Thank you very much.
My name is Captain Dan Adamus. I'm the president of the Air Line Pilots Association International's Canada board. I am an airline pilot, and I have been for 34 years.
The Air Line Pilots Association International represents just over 54,000 pilots who fly for 31 Canadian and U.S. airlines. We are also the largest non-governmental safety and security agency in the world.
We appreciate the opportunity to provide our perspective on the critical importance of safely integrating unmanned air vehicles, UAVs—or, as I will refer to them today, unmanned aircraft systems, UAS—into the Canadian national airspace system, the NAS.
I think you see a bit of a theme here. There are lots of acronyms in aviation, and I'll refer to some of these acronyms in my notes today.
The airspace in North America is the most dynamic and diverse such system in the world. ALPA fully supports the safe integration of UAS operations into the NAS. This is not a new issue, and our support for the future of UAS in the NAS as well as our perspective on the issues associated with safe integration are reflected in this statement.
The safety of the NAS must be maintained to deliver the safest and most efficient air transportation services in the world. Although the focus today is the Canadian NAS, we must point out that the safety issues highlighted are independent of any national airspace boundary and are faced by ALPA's pilots as we operate around the globe.
In August 2015, the FAA published a list of pilot reports of UAS encounters. ALPA reviewed the 764 events, which cover only the period from November 2014 through August 2015. Canada has also seen a rapid rise in reported occurrences of UAS, with a tenfold increase in drone encounters year over year. Both the volume of events and many of the event descriptions are sobering reminders to the industry that the risk of a collision between a UAS and an aircraft has increased significantly. ALPA believes that a significant step toward the eventual solution to safely integrating UAS into the NAS includes four fundamental elements.
The first is education. Anyone who plans to fly UAS must understand the aircraft, the airspace, and the other aircraft that could be encountered while flying. In the case of UAS that might be commercially flown for compensation or hire, the pilot must hold a commercial pilot certificate to ensure that he or she possesses the appropriate skill and experience to meet safety standards designed to protect the flying public. Those flying UAS for recreational purposes must adhere to the guidelines, keeping the UAS within line of sight, at heights under 90 metres, and at least nine kilometres from airports. ALPA urges Parliament to provide definitive authority and remove any ambiguity about the extent to which Transport Canada has the authority to regulate UAS operated for recreation, modelling, and hobby purposes.
Based on what Transport Canada has documented to date, the ongoing educational efforts under way by Transport Canada and the recreational UAS segment of the industry are still inadequate.
With the holiday season on the horizon, UAS operations will likely increase. ALPA recommends that Transport Canada expand their outreach initiative, encouraging manufacturers, businesses, and volunteer organizations with a vested interest in safe UAS operations to aggressively promote safe UAS operations, which include avoiding encounters with airline aircraft.
The second element is registration. ALPA endorsed the FAA's rapid implementation of a UAS registration requirement for all but the smallest aircraft. Gathering basic information about the identity of the individual purchasing the UAS not only allows law enforcement authorities to identify the owner if the UAS were to encounter a problem, but it helps make clear the serious nature of operating a UAS in the NAS and the responsibility to safeguard public safety. ALPA encourages Transport Canada to implement a registration system as soon as possible. Additionally, ALPA recommends that Transport Canada implement registration of UAS at the point of sale. This method will ensure the greatest possible compliance with the registration requirements.
The third element is technology. If UAS are operated either intentionally or unintentionally in airspace that aircraft use, pilots need to be able to see them on the cockpit displays, controllers need the ability to see them on their radar scopes, and the UAS must be equipped with active technologies that ensure that the UAS is capable of avoiding collision with manned aircraft.
In these types of operations, technology must enable the pilots to control and interact with them in the same manner as if the pilots were on board. If a UAS is restricted by regulations from operating in a particular geographic area and/or altitude, it must have technology that cannot be overridden that limits the geographic areas and altitude in which it can operate. This may include permanent locations, such as Parliament and all public airports, as well as temporary restrictions, such as for wildfires or natural disaster areas.
Transport Canada should expand its ongoing evaluation of technologies that are capable of identifying UAS and operator locations. Transport Canada should ensure that resources are available for the development of UAS-centric collision avoidance technologies, with standards in place for their adoption as soon as possible.
Number four is penalties and enforcement. UAS pilots must be properly trained and must understand the consequences of possible malfunctions. Anyone flying a UAS that is a hazard to other aircraft in the airspace, especially anyone who chooses to do so recklessly near airports, must be identified and appropriately prosecuted. We support the criminalization of intentionally unsafe operation of UAS and penalties for unintentional unsafe UAS operations.
If Transport Canada intends to rely on first responders to ensure UAS regulatory compliance, it should better inform local, regional, state, and national law enforcement officials. Providing law enforcement officials with information that defines unlawful operations, provides peer-to-peer contact information, and clarifies the regulatory authority, as well as other pertinent information, is critical for an effective use of first responders to ensure UAS regulatory compliance.
In closing, ALPA supports the ongoing efforts to safely integrate UAS into the North American airspace system. We realize that UAS create many opportunities to benefit society. However, the integration needs to be done in a way that ensures that aviation safety is not compromised and that the target level of safety for commercial air travel in the NAS is proactively, not reactively, protected.
We are fully aware that there is a strong desire by UAS proponents and those who wish to become UAS operators to begin flying in the NAS as quickly as possible. Clearly, there are commercial, social, business, and international competitive advantages to a strong UAS industry. However, government and industry must take a longer view of this present state of technology to ensure that robust safety systems, in tandem with Transport Canada-certified redundant systems of UAS, are developed that completely integrate with commercial airline operations and, above all, do so safely. An imprudent rush to create and implement minimum standards will not only harm safety, but potentially produce a setback for the future expansion of UAS operations for years to come.
On behalf of the 54,000 airline pilots whose top priority is safe transportation, we thank the committee for the opportunity to appear before you today, and we look forward to working together to ensure the safety of our air transportation system.