compliant

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.

Exemptions

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.

SFOC

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.

New SFOC Application Process – Part 6 Compliant UAV

sfocIn order to use the Compliant Operator Application Process under the new SFOC procedures, one the of requirements is that the UAV is compliant.

The criteria for a compliant UAV is outlined in Appendix C of the SI 623-001 document. To be compliant the aircraft needs to meet specific requirements across the following area:

  • Flight Performance
  • UAV Structure
  • Design and Construction
  • Propulsion System
  • Systems and Equipment
  • Manuals and Documentation – Flight and Maintenance

UAV System Airworthiness
(i) To be considered “Compliant”, a UAV will be required to meet the Small UAV Design Standard found in Appendix C.
(ii) Achieving Compliance – To achieve compliance the manufacturer must analyze the technical specifications, drawings, calculations, assembly instructions and other documented materials that fully describes the model of aircraft and its associated systems (i.e. type definition) against the requirements of the design standard, and conduct any necessary ground and flight tests to determine that it is compliant.

The issue with many of the smaller UAVs is that there is no specific documentation, manuals, or maintenance schedules that a full-size aircraft may have. This is further complicated when custom built UAVs are involved and the operator is the manufacturer in essence.

As part of the compliance, the aircraft needs to have both a Declaration of Compliance and Statement of Conformity.

Documenting Compliance – The manufacturer must preserve sufficient documentation to substantiate how each requirement of the Design Standard has been met to include any ground and flight testing.

A Declaration of Compliance 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 and has found the UAV performance to be acceptable.

A Statement of Conformity is a document upon which a manufacturer attests that a specific small UAV system conforms to the Type Definition as stated in the Declaration of Compliance for that make and model of small UAV system and the owner attests that it has not been altered or modified so as to invalidate the manufacturer’s attestation.

Type Definition means the Manufacturer’s technical specifications, drawings, calculations, assembly instructions and other documented material for a particular model of UAV. This information must be kept by the manufacturer and be made available to Transport Canada upon request.

UAV Compliance is the biggest hurdle we seen for most operators and to operate effectively an operator really needs to be Compliant, the restrictions imposed by the other application types will limit what the business can do, eliminating them from a large portion of potential work. It is unknown at this time how operators will be able to get a Declaration of Compliance and Statement of Conformity from manufacturers for the requirements of TC when main of these are custom systems built if far reaches of the world.  Also many are custom built by the operator or modified from the baseline, again it is unclear if and how these aircraft can meet the requirements as a result.

New SFOC Application Process – Part 5 Compliant Pilot

sfocIn order to use the Compliant Operator Application Process under the new SFOC procedures, one the of requirements is that the UAV Pilot is compliant.

The criteria for a compliant pilot is outlined in Appendix B of the SI 623-001 document.  The main elements are as follows:

  • 18 or older.
  • Medically fit.
  • Knowledge of flight law and procedures and has completed an approved ground school or holds a valid civil or military pilot’s license.
  • Experienced on the UAV(s) to be used.
  • Skilled in normal and emergency maneuvers.

The full details are as follows:

A Compliant Pilot of a small UAV system, restricted to VLOS, will meet the following requirements:
(a) Age – The pilot shall be a minimum of eighteen (18) years of age
(b) Medical Fitness – The pilot shall be deemed eligible for a Category 4 Medical Declaration/Certificate. A current medical associated with a pilot’s licence or permit would suffice.
(c) Knowledge – A UAV Pilot-in-command shall have:
(i) completed a course of pilot ground school instruction, based on the TP1526E – Recommended Knowledge Requirements for Pilots of Small Unmanned Air Vehicle Systems, Restricted to Visual Line-of-Sight, which includes the following subjects:
(A) air law and procedures relevant to the permit (e.g. general provisions, general operating and flight rules, air traffic control services and procedures, aviation occurrence reporting),
(B) flight instruments (e.g. altimetry, GPS, airspeed and heading indicators),
(C) navigation (e.g. aeronautical charts, pre-flight preparation),
(D) flight operations (e.g. wake turbulence causes, effects and avoidance; data and command links),
(E) meteorology (e.g. required for line-of-sight operations),
(F) human factors (e.g. aviation physiology, the operating environment, aviation psychology), and
(G) theory of flight (e.g. basic principles),
(ii) obtained a passing grade on a written exam, administered by a training organization.
(d) Experience – The UAV pilot shall have acquired on a small UAV system:
(i) practical training; and
(ii) has reached a satisfactory standard of experience to establish proficiency.
(e) Skill – The pilot must successfully demonstrate the ability to perform both normal and emergency manoeuvres appropriate to the small UAV system used for the training program, and with a degree of competency appropriate for the operation of a small UAV system – Restricted to VLOS
(f) Credits – A UAV pilot may be given credit for previous experience in accordance with the guidance below:
(i) Canadian Civil Licence:
(A) UAV pilots who hold a Private Pilot Licence or higher may be considered to have met paragraph c above (knowledge requirement).
(ii) Foreign Pilots:
(A) UAV pilots with foreign credits will be evaluated on a case-by-case basis.
(iii) Canadian Forces Pilots:
(A) Active and retired Canadian Forces personnel who have qualified to pilot aeroplane wings standard or who have successfully completed the Basic Flying Training course of approximately 120 hours, may be considered as having met paragraph c above (knowledge requirement).
(B) Active and retired Canadian Forces pilots who hold current Canadian Forces qualifications on a small UAV (or equivalent), may be considered as having met paragraph c, d and e above (knowledge, experience, skill).

New SFOC Application Process – Part 4 Compliant Operator

sfocIn order to use the Compliant Operator Application Process under the new SFOC procedures, one the of requirements is that the Operator is compliant.

The criteria for a compliant operator is outlined in Appendix D of the SI 623-001 document.

A large portion of the compliance for an operator builds on the processes and procedures that were part of the old SFOC application, in that operating and emergency procedures were defined and detailed and personnel were in place and properly trained for their role.  It is made more formal under the new process, and training records and manuals now must be maintained to a specific standard.

For training, the following is what must be maintained:

(d) Training
(i) Training Program
(A) The UAV operator shall establish and maintain a ground and flight training program that is designed to ensure that each person who receives training acquires the competence to perform their assigned duties.
(B) The UAV operator’s ground and flight training program shall be conducted in accordance with the Training Standard provided in paragraph (e) below and will include:
I. company indoctrination training;
II. upgrading training;
III. training in the specific work to be conducted; and
IV. initial and recurrent training, including
V. UAV type training,
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VI. procedures for passing piloting control from one control station or pilot to another,
VII. aircraft servicing and ground handling training,
VIII. emergency procedures training,
IX. training for personnel who are assigned to perform duties associated with the flight, and
X. any other training required to ensure a safe operation.
(C) The UAV operator shall:
I. include a detailed syllabus of its ground and flight training program in its operations manual; and
II. ensure that adequate facilities and qualified personnel are provided for its ground and flight training program.

(e) Training – Standard
(i) Company Indoctrination Training – This training is required for all persons assigned to the operation. Company indoctrination training shall include, as applicable ;
(A) Canadian Aviation Regulations and applicable standards;
(B) UAV SFOC and the conditions specified therein;
(C) company reporting relationships and communication procedures, including duties and responsibilities of crew members and the relationship of their duties to other crew members;
(D) flight planning and operating procedures including
I. operational preparation procedures related to reconnaissance of aerial work areas before low level flight operations; and
II. operational restrictions;
(E) fuelling procedures, including fuel contamination precautions;
(F) critical surface contamination and safety awareness program;
(G) use and status of the operations manual including maintenance release procedures and accident/incident reporting procedures;
(H) meteorological training appropriate to the area of operation;
(I) navigation procedures appropriate to the area of operation;
(J) carriage of external loads;
(K) operational control system; and
(L) weight and balance system.
(ii) Upgrading Training
(A) Upgrading training to PIC on a UAV type shall include:
(B) completion of applicable qualification training related to assigned duties; and
(C) completion of type training as PIC on the UAV type and a PIC competency check.
(iii) Ground Technical Type Training (Initial and Recurrent)
(A) This training shall ensure that each crew member is knowledgeable with respect to the systems of the UAV system and all normal, malfunction and emergency procedures, as applicable to their assigned duties. Ground technical type training programs shall include:
I. aircraft systems operation and limitations as contained in the UAV system operating manual, manual supplements, standard operating procedures;
II. use and operation of navigation and ancillary equipment;
III. equipment differences of UAV of the same type, as applicable;
IV. UAV performance and limitations;
V. weight and balance procedures; and
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VI. UAV servicing and ground handling procedures.
(iv) UAV Servicing and Ground Handling Training
(A) Training in UAV servicing and ground handling for each crew member, as applicable to their duties and applicable to the UAV type, shall include:
(B) fuelling/charging procedures:
I. types of fuel, oil and fluids used in the UAV;
II. correct fuelling procedures;
III. procedures for checking fuel, oil and fluids and securing of caps; and
IV. procedures for charging batteries.
(C) use and installation of protective covers; and
(D) procedures for operating in cold weather such as:
I. moving the UAV or other components of the UAV from a warm facility when precipitation or high humidity is present;
II. engine pre-heat procedures including proper use of related equipment; and
III. managing battery degradation.
(v) UAV Flight Training Program (Initial and Recurrent)
(A) The initial and recurrent flight training program shall ensure that each crew member is trained to competently perform the assigned duties including those relating to abnormal and emergency duties. Simulated malfunctions and failures shall only take place under operating conditions which do not jeopardize safety of flight. Flight training programs shall include, as applicable to the UAV system:
I. standard operating procedures for normal, abnormal and emergency operation of UAV systems and components;
II. use of check lists and pre-flight checks;
III. crew member co-ordination procedures;
IV. normal take-offs/launchs, circuits, approaches and landing/recovery including, as applicable, ground manoeuvring and hovering;
V. control station fire procedures, including smoke control;
VI. fire control and handling of hazardous materials;
VII. simulated engine and system malfunctions and failures including hydraulic and electrical systems;
VIII. simulated failure of navigation and communication equipment;
IX. stall (clean, take-off/launch and landing/recovery configuration) prevention and landing/recovery procedure;
X. autorotations and anti-torque system malfunctions, as applicable;
XI. rejected take-off/launch and landing/recovery procedures;
XII. use of performance information and performance calculation procedures;
XIII. simulated emergency descent;
XIV. collision avoidance techniques;
XV. operational procedures involving visual observers;
XVI. steep turns and flight characteristics;
XVII. briefings on recovery from turbulence and windshear; and
XVIII. flight manoeuvres used in specific operations.
(vi) Training and Qualification Records
(A) The UAV operator shall, for each person required to receive training, establish and maintain a record of:
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I. the person’s name and, where applicable, personnel permit/licence number,
II. if applicable, the person’s medical category and the expiry date of that category;
III. the dates on which the person, while in the UAV operator’s employ, successfully completed any training or competency checks; and
IV. information relating to any failure of the person, while in the UAV operator’s employ, to successfully complete any training or competency check or to obtain any qualification required herein.
(B) The UAV operator shall retain the records referred to in paragraphs (A) (III) and (IV) above, for at least three years.

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