SFOC

Transport Canada – Drone Assurance Declaration Online Submission Form

The online submission form for the new Transport Canada drone regulations is now live at: https://www.tc.gc.ca/en/services/aviation/drone-safety/submit-drone-safety-assurance-declaration.html

As per the information listed:

Who can submit a declaration

  • The designer and manufacturer of a drone
  • Third-party drone modifiers
  • Individuals who design and build “home-built” drones

About the RPAS safety assurance declaration

You can declare that your RPAS can safely conduct any or all of the following operations so pilots can register their drones for advanced operations:

  • Operations in controlled airspace
  • Operations near people: less than 30 meters (100 feet) but more than 5 meters (16.4 feet) horizontally
  • Operations over people: less than 5 meters (16.4 feet) horizontally

How to comply

Adding safety features to a drone, such as a deployable parachute, can help it meet the safety requirements for advanced operations.

Advisory Circular AC 922-001: Remotely Piloted Aircraft Systems Safety Assurance provides guidance on complying with the regulations and standards. For a copy of the draft AC contact: TC.RPASDeclaration-DeclarationSATP.TC@tc.gc.ca.

Penalties

We may fine you if you falsely declare to meet the technical requirements set out in Standard 922 — RPAS Safety Assurance. You may be fined $3,000 for a person and $15,000 for a corporation for each registered system.

What you need to know before you apply

You do not need to submit the results of the AC 922-001 Remotely Piloted Aircraft Systems Safety Assurance verification tests along with your declaration of RPAS Safety Assurance. However, you may be asked to produce the results of verification tests at a later date.

New Canadian Drone Regulations – Maritime Info Sessions

Transport Canada will be holding information sessions on the new regulations.  Below is the schedule for the first events in the Maritimes.


Following the publication of the Regulations Amending the Canadian Aviation Regulations (Remotely Piloted Aircraft Systems) on January 9, 2019, Transport Canada officials will be hosting public information sessions to answer questions on the new regulations.

The first sessions will be held:

Date Time Venue Registration
Tuesday, February 19, 2019 1400-1600 Halifax Central Library – Paul O-Regan Hall

5440 Spring Garden Road

Halifax, NS

B3J 1E9

In-person
Wednesday, February 20, 2019 1800-2000 University of Prince Edward Island – Climate Research Lab

550 University Avenue

Charlottetown, PEI

C1A 4P3

Space is limited so please contact climate@upei.ca with your name, affiliation, email and mailing address to reserve your spot
Thursday, February 21, 2019 1900-2100 Fredericton Convention Centre – Pointe Sainte Anne Room

670 Queen Street

Fredericton NB

E3B 1C2

In-person

Additional sessions in other regions will be scheduled shortly.

For further information on drone safety rules, please visit Canada.ca/drone-safety.

New Canadian Drone Regulations – DND Aerodromes

As we previously wrote, operations within 3nm of a DND managed aerodrome will still require SFOCs under the new regulations, and are not part of standard Advanced operations.

For clarification on this issue and its impact on operators that fly frequently in these zones, we reached out to Transport Canada for clarification on how this will be managed:

Our intention is to issue a standing SFOC to cover these types of situations and you should be able to work with DND and NAV Canada to continue to operate as you have been.

This is reassuring to know it can be dealt with under Standing SFOCs.

We have asked further on if an assured UAV is required under such an SFOC and are awaiting further information.

 

TC RPAS SAFE Assurance Draft & Associated Manufacturer Info

Attached are the drafted and associated documents from Transport Canada for the Remotely Piloted Aircraft Systems Safety Assurance process.

These were provided to us by:
J. A. Martin
RPAS Task Force Engineering
Chief Engineer
Transport Canada / Transports Canada (AARV) Tower C, Place de Ville

car part ix – srpas manufacturer regulatory overview

rod – part ix srpas manufacturer regulatory review – jan 24

draft – ac 922-001 – rpas safety assurance

New Canadian Drone Regulations – People, Buildings, Vehicles

One of the biggest changes in  the new Canadian drone regulations on Jan 9 2019 are around minimum distances allowed to people, buildings, and vehicles.

Gone are the restrictions to buildings and vehicles for both Basic and Advanced operations.  The primary requirement being to stay 30M from bystanders.  Flights over vehicles and buildings are permitted, as long as their are no freestanding people.

Horizontal Distance

901.26 Subject to paragraph 901.69(1)(b) or (c), no pilot shall operate a remotely piloted aircraft at a distance of less than 100 feet (30 m) from another person, measured horizontally and at any altitude, except from a crew member or other person involved in the operation.

The exclusion of occupied vehicles and buildings was confirmed by Katelin Klassen of COASTAL DRONE in a recent review with the TC RPAS Task Force:

The 100′ horizontal distance from people mentioned in CAR 901.26 means freestanding bodies. “People” does not refer to those in cars or buildings. Asking people to step inside while you fly is totally reasonable under the new regulations.

One additional item of note near buildings is the ability to exceed the base 400′ AGL altitude limit as well, allowing 100′ above the structure if you are within 200′:

Maximum Altitude

901.25 (1) Subject to subsection (2), no pilot shall operate a remotely piloted aircraft at an altitude greater than

(a) 400 feet (122 m) AGL; or
(b) 100 feet (30 m) above any building or structure, if the aircraft is being operated at a distance of less than 200 feet (61 m), measured horizontally, from the building or structure.

For Advanced operations the distance to bystanders can be further reduced, but is dependent on the assurance level the manufacture has approved for the UAV.  The details on the specifics are still unknown and TBA by TC.

901.69 (1) Subject to subsection (2), no pilot shall operate a remotely piloted aircraft system under this Division to conduct any of the following operations unless a declaration under section 901.76 has been made in respect of that model of system and the certificate of registration issued in respect of the aircraft specifies the operations for which the declaration was made:

(a) operations in controlled airspace;
(b) operations at a distance of less than 100 feet (30 m) but not less than 16.4 feet (5 m) from another person except from a crew member or other person involved in the operation, measured horizontally and at any altitude; or
(c) operations at a distance of less than 16.4 feet (5 m) from another person, measured horizontally and at any altitude.

The exception to this is at advertised events.  These will still require an SFOC for drone operations.

Special Aviation Events and Advertised Events

901.41 (1) No pilot shall operate a remotely piloted aircraft system at any special aviation event or at any advertised event except in accordance with a special flight operations certificate — RPAS issued under section 903.03.

(2) For the purposes of subsection (1), advertised event means an outdoor event that is advertised to the general public, including a concert, festival, market or sporting event.

New Canadian Drone Regulations – Putting an Industry in Limbo

After years of drafts, reworks, and delays, Transport Canada finally released the new Canadian drone regulations on Jan 9 2019.  Set to come into effect on June 1 2019, the regulations are still missing key details when it comes to Advanced operations involving compliant/SAFE assured drones.

Under the changes, any flights done within controlled airspace or near aerodromes require a compliant/SAFE assured drone.  Many commonly used systems, such as those from DJI, Yuneec, Freefly, and others are not on the existing compliant list and details required for manufacturers to submit systems to the list are still not published.

As such much of the industry are in a wait and see limbo phase where many operators do not know when or if their existing drones may be usable or what new UAVs they may have to purchase and at what cost to move forward.

While the existing list has systems that can be used, many do not meet the needs for certain application, such as TV/film work as one example.  Many are older industrial focused aircraft, and carry a much higher price tag than consumer/prosumer drones used by many smaller operators across the country.

Originally Transport Canada had stated there would be a 6 month transition period from the announcement to enforcement, however with core documents still not published the time-frame shrinks even more from the less than 5 months given.

Manufacturers, such as DJI, are waiting on these specifics to decide how they will move forward and what systems they may submit for assurance:

A key component of these new rules is the Safety Assured Flight Envelope system, through which manufacturers will declare that their drones are suitable for use in advanced operations, such as over people or in controlled airspace. DJI will be examining the details of the SAFE system with the goal of participating in it, to continue to provide leading products for our commercial and enterprise customers in Canada.

While we expect more manufacturers will come on-board, it is doubtful that all systems will be added, especially older units, with potential focus on only enterprise level to be available.  The time frame for new systems getting approved is also unknown and could possibly run past June 1.  Time will tell where this goes as manufactures review the time, costs, and associated liability of making submissions.

Alan Auld, a commercial operator in Ontario stated:

I was awarded a city contract for this summer that I’ll have to give up as a result. I’m a small business (filmmaker) who’s had a standing for three years without issue using DJI products. I can’t justify the approved equipment for the market I’m in so I’ll be walking away.

Alan, like many other small commercial operators, has been operating for years under the Special Flight Operations Certificate(SFOC) process, flying safely and legally within controlled airspace without issue.  A process that required liability insurance, which is oddly not even required under the new regulations.  Come June 1 what was once deemed allowable and safe by Transport Canada ends, and unapproved UAVs sent to collect dust.

Businesses trying to plan upcoming work beyond June 1 or that have ongoing contracts with clients throughout the year are now left in the dark.

Art Raham of Shadow Art Camera Services in Edmonton commented:

I had discussions with two clients yesterday wanting to quote on projects for the summer. Both disappointed that I couldn’t guarantee my availability or day rate past June 1.

Transport Canada is giving no prior credit for safe & legal operation for existing commercial operators, it is comply on June 1 with new regulations fully or be grounded.  Years of ongoing flight operations count towards nothing in regards to the flight review that is required under an Advance certificate either.

While most operators are in favor of the general concepts of the new regulations, the big gotcha is the compliant/assured UAVs that put ongoing businesses at risk in this transition.

As an interim solution we would suggest that Transport Canada grandfather in systems currently in use by operators under SFOCs until the end of life of those UAVs, or as a minimum extend the implementation of the new regulations to January 1 2020 so as to provide a proper transitional period, along with an exception from the flight review.  This would allow existing operators to maintain their businesses over the immediate future with minimal change while allowing time for planning a new path forward.

While the new regulations are being touted by Transport Canada as a major step forward, the reality is many businesses are left hovering in place not knowing if they can fly come June.