What constitutes a reason for the weight classification? and Why should we regulate? This needs to be resolved before we blanket new drone technology and capabilities with the existing control and safety regs of the past 50 years.

I have read though all of the notes and recommendations I can find on how Canadian Air Regs will be modified to accommodate drones . . .sorry "RPAS"  . . RPAS is the new acronym now generally agree on internationally . . so we are going to have to get used to that one now over UAVs or RPVs or UAS or drones. For now I'll just drone for convenience until the dust settles.

From all my reading  of the proposals and recommendations it comes down to CLASSIFICATION. If there is no new lower classification lower than 25kg then we are regulating on fear not physics and a whole set of over regulated unnecessary and ineffective control will result. The new rules Canada is proposing make perfect sense . . to a point . . . public safety, pilot knowledge, certification, vehicle maintenance and reliability  as well as ATC "rules of the air" all benefit from drones being required to meet certain standards. But . .  at some point you have to be practical as we have done with other vehicles. . . like bicycles, skateboards and scooters etc that share the road. Airspace is just a 3 dimensional road and the threat to life and property is no less real than unregulated drones.

However, given the ability to define rules of the air that automated systems can be programmed to avoid, there is no reason to further control 1kg machines than exploding cellphones or hoverboards.

So the first order of business, before setting the new regulations in "political concrete" is to recognize a weight or size class boundary that makes rational sense according to physics and analysis of the threat that goes beyond "antiquated" aviation flight experience.  . . I say antiquated because we have only just now realized the capability and performance of a 1kg flying camera. There are very capable systems now that general aviation has little or no first hand experience operating.

Beyond Visual Line Of Sight (BVLOS) when flying drones is currently a BIG no no . .  and almost every jurisdiction is  making rules about how it can be done commercially with restrictions, limitations, regulations, certifications, and qualifications. All this seems necessary, since irresponsible flyers can endanger hundreds of human lives with a single mid-air collision with an airliner that brings it down. Yes that's a horrific and sobering vision . .  like that time you saw an airliner flown into a building intentionally! . . .even so the reaction is very visceral as you step aboard your next flight to Miami, (sorry it's Canadian Snowbird season. Everyone seems to be headed south this time of year) it is important to put that risk into perspective, based on a full and rational analysis of all likely or unlikely threat and safety factors.

Here are some issues to consider.

They are working on practices and guidelines for established Small drone operators who wish to extend their operations from VLOS to BVLOS.  From this I assume there must also be a new set of Best Practices for Very Small operators. Does this mean that very small "Compliant Operators" will be able to fly "non-compliant" aircraft for commercial work or can Compliance be modified to allow lower priced but fully capable systems to qualify for some reasonable BVLOS activities . . when they are in the hands of a competent pilot. Maybe the proof of capability should rest with the Operator themselves and Transport Canada could qualify operators to allow them to judge the safety of their very small machines. At some point, the buck stops with the pilot anyway, doesn't it? Very Small RPAS is not a full fledged aircraft like a Cessna or even an Ultralight requiring strict standards so they don;t threaten human life. I think you can best regulate this end of the industry by regulating the pilots/operators to a reasonable standard. . . and it does not have to onerous . . . mostly common sense rules that can be assessed on a written test like a drivers license but with demonstrated knowledge of airspace and ATC rules.

What is the difference with BVLOS anyway for VERY SMALL machines? BVLOS applied to VERY SMALL RPAS should be defined as "BVLOS of potential hazards" not BVLOS of the MICRO RPAS itself. They are just too small.  You can see other aircraft or particularly large buildings of natural features. If you can see them but still know where your machine is, then you should be considered VLOS since the criteria of VLOS/BVLOS primarily exists to define risk of collision, damage or loss of life and a VERY SMALL RPAS is no more lethal than a baseball . . . so the PIC of a MICRO RPAS is able to see and avoid any other potential aircraft or hazards in his line of sight.

Instrument flight rules are designed to maintain aircraft separation while flying in cloud. This is different than IFR weather conditions. Simply speaking, VFR (Visual Flight Rules ) means you can fly if there is more cloud than sky with the lowest cloud being 1000ft and you can see 3 miles horizontally.  Any weather less than that is considered IFR. .  well except for SPECIAL VFR which is a special case. So in order to allow aircraft to fly IFR ie less than "1000 and 3" any aircraft must have certain equipment that are regulated to assure the aircraft can be flown safely in those conditions.. This is different than the rules for actually flying in IFR conditions which involve flight procedures and clearances and altitude restrictions. However, when you're flying a drone you can barely see  800ft away requiring 15,840ft visibility (3 miles) makes no sense. If you can see a  conflicting airliner 1 mile away then there is not going to be a conflict if you have the drone under positive control. Besides the airliner or any civilian aircraft should not be flying at 500ft anywhere except near an airport, so there is practically zero chance of a collision or even a near miss anyway.

So, IFR for VERY SMALL drones should mean you can fly if the weather is not below 1/4 mile visibility and 500ft lowest clouds (ceiling). Remember, 300ft AGL is a reasonable  maximum altitude for civil aviation separation in rural areas that are supposed to stay above 500ft. Both Canada and US FAA require planes to stay "1000ft above any obstacle within 2000ft of the aircraft", over built up areas so realistically, 500ft AGL maximum over built up areas should be perfectly safe for Very Small RPAS. I also think, reasonably, you should not be flying if there are icing conditions either during or forecast for your area within 1 hr of your planned mission but that's a different area for discussion.

Current CARs says your knowledge should include altimeter, airspeed indicators and the like. That's for Airplanes. VERY SMALL RPAS knowledge demonstration should not be about aircraft systems but be around the RPAS display instrumentation, map displays, navigation and flight modes interface and methods of using and switching flight modes . . . and WEATHER.

Recommendations currently call for only 6 hrs of flight time over 2 years (in the past 24 months) to remain qualified as a drone instructor. My experience with operational instructional flying in RCAF tells me that's pretty limited to be teaching others. 2 hrs or Dual instruction. 2 hrs of Dual acting as an instructor and 3hrs of solo and your an instructor? Maybe I'm reading that wrong but that's a bit light for Small Class drones. . . but realistically, for VERY SMALL drones it may be enough for qualification to fly but it's not enough to teach or qualify others at any size.

There is a range of required equipment recommended for BVLOS flight. Most of it is valid like ability to display magnetic direction, position or speed.  . . but a lot of seems to be a hangover from manned systems.  . .  Like "Means of making a standard rate 1 turn". That's called a "turn and slip indicator and a stop watch". . . . and mostly for fixed wing aircraft that can't hover in place. I can think of no circumstance flying a drone when a standard Rate 1 turn would achieve any useful purpose for the Pilot or an air traffic controller.

Requirement for "an adequate set of fuses" " accessible to the PIC ( Pilot In Command) for all on-board equipment is also a carry over from flying piloted aircraft. First there are virtually no accessible electronics in either the controller or the drone and replacing one during a flight is equally impossible so I would strike that requirement entirely for VERY SMALL class systems.

Then there is the recommendation it should carry ADS-B.  . . an aircraft based GPS reporting radio signal that reports your aircraft position to ATC and provides flight path de-confliction data for other aircraft in the area. As far as I can see there is no value to ATC for MICRO RPAS to possess ADS-B Out navigation or course correction for RPAS flying below 300ft AGL. Or a typical aviation Transponder. (see comments on real-time position reporting - Alternate World). Doing so would also clog the system unnecessarily.

In general, the drone world ( especially very small ones should not need to have anything to do with civil aviation. Their primary goal should be not to interfere and not present a threat to normal aircraft operations. For small and larger classes of drones, that's a different issue. They will need to interface regularly and there fore accommodate more restrictive access. I want to deal with just the Alternate World of VERY SMALL drones the same way the airlines would consider airport parking congestion as a threat to aviation. thousands of very heavy and powerful machines are allowed to manoeuver through airports and around aircraft with people in them but present virtually no threat to people or property unless its in the hands of a suicide bomber. There are fences and access roads, barriers and signs to direct traffic safely and efficiently. . . it's an Alternate Universe, and I believe the same can be done for personal and commercial drones. . .  especially the VERY SMALL ones.

A system of reporting position is currently feasible and could be implemented with existing RPAS simply by requiring an Internet link with the controller that reports position direction and ground speed like ADS-B. Typical Micro RPAS already store this flight information and a lot more locally in real-time. The ability to report updates to an existing website already is in use and Transport Canada or the FAA could make use of this data by allowing or requiring such reporting to an ATC accessible secure web address. How hard would that be, given anyone can see real-time video from personal drones in Facebook. Personally, I think it's overkill to require small business to report activities this way but if ATC Transport Canada or the FAA determined that VERY SMALL drones pose a serious threat because no one is tracking there locations with respect to civil aviation there IS a way to do it without a burdensome cost or operational impact to the small business operator.