After studying, reviewing, and writing on the new SFOC Application Process and Exemptions the last few days, I thought I would summarize the key points into a quick reference article. This summary represents our understanding of the current new processes; be sure to reference the Transport Canada website for the full official details.
When first announced the SFOC Exemptions were promoted as an easing and simplification of the old SFOC process, which would reduce the workload on TC and make UAV usage easier to some operators. The issue we discovered however is that the Exemptions have a number of requirements that must be met before they can be used.
The main item that most overlooked and that restricts the widespread use of the exemptions for many is the 5NM (9KM) restrictions from airports and built-up areas.
When you boil down the exemptions they are really for very specific and limited use, targeted at remote rural areas for farming, forestry, and mining type operations. For most operators the restrictions will be far too limiting for them to be used for commercial work, and you will need to file for an SFOC as had been done in the past.
So for those that can’t meet the limited exemptions for use you are left with filing an SFOC as has been done in the past. The issue however is that the SFOC process has changed.
Under the new SFOC process there are basically two application types that will apply to the majority of commercial operators:
- Compliant Operator Application
- Restricted Operator Application – Simplified Application
Compliant Operator Application
The complaint operator process is the primary one that TC wants everyone to work towards and offers the most flexibility in terms of when and where you can operate. The issue however is the amount of paperwork, processes, and requirements that are needed for this level of application. To be a Compliant Operator you need to have Compliant Pilots and Complaint UAVs, each of which has a list of its own specific requirements.
- Manuals must be created for all operations and procedural tasks.
- Training must be tracked and managed for all personnel.
- Pilots must have a fullsacle license or have passed a ground school, and a valid medical.
- UAVs must meet specific design standards, have operational and maintenance manuals, and be signed off by the manufacturer that it is airworthy and meets all design requirements.
Restricted Operator Application – Simplified Application
Restricted applications 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.
The simplified application most closely mirrors the prior process used by most commercial UAV operators. However, unlike the old process, the new Simplified Application has much tighter restrictions. 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 Application. It is also limited to 300 feet AGL maximum altitude.
As a result of the restrictions it will limit the effective use for many operators, although it may met the needs of some and will be the best/simplest path forward.
EDIT Dec 30 2014:
We have been informed today by TC that you CANNOT apply with multiple UAVs under the new RESTRICTED OPERATOR – SIMPLIFIED APPLICATION PROCESS. To have more than one aircraft you need to use RESTRICTED OPERATOR – COMPLEX APPLICATION PROCESS.
…for multiple makes and models under one application you need to submit an application that meets the SUR 623-001V2 Section 10.0 RESTRICTED OPERATOR – COMPLEX APPLICATION PROCESS criteria.