UAV SFOC Myths: I’ll attach a tether and then I don’t need an SFOC

Myths and Facts opposition written on whiteboardUAV SFOC Myth: I’ll attach a tether and then I don’t need an SFOC.

There have been various debates and discussions around ways to circumvent the UAV regulations, one of which is to attach a small line or tether attached to the ground to basically make it not a UAV by definition.  There have even been products sold and marketed to this potential loophole in the US (although the product appears to have since been pulled).

The reality however is this loophole has been closed by Transport Canada.  The latest regulations make specific reference to this:

6.17 Tethered UAVs
(1) Generally, aircraft that do not carry persons (e.g. small balloons/airships and kites) that are connected to the ground by way of a tether, operated as antennas, surveillance aircraft, sampling devices etc. are treated as obstacles to air navigation and are to be marked and lit in accordance with the obstruction marking and lighting standards found in section 621.19 of the CARs. However, since the Minister is responsible for protecting persons and property on the ground and other airspace users, tethered UAVs that are extremely manoeuvrable and which operate over wide vertical/horizontal areas may require an SFOC. In these cases, protecting other airspace users by marking, lighting and issuing a NOTAM may not be sufficient and/or may not address very low level operations in built-up areas.
(2) The type of regulations that apply to tethered UAVs depends on what type of UAV is being considered and the purpose of the aerial work. However, operating an aircraft on a tether simply to avoid SFOC requirements is not a viable solution.

While it is still not spelled out in clear black and white catchall terms, it is stated that tethering is not acceptable if it is merely used to avoid an SFOC.

At the end of the day a lot of it comes down to common sense.  If something is being used merely to circumvent a law then it more than likely isn’t the best approach to business.


  1. Not related to this posting: but what qualifies a person as a TRAINED visual observer when applying for a SFOC?


    1. The training is really up to the operator to define and provide. The duties and responsibilities of the observer are defined in the SI document.

      Visual Observers
      A visual observer is a crew member assigned and trained to perform duties associated with the provision of sense and avoid, such as continuously monitoring the UAV and the airspace (e.g. for other traffic, clouds, obstructions and terrain) both around and sufficiently beyond the UAV. For operations within VLOS, a visual observer(s) will be required unless a safety case can be provided that shows how the risks can otherwise be mitigated.
      The primary task of the visual observer is to provide the PIC with information to manoeuvre the aircraft clear of any hazards and any potential collision with ground obstructions or air traffic. Additionally, the visual observer must assist the UAV pilot to comply with applicable SFOC conditions, such as flight visibility and cloud clearance requirements and keeping the aircraft within VLOS. The visual observer must be able to see the aircraft and the surrounding airspace throughout the entire flight. They must be able to determine the aircraft’s relative altitude, flight path, and proximity to all aviation activities and other hazards (e.g. terrain, weather, structures) sufficiently to prevent the aircraft from creating a collision hazard.
      Visual observers shall only perform observation duties for one (1) UAV at a time
      Visual observers must maintain constant communication with the UAV pilot and have the ability to communicate timely information to the UAV pilot to avoid other aircraft where a potential for conflict exists.
      The use of visual observers in/on moving land vehicles will not be approved as a method of extending the operating area/range of a UAV system.
      For visual observers, the following are considered the minimum requirements:
      Age – Minimum age of 18 years old.
      Visual acuity sufficient to conduct their duties.
      Visual acuity sufficient to conduct their duties.
      Visual scanning techniques;
      Inter-crew communication requirements;
      Hazardous in-flight weather conditions;
      Actions to be taken in the event a risk of collision develops;
      The vertical and horizontal boundaries of the operation;
      The class of airspace in which they intend to operate including the vertical and horizontal airspace boundaries and determining adjacent classes of airspace;
      Right of way rules as specified in the SFOC; and
      The UAV system limitations.
      Radiotelephony – A Radiotelephone Operator Restricted Certificate (Aeronautical) is required to communicate on frequencies within the protected aviation band.
      Language Proficiency – compliance with the language proficiency requirements of subsections 401.06(1) and 421.06(4) of the CARs.


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