New SFOC & Exemption Summary

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.


    1. I knew from the start the exemptions were of little to no value to most so that is not a surprise. The implementation timing of the new SFOC process is the issue. No one was given any notice to these changes coming into effect. So now some of us are left in limbo having to scramble for info over the holidays.


  1. Seriously? No really? So, we are supposed to comply with a procedure we can’t even see? Or do you only get access to these documents if you are a large defense contractor with well-heeled lobbyists?


    1. I would suggest contacting your regional TC office and asking them directly. One speculation on why the document is not public is that the French translation is not completed, but this may be mere speculation.

      Thing seems to be in a mess right now. I’ve spent all week trying to get details and still stuck in limbo.


  2. And if you unhappy with the new SFOC and related regulations I suggest contacting your MP on the issue. The biggest issue we have right now with the changes is the timing and lack of any advanced notice. The regulations themselves are what was known to be coming for some time but it seems in all the press on the exemptions that the SFOC changes were dumped in with no mention.


  3. Well, at least they sent you the document. I was concerned the problem was worse than that. It’s still not quite an open and transparent process, but at least we are not being asked to comply with officially secret regulations.

    I don’t agree that the regulations are what was known to be coming. First, the development of the regulations was not really public. Not secret, but not public. I knew of several people who were involved, but they would not discuss what was going into it. Again, not a secret, but definitely closed-door policy development.

    Second, the “exemptions” were really not what was suggested was coming. The 9km restriction makes these exemptions useless for most people. This was not what was expected.

    It’s like if Immigration Canada announced they were developing a new immigration policy that would make it quick and easy for anybody to come to Canada. And teasing it, generating lots of media attention. But then when they release the policy, buried deep within it is a clause that says the new policy only applies to people with a PhD.


  4. Latest update we learned 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. So this will rule out that option for many.

    “…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.”


  5. There is a new product out of Ontario being funding sourced, and it appears to have a number of new features that sound interesting…BUT one thing that caught my eye was this:

    “The PlexiDrone means business, literally. We have successfully obtained multiple Special Flight Operating Certificates (SFOC), necessary for commercial flying, and we want to make it easy for you to do the same. Through you simply fill out our online documentation to apply for you personal SFOC’s which we will review and forward to Transport Canada for their approval. You will be all set to start earning money without hassle or worry. Whether you are part of a search and rescue team, a film crew, adventure travel or real-estate company, we are here to simplify your operation and support you all the way!”

    Can it be that the Ontario Regional TC office has some arrangement with them? What are your thoughts?


    1. I’ve caught them posting “misleading” info more than once so I’m a bit skeptical with much of what they say now as a result, They are making a lot of big claims and have shown nothing to date to indicate they can deliver on them.

      As for the SFOC I’m doubtful. That was on their site under the old rules. With the new ones it is far more involved and will be harder to just templatize IMHO. They also make no mention of the insurance requirement. I seen them also post on Twitter a month or so ago “implying” their system needed no SFOC due to the 2kg exemption which was again misleading.

      Might be a good product but their approach has turned me off. Time will tell where it goes but I wouldn’t jump n the bandwagon personally just yet.


      1. I agree with your sentiment on them in general.

        However, a month ago, we all believed that <2kg was exempt, as that was what the government press releases said, before they released the full details of the exemption. I spent hours modifying one of my machines to see if I could get it under 2kg.


  6. In all honesty I never believed under 2kg was going to be a free for all. That never made sense in the context of the previous and draft regulations. Many in the industry knew there would be a number of further restrictions. However i agree that TC made the initial press release poorly which led to confusion and assumptions by many.


    1. I never thought it would be a free-for-all. But from the info that was published, I believed that <2kg would be subject to similar rules as for recreational use. Limited altitude, not close to airports, not too close to people, etc.


      1. Which it is now with the exemption. They are just more limited than most wanted or that meets the needs of most. it is focused on rural applications primarily.


      2. I disagree. The <2kg exemption for commercial operations is nowhere near as permitting as recreational use. The 9km built-up area requirement, if applied to MAAC fields, would mean the vast majority of them would have to close.

        That one requirement in the exemption, is what changes the entire character of the regulation. That changes it from being similar to recreational usage, to being highly restrictive.


  7. Ok here it is August 2015, what is the latest on getting a drone license? Should I wait tell the new FAA rules come out or try getting one before


Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s