MAAC Outdoor Site Survey options/options d’enquête sur les sites extérieurs
Hello Mr. Hepner,
As it was your zone director email address that appeared in the ‘reply to’ area of the eblast identified in the header above, this enquiry is going to you. That eblast was received on December 18th, 2023. Please feel free to pass this on to the apparent authors of the eblast (or at least the main part of its content) – Mark Winstanley and Dave Cummings – if you feel that they should respond to questions about this correspondence.
Firstly, I am puzzled by this eblast’s claim that a site survey may now be done only once per year – but it then says (quite rightly) that the RPAS survey must be checked every 56 days, in accordance with the schedule of updates to Transport Canada documentation. So the site survey is, in fact, subject to review 6 times a year. What has changed? What is the good news?
I am at a loss to understand the firm requirement in that notice, received on December 18th, 2023, that site surveys must ONLY be done using RPAS Wilco. Could someone please explain why this is an absolutely rigid, single-source, requirement? Drone pilots do not have any such restriction. RC model aircraft fliers, who are not members of MAAC, do not have any such restriction. Tens of thousands of RPAS operators outside MAAC conduct their activity satisfactorily, and within the law, without the use of RPAS Wilco, but MAAC members are restricted to only that option. It is not Transport Canada that has created that imposition on MAAC’s membership – it is MAAC’s leadership! Transport Canada’s Aviation Information Manual (AIM), which endeavours to explain the laws and regulations governing aircraft operations (including RPAS), not only does not describe any such restriction – it specifies other ‘apps’ that it recommends, and doesn’t even mention RPAS Wilco. The AIM lists two free ‘apps’ that it recommends be used to help with ensuring that an RPAS flier complies with the requirements of Part IX of CARs – the NAV Canada ‘app’ (NAVDrone) and the NRC ‘app’. MAAC ‘outlaws’ those two ‘apps’ for use by MAAC members. Please explain.
In a column in the MAC magazine for Sept/Oct 2023 it was stated by the chairman of the SAG that the NAVDrone ‘app” does not comply with all of the requirements of CARs part 901.27. To quote his words “NAVDRONE is an airspace permission tool that meets a few of the CARs 901.27 site survey requirements but not all. An RPAS Wilco site survey, when conducted in accordance with the MAAC SOC rules package, meets all the CARs requirements.” In fact, no ‘app’ can possibly comply with all of the requirements of Part 901.27. Here are the requirements of 901.27 in full:-
901.27 No pilot shall operate a remotely piloted aircraft system unless, before commencing operations, they determine that the site for take-off, launch, landing or recovery is suitable for the proposed operation by conducting a site survey that takes into account the following factors:
- (a) the boundaries of the area of operation;
- (b) the type of airspace and the applicable regulatory requirements;
- (c) the altitudes and routes to be used on the approach to and departure from the area of operation;
- (d) the proximity of manned aircraft operations;
- (e) the proximity of aerodromes, airports and heliports;
- (f) the location and height of obstacles, including wires, masts, buildings, cell phone towers and wind turbines;
- (g) the predominant weather and environmental conditions for the area of operation; and
- (h) the horizontal distances from persons not involved in the operation.
The eblast referred to (which can be seen below) acknowledges that items f) to h) of Part 901.27 must be determined by the RPAS pilot at the time of the operation (in opposition to what is said in the MAC article referred to above). Of the remaining items – a) to e) – only b) and e) can be determined by any of the ‘apps’ that are available, including RPAS Wilco, and those two requirements are satisfied by all of the ‘apps’, including the two free ones. The other items – a), c), and d), as well as f), g), and h) – must all be determined outside the ‘app’, even if some of the results can then be entered into the ‘app’.
Item a) must be determined by the flier at the time of operation – or predetermined by the club operating a communal site. Similarly, item c) can only be determined by the flier – or predetermined by the club if it is a club field. Item d) refers to actual manned aircraft operations – which can only be determined at the location of the operation at the time of the operation, not by any ‘app’. Manned aircraft operations can, and do, occur anywhere in controlled or uncontrolled airspace at any time. Items b) and e), therefore, are the only ones that an ‘app’ can actually help with.
Which of items b) and e) is satisfied by RPAS Wilco but is not satisfied by the other two Transport Canada-approved ‘apps’? In what way would “A NAVDrone site survey, when conducted in accordance with the MAAC SOC rules package, NOT meet all the CARs requirements”?
There is this statement, found on NAV Canada’s website:-
“Whether you’re planning a drone flight, looking for airspace information or simply want to gain a better understanding of where you can fly your drone in Canada, NAV Drone is the only app that lets you safely and legally request permission to fly a drone in airspace controlled by NAV CANADA. From the web or a mobile device, professional and recreational drone pilots and operators can easily see where they can and cannot fly with interactive maps and, when needed, submit requests to fly in controlled airspace.” {Note – my highlighting.}
Can you explain why, while NAV Canada takes the above position, and Transport Canada takes the same position, on the use of the free ‘apps’, MAAC prohibits the use of them? While it is true that “drones” are not the same as model aircraft, and “drones” are what is referenced in the passage from NAV Canada, it is quite clear that the recommendation would cover remotely piloted aircraft as well.
The fact of the matter is that no ‘app” at all is required in order to comply with all of Part IX of CARs. An ‘app” can certainly be helpful, but it is NOT a requirement. There is documentation available, as described in the AIM, which can be used to satisfactorily establish a site survey according to the requirements of CARs. That documentation is available as a download as well as hard copy. This might be more time-consuming and difficult (for some) than using an app, but it complies with the requirements of the laws of Canada. It is also less difficult than using an app, for some. Transport Canada, in a meeting held to discuss the subject, have agreed with that position. Transport Canada, to a very large extent, does its best to accommodate all levels of “tech-savviness” – MAAC should accommodate its less tech-based members with assistance in the techniques that suit them, not chase people away from the activity by insisting on their use of equipment they cannot understand. Offering training in high-tech devices simply doesn’t work for some people, they can only operate successfully with the lower-tech options. It is MAAC’s task to support those people, not to discard them.
Can you explain why MAAC feels that it must restrict the activities of its members well beyond the requirements of the laws of Canada, even to the extent of prescribing that they may not use government-recommended site survey software. The mandate and guiding principle of the governing body for any recreational activity should be to protect its members’ interests – to do everything in its power to expand the opportunities and the support that its members receive in the pursuit of their chosen activity. Restricting those activities is the business of the regulating bodies, such as Transport Canada, and they are fully equipped to perform that function. The Board of our organization should concern itself with minimizing those restrictions as far as that is possible – that is how it should serve its membership – not with demonstrating how far beyond the legislative requirements they can push matters. No gain can arise from trying to out-legislate the legislators – what they are looking for is an organization that will uphold their rules, nothing more.
MAAC should endeavour to support all of its members and clubs in the conduct of site surveys (where legally required) in any way that those members require – as long as it is in compliance with the law. For instance, it would be a very valuable service for MAAC to offer unbiassed advice as to the level of updating of documentation, etc., and help with the process, if a member, or a club, chooses to comply with the law through a legal, hard copy, route. That would be in keeping with the mandate for the Board of a recreational association. There must be MAAC members who have experience of that route and would be willing to help others through the process. Provision of assistance to use the free software that is recommended by Transport Canada and distributed by either NAVCanada or the NRC would also be a valuable service to those who request it. Again, if the SAG and TCAG lack that expertise, there must be members of MAAC (or even non-members of MAAC) who are familiar with those apps and willing to help.
Before another penny is spent by MAAC on the commercial site survey software (RPAS Wilco) the membership should be presented with a factual, documented, explanation of what, exactly, are the benefits of purchasing commercial software vs the free software. The full cost – past capital and annual costs, as well as anticipated future annual maintenance fees – should be openly revealed to the membership, open discussion on the matter should be encouraged, with all opinions considered, and the membership should vote on the direction that they wish to take for the future. I should note that the commercial software uses the same database as the free software – licensed from NAV Canada. This Board has led the association down a path where our fiscal situation has deteriorated to the point of being unsustainable, and membership has dropped dramatically, all in the past few years. Covid has not been the culprit here. Membership did not drop significantly through the years 2020 – 2021, it has dropped badly in the years since then. MAAC’s current practices of unjustifiable over-spending, coupled with a disdain for the Board’s proper role in encouraging and supporting its members – need to be reversed.
It is time to stop defending past bad decisions and face up to the real needs of MAAC’s members. It is time to put MAAC back on to a sound fiscal and functional basis – being a member-centric association in support of all facets of the great hobby/sport of model aircraft flying.
Roy E. Smith, #7759L CM
The text of the eblast that triggered this open letter can be found immediately below this point.
On 12/18/2023 12:53 PM, MAAC wrote:
Outdoor Daily site Survey Options – ANALYSE DE SITE quotidienne
*FRENCH BELOW
GREAT NEWS FROM MAAC TCAG and SAG,
(TCAG, Transport Canada Advisory Group – SAG, Safety Advisory Group)
Effective immediately, members may elect to conduct a single site survey once per year, for shared use by all members at any outdoor MAAC SOC site (clubs), with the following conditions:
- Site surveys must be done using RPAS Wilco
- Site survey to be available to pilots electronically or printed.
- new site survey to be checked at site level every 56 days per the schedule below.
- CONTROLLED AIR SPACE, pilot MUST have in hand the latest version at any given time while flying.
- NOTAM must be checked daily using RPASWilco or at NAV CANADA portal.
- Members operating RPAS remain individually responsible for daily visually confirmation of CAR 901.27 (f to h)
- Indoor sites do not require a site survey
Link to MAAC NOTAM 2023-04
*FRANÇAIS
BONNES NOUVELLES DE MAAC TCAG et SAG,
(TCAG, Groupe consultatif de Transports Canada – SAG, Groupe consultatif sur la sécurité)
À compter de maintenant, les membres peuvent choisir de faire une seule analyse de site une fois par an, pour une utilisation partagée par tous les membres sur n’importe quel site COS de MAAC (clubs), avec les conditions suivantes :
- Les analyses de site doivent être effectuées à l’aide de RPAS Wilco
- L’analyse du site doit être mise à la disposition des pilotes par voie électronique ou imprimée.
- Nouvelle analyse de site à vérifier tous les 56 jours selon l’horaire ci-dessous.
- ESPACE AÉRIEN CONTRÔLÉ, le pilote DOIT avoir en main la dernière version en tout temps lors des vols.
- Les NOTAM doivent être vérifiés quotidiennement à l’aide de RPAS Wilco ou sur le portail de NAV CANADA.
- Les membres qui exploitent un SATP demeurent individuellement responsables de la confirmation visuelle quotidienne selon l’article 901.27 du RAC (f – h)
- les sites intérieurs ne nécessitent pas d’étude de site
Lien vers le document MAAC NOTAM 2023-04
Mark Winstanley
Chef de groupe/Group Chair
MAAC TCAG
Dave Cummings
Chef de groupe/Group Chair