Use & Abuse of Terminology in the Canadian UAV Industry

As the UAV industry grows in Canada there are many new companies getting involved in various aspects from manufacturing, training, consulting, and providing aerial services.  As part of this growth is the marketing aspect as new companies push to find clients and expand their exposure in the industry.  It is the wild west and everyone is putting out a shingle in hopes of getting noticed.

With most marketing campaigns companies are looking to set themselves apart from the competition and show their unique offerings. With that can come “marketing spin” when things are pushed to their limits in terms of meaning. Often there is a fine line in the use of certain terminology which can imply something that may not always be the case, especially in the context of how the terms are defined and used by Transport Canada, with companies trying to highlight their services or make their offering stand out from the competition. Care must be taken in how these terms are used and interpreted when trying to decide between companies offering similar drone services.

The way that UAV service providers operate legally in Canada is via what is called an “SFOC” or “Special Flight Operations Certificate”. Operators apply to Transport Canada for an SFOC that allows them to conduct commercial UAV flights, typically for a defined geographic region and within a certain set of flight parameters.  As part of the application process the operator defines their operating and safety procedures as well as processes for managing their crews, aircraft, etc. Transport Cnaada reviews the request and procedures and if they feel it will provide for safe flight operations then a SFOC is granted. Each SFOC is unique so the specific details can vary from operator to operator in regards to when and where they can fly, such as in controlled airspace, at night, maximum altitudes, etc; not all SFOCs are equal so having one in and of itself does not grant the holder to a free for all of drone use, limitations and restriction exist even with an SFOC.

For training there are no current Transport Canada approved/licensed/certified UAV providers.  Transport Canada has defined a set of “knowledge requirements” on which most providers base their curriculum, but they do not certify the courses or trainers. However, organizations offering training that meets the knowledge requirements will be expected to provide Transport Canada with a written self declaration attesting to the compliance of their courseware and testing. Thereafter, SFOC applicants with pilots who have successfully completed such a compliant course will be able to reference that course and ground school provider in their SFOC application as proof of pilot knowledge.

There are also no official exams at this stage (this may be part of the new regulations coming in late 2016/early 2017).  Training currently can be provided by any company looking to do so, from established manned aviation training centers, to new UAV specific startups, as well as online self study, and in house training.

With these points in mind, here are a few of the common terms that can have varied meaning in and out of the context of Transport Canada and lead to possible confusion:

Compliant

This is probably the most confusing term as it relates to UAVs in Canada, in that it has a very specific meaning within the Transport Canada UAV regulations, referring to an operator that has met the conditions of a “Compliant Operator SFOC Application“.

This application process requires the operator to meet specific standards for how the company is operated, how the pilots are trained, and the aircraft used deemed compliant and meet specific design standards. These requirements are generally above and beyond and to a higher level than the more common Restricted SFOCs that the majority are operating under.  

Having an SFOC alone does not make an operator “capital C Compliant”, it needs to be a specific”Compliant” SFOC, whereas small c “compliant” is often used to indicate complying with the UAV regulations in general, a subtle but distinct difference.  The term often is used in a more general sense in marketing and does not always have the Transport Canada meaning.  If someone is using “Compliant” in their marketing it is a good idea to ask for clarification or to see a copy of the “Compliant SFOC”. Complying with the regulations and being a “Compliant Operator” are different.

Currently there are very few Compliant Operators in Canada due to very few compliant aircraft being approved so far. Most providers generally are using Restricted SFOCs.

Certified

This term is often used since the SFOC itself is a “certificate”, therefore the holder is in turn certified.  There is however no further certification process done by Transport Canada beyond the SFOC process that all legal operators must follow.

Certified and Certificate also often get used when dealing with UAV training programs. Many providers offer a certificate on completion of their course.  While this certainly holds some value and shows the student completed a defined program, it is not a certificate issued by Transport Canada or a government or industry agency and really only holds meaning in relation to the organization that issued it. Organizations offering training that meets the knowledge requirements will be expected to provide Transport Canada with a written declaration attesting to the compliance of their courseware and testing. Thereafter, SFOC applicants with pilots who have successfully completed such a compliant course will be able to reference that course and ground school provider in their SFOC application as proof of pilot knowledge.

Licensed

Currently there is no such thing as a licensed UAV pilot, company, or training facility. Some refer to having a SFOC as a license but it is not technically a license for operation. Again, the underlying items that must be in place for all operators is the SFOC, nothing more.

Exempt

Some providers often state that they are “exempt” from Transport Canada SFOC requirements because they use a small (under 2kg) drone. While this is possible and there are a set of regulations dealing with exemptions, they can rarely be used in most applications.

The main issue is exemptions can typically only be used in very rural areas, outside of what Transport Canada calls a “built-up area”, another confusing term which has varied meanings, but in the context of UAVs it refers to anything bigger than a single farmstead within an area of 9km.

Be wary of an operator providing services in urban or even lightly populated areas under an exemption. Often times the provider may be honestly confused and think an exemption applies, but some may also exploit this as an opportunity to get around the SFOC process.

Insured

A UAV provider being insured is definitely an important factor, but in the context of operating legally in Canada it is also mandatory.  An operator without insurance would be working outside the boundaries of the regulations.  (We once seen an operator promoting NOT having insurance as a selling point in regards to keeping their rates low). Insurance is required even even under an exemption, and using a provider without coverage could leave the client on the hook for damages in case of an accident.

The main item to note is how much insurance coverage an operator has.  Transport Canada only requires $100,000 of liability coverage.  Most insurers however generally suggest $1,000,000 or more.

Approved

Outside of the SFOC there is no additional approval process done by Transport Canada for operators or trainers.  Stating “approved” generally implies an SFOC is in place or training meets the knowledge requirements, again nothing more.


With all this said that doesn’t mean someone using these terms and approaches are doing anything wrong or trying to intentionally mislead.  The terminology used in this industry can be confusing, so trying to express these details to a non aviation/UAV client base is a challenge. Often times the terms are used with an intended different meaning to try and put them in common language most can understand and related to; the average person on the street more than likely won’t have a clue as to what an “SFOC” is for example but may see Transport Canada licenses or certified as a meaningful indication that the operator is playing by the rules.

At a minimum when selecting an aerial service provider they will need an SFOC (or possibly an Exemption) and UAV aviation liability insurance.  Ask to see a copy of these if you have concerns.  If a provider states they are “licensed” or “compliant” ask for clarification.

On the training side it is not as clear, but dealing with organizations that has been working in the UAV industry for sometime or have a traditional aviation background is definitely a plus.  Ask for references or talk to others that may have taken the course, first hand experience is a good weigh to measure value in these early stages as training programs evolve.

In the end it comes down to a balance of an honest approach by those in the UAV industry and customers taking the time to research who they hire, doing a little research and reference checking can go a long way in selecting a good reliable legal UAV service provider and separating the buzz words and spin from reality.

Advertising is the art of convincing people to spend money they don’t have for something they don’t need. – Will Rogers

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