Terminology: Declaration of Compliance

Declaration of Compliance – As it relates the the Transport Canada UAV SFOC process, 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 of SI 623-001 and has found the UAV performance to be acceptable.

7 comments

  1. Time for me to join the discussion.

    Are they any manufactures that are providing their Canadian customers with Declaration of Compliance and Statement of Conformity documents? I haven’t heard back from anyone I’ve contacted (DJI and a few UAV e-tailers). If not, it would seem Compliant is currently an option, and the only people receiving new SFOCs post-Nov2014 update will be those who apply for Restricted…

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    1. Not that I’m aware of to date. For most like DJI the Canadian market may be too small to be worth the bother but I’m not sure but I do know it has been brought to their attention. Signing the compliance letter without the backup of the required testing may put them too much at risk in the end liability wise. Many will probably not bother getting tested to meet compliance for low end systems. Such regulations is why we have systems that cost $50K with less functionality of hobby grade systems. We pay for the cost of playing the certification game with government. This relates back to my concern that these new regulations cater to certain specific Canadian manufacturers.

      Many operators may be left holding UAVS that will not be compliant in the end. And the way the regulations are written the Restricted application process for SFOCs is only temporary and could be pulled at any point.

      Regulating small UAVs as if they were fullscale commercial passenger carrying aircraft is a bit overboard IMHO. Even amateur built aircraft don’t need to meet these requirements. You could build an ultralight from plans and fly it over a town with less restriction than flying a UAV over a building. Things seem a bit unbalanced all in the guise of safety.

      There are a lot of concerns that could become issues in the coming years, and this leads back to operators needing a voice to represent their needs, one I think is currently missing.

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      1. So then what happens when the pre-Nov2014 Standing SFOCs expire? UAV operations just shut down because TC wants documentation that can’t be had?

        I was talking to my dad (private pilot) about this the other day. He said this looks exactly like the ultralight situation in the 70s. Apparently TC tried to regulate-away the whole thing, so ultralight owners/pilots just flew w/o licensing or approval. Eventually TC realized that they didn’t have the resources to shut them all down, so they started working with them to make sane, safe regulations that worked for both TC and the ultralight community.

        I really hope we don’t have to endure years of civil disobedience to get workable regulations put in place.

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      2. Yes when your existing SFOC expires you have to reapply under the new regulations. We refiled prior to the new rules back in early November but our application never got looked at until mid December due to the current backlog of 6-8 weeks. Our application, which was sufficient in 2014 was then processed under the new rules and rejected. We had to then refile under the new process. We filed as Restricted Complex since Complaint has elements no one yet understands such as the compliance letter.

        There will be operators forced out of business with the new rules. It’s more an issue of how many.

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  2. Does anyone have new information or current experience with the compliance/conformity situation over the past year? If business are receiving “open/standing” SFOCs how are they dealing with the issue?

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