In order to use the Compliant Operator Application Process under the new SFOC procedures, one the of requirements is that the UAV is compliant.
The criteria for a compliant UAV is outlined in Appendix C of the SI 623-001 document. To be compliant the aircraft needs to meet specific requirements across the following area:
- Flight Performance
- UAV Structure
- Design and Construction
- Propulsion System
- Systems and Equipment
- Manuals and Documentation – Flight and Maintenance
UAV System Airworthiness
(i) To be considered “Compliant”, a UAV will be required to meet the Small UAV Design Standard found in Appendix C.
(ii) Achieving Compliance – To achieve compliance the manufacturer must analyze the technical specifications, drawings, calculations, assembly instructions and other documented materials that fully describes the model of aircraft and its associated systems (i.e. type definition) against the requirements of the design standard, and conduct any necessary ground and flight tests to determine that it is compliant.
The issue with many of the smaller UAVs is that there is no specific documentation, manuals, or maintenance schedules that a full-size aircraft may have. This is further complicated when custom built UAVs are involved and the operator is the manufacturer in essence.
As part of the compliance, the aircraft needs to have both a Declaration of Compliance and Statement of Conformity.
Documenting Compliance – The manufacturer must preserve sufficient documentation to substantiate how each requirement of the Design Standard has been met to include any ground and flight testing.
A Declaration of Compliance is a written submission to TC by the manufacturer of a small UAV system attesting that the Type Definition for a particular make and model of a small UAV system complies with the Design Standards published in Appendix C and has found the UAV performance to be acceptable.
A Statement of Conformity is a document upon which a manufacturer attests that a specific small UAV system conforms to the Type Definition as stated in the Declaration of Compliance for that make and model of small UAV system and the owner attests that it has not been altered or modified so as to invalidate the manufacturer’s attestation.
Type Definition means the Manufacturer’s technical specifications, drawings, calculations, assembly instructions and other documented material for a particular model of UAV. This information must be kept by the manufacturer and be made available to Transport Canada upon request.
UAV Compliance is the biggest hurdle we seen for most operators and to operate effectively an operator really needs to be Compliant, the restrictions imposed by the other application types will limit what the business can do, eliminating them from a large portion of potential work. It is unknown at this time how operators will be able to get a Declaration of Compliance and Statement of Conformity from manufacturers for the requirements of TC when main of these are custom systems built if far reaches of the world. Also many are custom built by the operator or modified from the baseline, again it is unclear if and how these aircraft can meet the requirements as a result.