Radio Silence: The ROC-A Myth and Why Canadian Drone Pilots Must Stay Off the Air

By [Colonel (ret) Bernie Derbach, KR Droneworks]

If you have passed your Advanced RPAS exam, you likely hold a Restricted Operator Certificate - Aeronautical (ROC-A). It is a standard recommendation in many ground schools: get your ROC-A so you can legally use an aviation radio.

Consequently, many pilots go out and buy a high-quality handheld aviation transceiver (like an Icom or Yaesu), believing they are now fully authorized to communicate with Air Traffic Control (ATC) or broadcast their position to other aircraft.

This is a dangerous and illegal misconception.

Holding an ROC-A does not grant a drone pilot the legal right to transmit on aviation frequencies during standard operations. In fact, keying that microphone can result in significant fines from Innovation, Science and Economic Development Canada (ISED).

Here is the breakdown of why you can’t use that radio, why airport vehicles can, and how you should actually be communicating.

The Two-Key System: Operator vs. Station

To legally transmit on an aviation frequency in Canada, you need two distinct "keys." Having one without the other is not enough.

1. Key #1: The Operator Certificate (ROC-A) This certifies the person. It proves you know the phonetic alphabet, standard phraseology, and emergency procedures.

   
   

2. Key #2: The Radio Station License This certifies the equipment and authorizes it to transmit from a specific location.

The Catch: When you fly a manned aircraft (like a Cessna), the radio installed in the dashboard is an "Aircraft Station." These are largely exempt from needing an individual station license for domestic flights.

However, your drone does not have a pilot on board. You are standing on the ground holding a portable radio. In the eyes of the law, you are not an "Aircraft Station"—you are a "Ground Station." Ground stations require a specific license, and standard aviation handhelds do not come with one.

Why ISED Won’t Give You a License

If you apply to ISED for a ground station license to use with your drone operations, it will almost certainly be denied. Why?

• Spectrum Congestion: The aviation frequency band (118-137 MHz) is incredibly crowded. If ISED granted a mobile ground station license to every commercial and recreational drone pilot in Canada, the airwaves would become unusable (in the eyes of ISED).

  
  

• Safety & Identification: Ground station licenses are typically for fixed locations (towers) where ATC knows exactly who and where the transmitter is. A roving drone pilot "self-announcing" from a park 5km away introduces an "unknown actor" into the system. This degrades safety for manned aviation rather than enhancing it (in the eyes of ISED)

The "Snowplow Exception": Why Airport Vehicles Can Use Radios

This is the most common counter-argument: "I see snowplows, tugs, and follow-me trucks driving around the airport talking to the tower all the time. They are on the ground—why can they use radios and I can't?"

The difference comes down to location and control.

1. "Inside the Fence" (Controlled): Airport vehicles operate "Airside." They are physically located on the runways and taxiways. They are part of the airport's internal ecosystem and are often covered under the Airport Authority’s spectrum license or a specific commercial land-mobile license.

   
   

2. Visual Contact: The Air Traffic Controller can look out the window and see the snowplow. They are under positive control. If the radio fails, the tower can signal them with light guns.

   
   

3. "Outside the Fence" (Uncontrolled): As a drone pilot, you are usually operating away from the airport. You are not part of the airport's ground traffic flow, and the tower cannot see you. You are an external variable. Because you are not within the "confines of the aerodrome," you do not qualify for the operational authority that allows ground vehicles to transmit.

How Should RPAS Pilots Communicate?

If you can't use the radio, how do you coordinate with ATC or handle a plane flying toward you?

1. Coordinating with ATC (Controlled Airspace)

Do not call the tower for permission. Unless you have a specific instruction to do so, "cold calling" the tower to ask for permission ties up emergency lines.

• The Correct Procedure: To fly in Controlled Airspace (Class C, D, or E), you do not usually need an SFOC. Instead, you need an Advanced Pilot Certificate and a NAV CANADA Flight Authorization.

• How to get it: Submit your flight proposal via the NAV Drone app (or web portal).

• The "Phone Call" Protocol: Once your flight is approved, read the conditions carefully. In many control zones, the authorization will explicitly instruct you to call the tower by phone (using a provided number) 5-15 minutes before you launch and again immediately after you land.

  
  

2. Dealing with "Intruding" Aircraft

Imagine you are flying your drone and you hear a helicopter approaching. Your instinct is to grab the radio and say, "Helicopter near the park, Drone 1 is descending."

Do not do this.

• The Rule: Right of Way (CAR 901.11). Manned aircraft always have the right of way.

  
  

• The Action: You must immediately yield. This usually means descending and landing if necessary.

  
  

• Why not talk? Manned pilots are not expecting to hear drones on the frequency. A sudden transmission from an unauthorized ground source can step on high-priority ATC instructions. The safest action is to get out of the way, not to talk your way out of it.

Summary

Keep your ROC-A; it is a valuable certificate and provides valuable understanding of aviation communications while you monitor (listen to) frequencies for situational awareness. Listening can help you land your drone before that helicopter arrives.

But when it comes to the "Push-to-Talk" button, remember the rule: Unless you are in a distress scenario where life is at risk, maintain radio silence.

Regulatory References & Definitions

For those who want to see the specific regulations, here is the breakdown of the applicable laws and standards.

1. Licensing and The Act

• Radiocommunication Act, Section 4(1): States that no person shall install, operate, or possess radio apparatus without a valid authorization.

  
  

• Radiocommunication Regulations, Section 15.1: Provides the exemption for "Aircraft Stations" (radios on board planes) to operate without a station license domestically.

  • Note: Because a handheld radio held by a pilot on the ground is defined as a Land Station (specifically an Aeronautical Mobile-Exempt station), the exemption in Section 15.1 does not apply.

2. Operator Certification

• Radiocommunication Regulations, Section 33: Requires that any person operating a radio apparatus on aeronautical frequencies must hold an appropriate certificate (ROC-A).

  
  

• RIC-21: The Study Guide for the Restricted Operator Certificate with Aeronautical Qualification.

3. Airspace and Right of Way

• Canadian Aviation Regulations (CAR) 901.11 (1): "The pilot-in-command of a remotely piloted aircraft system shall give way to power-driven heavier-than-air aircraft, airships, gliders and balloons at all times."

  
  

• TC AIM (Aeronautical Information Manual) - RPA Chapter: Transport Canada explicitly directs RPAS pilots to use "electronic means" (apps/portals) for airspace coordination rather than voice communications.

4. Airport Vehicle Operations

• TC AIM - RAC (Rules of the Air): Details that vehicles on airport maneuvering areas are required to maintain two-way radio contact with ground control.

  
  

• Spectrum Management: These vehicles generally operate under a site-specific license granted to the Aerodrome Operator, allowing transmission only within the aerodrome boundaries—authority that does not extend to RPAS pilots operating off-site.