. Pilots are creatures of habit, and when there are safe and efficient habits to follow, the resulting flights are equally safe.
Having a good operational control system is excellent insurance against future changes to aviation regulations. If you are still feeling overwhelmed, Canfly Drones is able to provide guidance in the development of good operating procedures.