Further to our previous article New SFOC Application Process – Part 1, the following take a look at the new application types.
The Staff Instructions document that is being discussed can be found here for reference: https://flitelab.files.wordpress.com/2014/12/si-623-001.pdf
Under the previous SFOC process, there was basically one application type that was created by the operator detailing their planned operation and associated equipment, personnel, procedures, plans, etc. which we outlined in these articles:
- UAVs & SFOCs: An Overview of the Commercial Use of Unmanned Aircraft in Canada
- SFOC Application Sample
Under the new process there are now 4 types of applications:
- Compliant Operator Application
- Restricted Operator Application – Complex Application
- Restricted Operator Application – Simplified Application
- Restricted Operator Application – MAAC/AMA Application
Compliant Operator Application
These Certificate applicants are required to demonstrate that they have a compliant organization with qualified personnel operating a compliant small UAV within VLOS in accordance with a set of criteria. These applicants will be granted greater geographical flexibility, longer SFOC validity periods and this process will provide for more streamlined SFOC renewals. The processing of Compliant operator applications may also be given priority. See the specific eligibility requirements and SFOC application process in Section 9 of this SI.
The Compliant Operator Application is now the new standard application type that TC prefers all operators submit under and as such it provides for the most flexibility in terms of where and when you can operate. The issue with this type however are the eligibility requirements and documentation that must be provided to be granted this type of SFOC.
In order to use this Compliant operator application process, the proposed operation will have to consist of a small UAVs operated within VLOS under VFR, day or night, where the Certificate applicant demonstrates that:
(a) all pilots are appropriately qualified;
(b) a small UAV system meets the Design Standard; and
(c) the UAV operator is compliant.
Certificate applicants shall provide the following documents in support of their initial SFOC application:
(a) UAV operator operations manual;
(b) Standard Operating Procedures (SOPs);
(c) Training manual;
(d) UAV system flight manual;
(e) UAV maintenance manual;
(f) Declaration of Compliance; and
(g) Statement of Conformity.
The major hurdle in these new requirements will be the Declaration of Compliance and Statement of Conformity. These both appear to require sign-off from the UAV manufacturer with supporting material on their testing of air worthiness.
Restricted Operator Application
These Certificate applicants are either unable or unwilling to meet the criteria to become a Compliant operator or compliance with these criteria is not required based on the scope and complexity of the operation. Again, these operators will be granted fewer privileges than those extended to Compliant operators. A description of each methodology is provided below.
Restricted application basically include anything that falls outside of the Complaint Operator Application, and are similar in many respects to the previous SFOC process that existed before the update in November.
Applies to all UAV system operations except those addressed under Compliant operator applications or any other Restricted Applications outlined below. See the specific eligibility requirements and SFOC application process in Section 10 of this SI.
The Complex Application appears to be intended for special case operations:
This SFOC application process applies to all Certificate applicants who are not eligible to apply under the Compliant operator, Simplified, or MAAC/AMA processes. Specifically this process applies to:
(a) Small UAVs (not Compliant operators or Restricted operators – Simplified application process);
(b) UAVs with a maximum take-off weight above 25 kg;
(c) Model aircraft operated by non MAAC members where the aircraft exceeds 35 Kg;
(d) UAVs conducting BVLOS operations;
(e) UAVs participating in air shows;
(f) UAVs operated by eligible foreign UAV operators; or
(g) UAVs operating in Class F Restricted airspace dedicated to UAV testing and development.
Applies to small UAVs, operated within VLOS where the scope of operation is limited. See specific eligibility requirements and the SFOC application process in Section 11 of this SI.
The Simplified Application most closely mirrors the prior process used by most commercial UAV operators.
This SFOC process applies to all Certificate applicants who do not intend to apply under the Compliant operator or Complex processes and are not eligible to apply under the MAAC/AMA processes. Specifically this process applies to:
(a) small UAVs operating within VLOS conducting pilot training or aerial work (excluding aerial demonstrations or air shows before invited persons).
However, unlike the old process, the new Simplified Application has much tighter restrictions:
In order to use this simplified application process, the proposed operation will have to consist of a single make/model of small UAV operated within VLOS under VFR, day or night:
(a) from a single control station;
(b) in flight by a single pilot at any one time;
(c) at a maximum altitude of 300 feet AGL;
(d) at not less than 100 feet lateral distance from persons not associated with the operation;
(e) only in Class G airspace;
(f) more than 3 nm from the centre of an aerodrome:
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(g) at a maximum calibrated airspeed at full power in level flight of 87 knots or less; and
(h) with no explosive, corrosive or bio-hazard payloads carried onboard or any payloads that can be jettisoned, dispersed or dropped.
The main item that will impact commercial operators is that this can only be used for uncontrolled airspace. To fly in controlled zones it appears the only means possible is via the Compliant Operator or Restricted Complex Application. It is also limited to 300 feet AGL maximum altitude.
Applies to model aircraft that exceed the 35 kg maximum weight required to meet the definition of model aircraft and are operated recreationally by members of MAAC for all operations or AMA member participating in MAAC sponsored events. See specific eligibility requirements and the SFOC application process in Section 12 of this SI.
The MAAC Application is for oversize recreational model aircraft, and thus is not associated with commercial operations.
This SFOC application process applies to model aircraft that are too heavy to meet the definition of model aircraft. They are model aircraft that are operated recreationally by MAAC members, in accordance with the relevant MAAC Safety Codes. They also include AMA members who are visitors to Canada that hold a valid Flight Permit for the AMA Experimental Class for models weighing 55-100 lbs and who are demonstrating at events sanctioned by MAAC.
While the 4 types exist, the end goal of Transport Canada (TC) is to have all applicants becoming Complaint at some time-frame:
The UAV system regulatory recommendations approved by the TC Canadian Aviation Regulatory Committee require UAV operators to become “Compliant”. As such all Certificate applicants are strongly encouraged to work towards becoming compliant to ensure their operations can be continued with minimal interruption once future regulatory development is completed.