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Another timely goal for Transport Canada: The publication of the revised Standard 922. Of course, today is April 1st, and some may think this is a joke. However, it is not.
So, in the summary below, we’ve provided the reader with an overview of the previous Standard 922 self-declaration process and then detailed the revised version.
For drone manufacturers looking to sell under the Advanced Category of drone operations in Canada, declaring your drone safe for controlled airspace, near people, and over people was simple. The process? Simply go to the declaration page, fill out a few lines, and you are added to the list.
However, as mentioned in the previous article, this process has been problematic for end users and manufacturers.
For end users, they assume that Transport Canada – Transports Canada has looked at the paperwork in advance. In reality, it is a self-declaration process whereby “you do not need to submit the results of the AC 922-001 Remotely Piloted Aircraft Systems Safety Assurance verification tests along with your declaration of RPAS Safety Assurance. However, you may be asked to produce the results of verification tests at a later date. Failure to produce the results of verification tests when requested may impact the declaration status of your RPAS.”
This has been problematic for end users as they’ve now experienced life when Transport Canada completes an audit and removes the expensive drone you just bought from the list. For example, in 2024, Transport Canada released their oversight report results.
In the image below, you can see how many drone declarations (110) and pilots (1905) were affected by the faulty paperwork. Imagine waking up and finding out you can’t drive your truck to work? This, perhaps, is a joke that should be addressed more proactively.
This revised standard “describes the technical requirements that persons making a declaration are required to meet in accordance with section 901.194 of the CARs.” (P.1)
To comply with the new regulations, drone manufacturers must complete declarations and “acceptance letter requirements must be satisfied as listed in Table 1 below.” (P.1):
So, what does this mean? Well, for those manufacturers wishing to sell small or medium drones for BVLOS missions, they must start the Pre-Validated Declaration (PVD) process.
More about the PVD process can be found here and here.
To comply with the PVD declaration process, key points to be aware of are listed below for the three PVD considerations.
Sparsely Populated Area:
922.07 – Safety and Reliability:
922.09 Command and Control Link Reliability and Lost Link Behaviour:
922.10 Detect, Alert, and Avoid Systems:
922.11 Control Station Design:
922.12 Demonstrated Environmental Envelope:
922.07 – Safety and Reliability:
922.07 – Safety and Reliability:
“Non-safety critical systems, equipment, and payload shall not adversely affect any safety critical system.” (P.7)ore time to work on the critical urban core activities to improve regular Canadians’ daily lives.
Must meet reliability targets in the table below, (a) “based on the maximum kinetic energy that can be achieved by the RPA; (b) catastrophic failures conditions are extremely improbable and do not result from a single failure; and, (c) The probability of a failure condition resulting in a severe injury to persons not involved in the operation is shown to be extremely remote.” (P.6-7)
Structures and components shall be designed to allow for safe operations throughout the operational envelope
Systems for monitoring and warnings used to notify the crew must minimize any hazard from unsafe conditions and be designed to minimize pilot error
ABOUT AVSS:
Founded in 2017, AVSS – Aerial Vehicle Safety Solutions Inc. (AVSS) is a Canadian aerospace company commercializing drone technology for Urban Air Mobility. AVSS’s current products are ASTM F3322 drone parachute recovery systems for commercial drones, independent flight termination systems, and precision-guided delivery systems for last-mile delivery.
AVSS’s retrofit products (DJI M3D and M3TD for Dock 2, DJI M200, DJI MAVIC 3 ENTERPRISE, DJI M300 RTK, DJI M350 RTK) are distributed worldwide through their more than 50 authorized dealer network and sold directly to drone manufacturers across the world. AVSS also provides direct support to drone manufacturers and pilots who integrate the PRS product line for flight over people and BVLOS compliance.
Visit us at www.avss.co to learn about drone parachutes, regulatory compliance, custom integrations, and more.
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