In Canada, the use of drones for pesticide application, otherwise known as Remote Piloted Aerial Application Systems (RPAAS), is regulated by two Federal Departments: Transport Canada establishes regulations for safe operation and Health Canada for the registration and conditions of use of pest control products.
Drones are already used in Canadian agriculture for crop surveillance and livestock management, and they’re being used to apply granular fertilizers, for pollination, and for frost protection. The use of drones for general spraying was cleared by Transport Canada in July 2017. In 2018, Health Canada stipulated that the use of RPAAS for pesticide application is not allowed under the Pest Control Products Act (PCPA) without sufficient data to characterize the hazards or risks associated with this use.
At this time this article was written, there were no liquid pest control products registered for application by RPAAS in Canada, although two restricted-use granular microbials intended for larval mosquito control were expanded to include RPAAS in the fall of 2022. RPAAS working groups, both industry-oriented and regulatory-oriented, are working collaboratively to assemble the information we need. Many research trials using RPAAS (approved by Health Canada) are planned or on-going as stakeholders determine the safest and most effective way for drones to fit into agricultural pest control.
Certification and Registration
Anticipating pesticide label expansions, perhaps you’re planning to buy and fly an RPAAS. Transport Canada requires all pilots with RPAAS over 250 g to obtain a Pilot Certificate, either for Basic Operations or for Advanced Operations. Pilots only need a Special Flight Operations Certificate (SFOC) when operating outside the rules for Basic or Advanced operations, such as beyond Visual Line-Of-Sight (VLOS).
Pilots must register their drone (online for a $5 fee) and display that number on the drone. For more information, the Canadian Aviations Regulations (CARs) covers drones here. It’s a massive document, so jump to the end to find the relevant information under Section IX.
Yes, drones do seem to require a lot of acronyms.
Basic Operations Pilot Certificate
The Basic Operations certificate allows pilots to operate any drone from 250 g up to and including 25 kg. This allows the pilot to fly:
- Outside controlled airspace
- Over 100 ft above people
- In VLOS (or in contact with someone in VLOS)
- Over 1.8 km from heliports
- Over 5.6 km from airports
If you’d like to explore the requirements, Transport Canada has an online document called TP15263 which describes required knowledge for Basic Operation pilots of small RPAAS. Personally, I took a $100 online course (from a Canada-based drone flight school) to help me prepare for my exam. A good course will supply you with what you need to know about the laws, the environment, the aircraft, and your responsibilities as a pilot.
The $5 exam has 35 multiple choice questions. You have 90 minutes to complete it and you need a 65% to pass. It was a surprisingly challenging exam, so don’t be discouraged if you don’t pass on your first try. You can take another swing at it after 24 hours, and you’ll encounter new questions randomly drawn from their database.
Advanced Operations Pilot Certificate
The Advanced Operations certificate allows pilots to operate any approved RPAAS over 25 kg in VLOS. This allows the pilot to fly:
- Inside controlled airspace
- Above 16.54 ft above people
- Under 16.4 ft horizontally from people
- In VLOS (or in contact with someone in VLOS)
- Within 1.8 km from heliports
- Within 5.6 km from airports
There are two parts to this certification. The $10 exam requires an 80% to pass, covers more topics than the Basic Operations exam, and has the same 24h wait to retry. You must also undergo a Flight Review with a certified trainer, who changes about $200 for the service. Once the exam and flight review are successfully completed, there’s a $25 issuing cost. Lots of nickel-and-diming, here.
Once you have your Certificate you must carry a copy with you while flying. Technically, it doesn’t expire, but you still have to maintain it. According to CARs 901.56, pilots cannot operate a drone unless they have successfully completed the following within 24 months preceding the flight:
- Testing / Issue of their pilot certificate (Basic or Advanced).
- A Flight Review
- Any of the recurrent training activities set out in section 921.04 of Standard 921. This is an online questionnaire that has the answers posted right after each question. Don’t ask… just comply. Be sure to print it out after you complete it because it doesn’t save the answers.
Just like the Certificate, the pilot must have Proof of Recency with them at all times. Unlike the Certificate, it’s free.
Every owner of a remotely piloted aircraft has to keep certain records. They need to be with you while flying for a certain period of time and all records must be transferred with the system if you sell or give it to a new owner.
- The name of the pilot(s) and crew involved with each flight, noting time and date (keep with you while flying for 12 months).
- Any maintenance, modification or repair of the RPAAS, including precisely who did what and when. This should detail the instructions used to complete the work (keep with you while flying for 24 months).
Get certified before you buy your RPAAS, and do your research before you commit to a system. Rotor-based RPAAS design is changing rapidly as manufacturers adapt to the demands of North American and European applicators. Be sure you understand what they can and what they cannot do. Only buy from a reputable dealer with practical spraying experience, and not someone with slick advertising that over-promises RPAAS work rate, swath width, reduced drift or improved coverage potential. Ask to see the data.
RPAAS is still finding its niche in Canadian agriculture, and while we’re unsure about their capabilities, we are sure they’re here to stay.