Response to MAAC letter re new Transport Canada Regs

[saboo]

Good Day All.

I used the contact information at the end of the MAAC special letter to reply to Mr Williams. Mr Williams is the MAAC contact for dealings with Transport Canada. Below is the contents of my email to him.

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Good Day Mr. Williams.

Thank you for your efforts with Transport Canada. I am not a big fan of their methods, procedures, and biases.

What I would like for MAAC and yourself to consider is pushing for some amendments that cover full size aviation.

Some I would like to see, in no particular order, are

1) A minimum Height Above Average Terrain across ALL classes of airspace. 300 or 500 metres. So a full size aviation operation would have to stay 500 metres above any terrain or obstruction within a 2 km radius of the flight operation. A 100 metre communication tower or 40 storey building, would determine the minimum operating altitude. Right now there are no minimums in large stretches of the country. The interim regulations had required rural model aviation to have a lower maximum altitude. This rule was a joke. If a full size aviator wished to fly at 100' they could. They would be just as dead as the one who flew at 250 feet and hit a model aircraft. So if the risk was there, the rule should have banned all model aviation in those areas. In reality the risk is so small as to be very difficult to enumerate.

2) Remove the exemption for helicopters flying below this height. A helicopter regularly flies over my model flying field at 150 feet above ground. He only climbs as he approaches the higher ground behind my place. I am allowed to fly to 300 feet above ground. He could be 150 feet below me. This is a large gap in Transport Canada Regulations. It makes Transport Canada liable for failing to regulate these low altitude flights by full size aviation.

3) No flying below the above minimum altitudes unless landing or taking off.

4) The above minimum begins to apply at 5000 metres from the control tower of a controlled airport, or the end of the runway. Even the most anemic or under powered light aircraft can achieve these minimums after takeoff. There is no reason for them to be flying in the weeds.

5) SFOC be required for all operations by full sized aviation below the above stated minimums. What is fair to model aviation is fair to full size aviation. We are a larger constituency than full size aviation.

6) The above minimum altitude to apply beginning at 500 metres from a heliport or helipad. That means no long low slow approaches to the many unmarked helipads.

7) Private, non public airports are not to be covered by the minimum operating distance requirements for model aviation. In other words, a private, non-public airport should not be recognized due to the randomness or non existent flight operations.

7a) No airfield which averages under a to-be-determined average number of flight operations per day, is to be considered an active airport. In other words if the airfield averages 200 operations or less a year, then its' status as an airfield is invalid.

8) Military aircraft to abide by the above minimum altitudes unless involved in SAR or hostilities. To apply to foreign and domestic militarys. This comes about from observations of US military Predators and / or Global Hawk operations at less than 300 metres over parts of Nova Scotia.

9) If a runway is marked as not in use or marked with large X as an abandoned airfield, the minimum distance to model aviation operations, should not apply. An example is the closure of Shearwater runways in Dartmouth, NS. They are marked with large X at the end of each runway. Only military helicopter operations take place and not from the runways. Model flying takes place on the runways. Yet some regard it as an active airport and assume the 5 km minimum distance applies. It should not.

These are all intended to protect full size aviation from their own follies. Model aviators will seldom ever be physically injured in an interaction between model size and full size aircraft.

Regards

Jim Haliburton

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The above has 2 typos corrected from the original sent to Mr. Williams