RPA collision hazards & give-way duties

RPA (drones) are an in-flight collision hazard, worst at low altitude (TC AIM AIR 2.4).

Why RPA are hard to avoid (AIR 2.4.2):

• Small, low contrast against background: hard to see in time to avoid.
• Collisions happened despite RPA give-way rule: manned aircraft typically much faster, little margin.

RPA at low level (AIR 2.4.2):

• Face the same hazards as manned aircraft, more so with beyond-visual-line-of-sight (BVLOS) operations.
• Extra hazard: buildings and similar objects can cause loss of visual contact or disrupt the radio link.

ATC (RPA 3.2.34):

• Small RPA usually not transponder-equipped.
• ATC cannot give separation or conflict-resolution service given to VFR/IFR traffic.
• No traffic warning expected.

RPA give-way and clearance duties (CARs 901.17; AIR 4.16):

• RPA gives way to manned aircraft at all times.
• Manned aircraft: power-driven heavier-than-air aircraft, airships, gliders, balloons.
• Gives way regardless of side, altitude, direction.
• RPA pilots must stay clear of areas where traditional aircraft operate.

Pilot action (AIR 4.16): RPA mostly fly at or below 400 ft AGL.

• Exercise caution below 400 ft AGL in uncontrolled airspace.
• Fly standard circuits at uncertified aerodromes, where other users expect aircraft.

Trap: RPA give-way rule does not prevent collision. RPA small, hard to see: see-and-avoid still applies. CAR 602.19 right-of-way covers manned aircraft only; RPA always gives way.

Practice