Madam Chair, I wish to extend my appreciation to the committee for the invitation to appear as a witness.
Unmanned Systems Canada is a national not-for-profit association established in 2003. With 500 members, we represent the Canadian unmanned systems community. We have been proactively engaged with Transport Canada since 2006, a decade ago, regarding the development of UAV regulations. We have co-chaired the UAV systems program design working group with Transport Canada since its inception in 2010, which has resulted in the guidance material used today by industry and regulators.
The current visual line of sight practices, honed over five years of commercial operations, are the basis of what is being proposed as amended regulations with Canada Gazette part I notification expected by mid-2017.
From an industry association's perspective, I will not address the regulations themselves, but rather how they will be implemented. Our critical concern is business continuity.
Under the current regulations, UAV operations are approved by means of a special flight operations certificate, SFOC, whereby an operator in their application for that SFOC describes how the risks of their operation are mitigated. A decade ago, the issue was the lack of guidance to industry and the regulator on how an application should be made by industry for an SFOC, how the regulator might approve an application, and the business risk associated with the lack of an approval process.
Since then, the working group results, our association's visual line of sight best practices, improved Transport Canada staff instructions, and increasingly reliable and affordable equipment, coupled with major business opportunities, have resulted in the dramatic growth of SFOC approvals.
Let's talk about business continuity. In 2011 about 100 SFOCs were approved by Transport Canada. Last year that number was 2,480, and we've passed the 4,000 mark as of this year. There are now 1,000 UAS-related businesses in Canada. This is why business continuity is at the forefront of our concerns. These companies invest in intellectual capital, equipment, training, marketing and sales to meet the requirements of the regulator and to develop commercially viable businesses.
UAS technology applied in areas as diverse as the film industry, construction, and precision agriculture have resulted in better, safer, and cheaper business practices. These results are reflected in an increase in investment dollars flowing to the industry. Regulatory certainty is an important criterion for investors to determine the risk to their investment. Therefore, we are very pleased that Canada is moving ahead toward a regulatory structure.
The business continuity risk we're discussing here has two aspects. One is the transition to the regulations and the second one is the capacity risk at Transport Canada. The two are linked.
With regard to the transition, the regulations are going to address three fundamental areas and accords with how the regulations are structured: knowledge requirements, operating procedures, and equipment.
Companies have invested heavily to build their businesses, and therefore it is critical to their business continuity that the transition to the proposed regulations take into account a business means test reflected in an enabling transition plan. Companies with approved SFOCs should see no change in their operations other than minor adjustments. However, we have concerns, such as how UAV equipment requirements will be defined. Part of the solution will be grandfathering, which recognizes investments made, ongoing business obligations, and proven expertise.
Let's turn to capacity risk at Transport Canada. You may be surprised to learn that there are only two people in the department who are dedicated to UAS regulations. This situation poses the most significant risk to Canadian industry. Not only is the transition to the proposed regulations at risk, but there is also a growing backlog of issues critical to the future of the industry.
We are one of the most innovative industries in Canada, so visioning is part of our DNA. In October our association published “Beyond Visual Line of Sight Best Practices” to enable the industry to take the next critical step. The business case for BVLOS operations needs to be built, just as we have done with visual line of sight operations to capture the immense economic potential.
A recent PricewaterhouseCoopers report estimated that the global accessible market for UAS operations is $127 billion. In sectors ranging from mining to forestry, environmental, pipeline and railway monitoring, to precision agriculture, we have the geography and the expertise to take our experience to the global market.
The lack of capacity at Transport Canada has directly impacted Canadian businesses by a lack of priority on BVLOS operations which is the Holy Grail of the industry in which we're in a global competition.
Canada is a world leader in developing the UAS industry. Unfortunately, failing comparable investment by other nations such as the U.S., Australia, and the various countries in Europe, we are now falling behind. Therefore, we need accelerated government action and investment to ensure that our industry continues to innovate and flourish. We encourage government to examine the broad economic and social implications of this industry, and how other departments can provide resources beyond just those implicated in a regulatory development.
In summary, we are pleased UAS regulations for visual line of sight are being proposed. However, we need a thoughtful implementation strategy to enable Canadians to establish a global market share with this technology, with accelerated government investment and action that is responsive to market realities.
Thank you.