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Staff Instruction (SI) No. 623-001

The review and processing of an application for a Special Flight Operations Certificate for the Operation of an Unmanned Air Vehicle (UAV) System

Internal documents and documents hyperlinked and stored on
Transport Canada's intranet mentioned in this document
are available upon request. See Contact Office below.

Issuing Office: General Aviation    
Activity Area: Qualifying SI No. 623-001
File No.: 5812-11 U Issue No. 01
RDIMS No.: 4543935 Effective Date 2008-11-27

1.0  INTRODUCTION

1.1  Purpose

  1. The purpose of this staff instruction is threefold.

    1. First and foremost, it provides Inspectors with the information, procedures and guidelines necessary to process an application and prepare a Special Flight Operations Certificate (SFOC) required by section 602.41 of the Canadian Aviation Regulations (CARs) for the safe conduct of unmanned air vehicle (UAV) systems.
    2. Secondly, it provides guidance to individuals and organizations when they are exercising privileges granted to them under an External Ministerial Delegation of Authority, although there are presently no such delegations.
    3. Lastly, it provides Certificate applicants with guidance for submitting an application concurrently with giving them the opportunity to review the guidelines provided to Inspectors. Certificate applicants should be aware, however, that the questions contained within the body of this document are only intended to provide guidance to Inspectors, rather than consisting of individual questions to be answered by the applicant.
  2. This staff instruction has been prepared in line with the functional authority and direction given by the Headquarters Personal Aviation, Launch Safety and Special Flight Operations division, which is the delegated Functional Specialist for flight operations involving unmanned air vehicle systems. It will ensure common application of policies, directives, standards and procedures within Transport Canada. This staff instruction will aid Headquarters and Regional staff by providing guidelines and advice in their activities with regard to national policies, directives and standards. All personnel, directly or indirectly concerned with unmanned air vehicle system operations must be informed and apply these procedures as contained in this staff instruction.
  3. This is a living document and will be revised at intervals to take account of lessons learned, changes in technology, harmonization with international regulations and feedback from the UAV industry. The granting of Special Flight Operations Certificates will continue until the scheme of regulation for civil UAVs matures. Even when detailed standards for UAV operations finally become incorporated into legislation, they must evolve to keep pace with technological developments, so they will have to be reviewed on a regular basis to ensure currency. Recommendations for improvements or questions pertaining to the information contained in this staff instruction should be forwarded to the Special Flight Operations Inspector at: AARRD, 6th Floor, Place de Ville, Tower C, 330 Sparks Street, Ottawa, ON K1A 0N8
  4. Although this document is intended to be an accepted, consistent means to evaluate proposals for UAV flight operations, it does not purport to address all of the safety concerns.

1.2  Applicability

This document applies to Transport Canada Civil Aviation (TCCA) personnel and the aviation industry.

1.3  Description of Changes

Not Applicable.

2.0  REFERENCES AND REQUIREMENTS

2.1  Reference Documents

  1. Subsection 101.01(1) of the CARs defines unmanned air vehicle.

    1. “unmanned air vehicle" means a power-driven aircraft, other than a model aircraft, that is designed to fly without a human operator on board”.

      Information Note:
  2. Section 602.41 states that no person shall operate an unmanned air vehicle in flight except in accordance with the provisions of a special flight operations certificate or an air operator certificate.
  3. Section 623.65(d) specifies the standards that apply to the application for, and the operation of, an unmanned air vehicle.
  4. Section 603.66 of the CARs prohibits the flight operation of an unmanned air vehicle unless the provisions of a special flight operations certificate are complied with.

    Information Notes:
    Where it is found that operations are being conducted without SFOCs, detailed information shall be passed on to the Regional Enforcement branch for action (e.g. Detection Notice).

    Section 602.41 as a designated provision, has an individual penalty in the amount of $5,000.00 and a corporation penalty of $25,000.00.

  5. Section 603.67 states that an application is to be submitted in the form and manner required by the Special Flight Operations Standards. It also states that once the application is received and the applicant demonstrates the ability to conduct the flight operation in accordance with the Special Flight Operations Standards, the Minister shall issue the Special Flight Operations Certificate.

    Information Note:
    Article 8 of the Chicago Convention states that no aircraft capable of being flown without a pilot shall be flown without a pilot over the territory of a Contracting State without special authorization by that State. As a member state of ICAO, Canada undertakes to comply with the provisions of the Convention.

2.2  Cancelled Documents

Not applicable.

2.3  Terms and Definitions

  1. The following list will assist Inspectors and Certificate applicants to reach a common understanding of UAV-related terms and definitions.

    1. Automatic The execution of a pre-defined process or event that requires UAV pilot initiation and/or intervention e.g. automated take-off/landings, way-point navigation, auto-pilots, pre-programmed manoeuvres etc.
    2. Autonomy The ability to execute processes or missions using on-board decision making capabilities. No intervention by UAV crew members is required.

      Information Note:
    3. Beyond visual range Any distance at which sense and avoid cannot be performed through visual contact.

      Important Note:
      This is also referred to as beyond line-of-sight (BLOS).
    4. Canadian Aviation Documents (CAD) Any licence, permit, accreditation, certificate or other document issued by the Minister under Part I of the Aeronautics Act to or with respect to any person, or in respect of any aeronautical product, aerodrome, facility or service.

      Information Note:
      A Special Flight Operations Certificate is a CAD

    5. Communication links The mechanisms for command, control and information transmitted or received by the unmanned air vehicle.

      Information Note:
      Communication link is another term for “data link”.  Communication links are command, control and information links generated within or received by the UAV system.  They are the wireless means of connecting one location to another for the purpose of transmitting or receiving data.  UAV system communication links cover all communication, both within the system that may comprise of the control station, air vehicle, remote antenna(s), launcher(s), landing/recovery equipment and operational personnel and communication, to/from equipment and agencies external to the UAV system that require access to data, or control of, the UAV system and/or its associated sub-systems and payload(s).  Communication links can be made by one or more of a variety of means such as, but not limited to: audio, visual, video, radio frequency (RF), infrared (IR), ultra-violet (UV), microwave and fibre optic
      .
    6. Control station The equipment remote from the unmanned air vehicle from which its flight is controlled and/or monitored.

      Information Note:
      Control stations are also referred to as Ground Control Stations (GCS) or Vehicle Control Stations (VCS). They may have multi-vehicle and multi-operator capability. A single VCS and operator can control multiple vehicles. Alternately, several stations can be networked to shared vehicle and payload information and control. Operators at different workstations can split payload and vehicle control requirements, allowing one operator to interpret sensor information while another monitors vehicle functions and handles communications.
    7. Crew member In subsection 101.01(1) of the CARs, crew member is defined as “a person assigned to duty in an aircraft during flight time”.  In the case of an unmanned aircraft system, it means a person assigned to duty with respect to the operation of an unmanned air vehicle system during flight time.
    8. Flight termination Flight termination is a system, procedure or function that ends the flight of the aircraft.

      Information Note:
      This could range from automatic flight guidance systems that navigate the aircraft to a suitable location and completes a landing, to devices that bring the aircraft down immediately e.g. deployment of a parachute.  It could be a pre-programmed procedure triggered automatically or manually
      .
    9. Line of sight (LOS) A direct point-to-point contact between a transmitter and a receiver.

      Information Note:
      It is imperative for the Inspector and Certificate applicant to have a common understanding of the term “line of sight” as it relates to the proposed operation.  Visual line of sight (i.e. visual contact) is not to be confused with electronic line of sight.
    10. Observer A person assigned and trained to perform duties as a crew member
      associated with collision avoidance, 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.
    11. Payload The payload comprises of all elements of the air vehicle that are not necessary for flight but are carried for the purpose of fulfilling specific mission objectives. This may include such sub-systems as intelligence and surveillance assets, communication relay equipment, sensors, cargo and cameras.
    12. Payload Operator Person (s) trained to operate the payload system, and in some cases, manage the flight profile.
    13. Real-time A process or activity occurring in real-time if it responds within a specified time variant from an external source, typically a fraction of a second.
    14. Recovery The phase of a UAV flight that involves the return of an air vehicle to the ground or to base.
    15. Sense and avoid The ability to detect conflicting traffic or other object(s) and take the appropriate action to avoid collision.
    16. Synthetic Aperture Radar (SAR) Synthetic aperture radar systems take advantage of long-range propagation characteristics of radar signals and the complex information process capability of modern digital electronics to provide high-resolution imagery.

      Information Note:
      SAR complements photographic and other optical imaging capabilities because of the minimum constraints on time-of-day and atmospheric conditions and because of the unique responses of terrain and man-made objects to radar frequencies.
    17. Telemetry data Real-time, recorded or statistical parameters transmitted by the air vehicle to the control station to report the status, condition, position, behaviour and performance of the air vehicle, its subsystems and its payload(s).
    18. UAV Pilot A crew member actively exercising control of the UAV and/or monitoring the state and progress of the UAV, in an automatic or programmed flight mode, from the control station.

      Information Note:
      The UAV pilot is the person responsible for command and control of a UAV in flight. The UAV pilot may or may not be the UAV Payload Operator and may or may not be the Certificate holder. The intent is to distinguish between: the person who is actively exercising control of the UAV while in flight; the person who is in overall charge of, and responsible for, a particular UAV flight; the person or organization which operates the UAV and the person who operates the payload system and in some cases, manages the flight profile.
    19. Unmanned aircraft system The unmanned air vehicle(s), control station(s) and any other elements required for flight.
    20. Visual contact Unaided (other than corrective lenses) direct visual observation of the UAV by a crew member.
    21. Visual range The maximum distance at which sense and avoid can be performed by visual contact.

3.0  BACKGROUND

  1. The Canadian Aviation Regulations, Part VI, Subpart 3, Division IV – Miscellaneous Special Flight Operations contains the information that must be submitted to the Minister in order to obtain a Special Flight Operations Certificate for the operation of an unmanned air vehicle system.
  2. Regional Superintendents, General Aviation and Civil Aviation Safety Inspectors, General Aviation — Headquarters are delegated (Schedule C-9) the authority and responsibility to issue Special Flight Operations Certificates for the operation of unmanned air vehicle systems and to specify the conditions to be contained in the certificates.
  3. The successful operation of a UAV system requires adequate pre-planning by the operator. In consideration of the limited aviation background of many UAV manufacturers and operators, where they may have little or no knowledge of Transport Canada requirements and procedures, the processing of an application may be very demanding on an Inspector's time.
  4. Upon initial contact with a Certificate applicant, the Inspector should ensure that the applicant is:

    1. in possession of the Standards applicable to unmanned air vehicles, and if not, inform the operator of the procedures to obtain them,
    2. made aware of the type of information that must be submitted in an SFOC application (i.e. the applicant obtains a copy of this staff instruction)
    3. made aware of the requirement to submit the application a minimum of 20 working days prior to the date of the proposed operation.

4.0  GENERAL INFORMATION

4.1  Application

  1. Transport Canada is responsible for the conduct of civil UAVs. As stated in section 102.01 of the CARs, these regulations do not apply in respect of

    1. military aircraft of Her Majesty in right of Canada when they are being manoeuvred under the authority of the Minister of National Defence, or
    2. military aircraft of a country other than Canada, to the extent that the Minister of National Defence has exempted them from the application of these Regulations pursuant to subsection 5.9(2) of the Act (i.e. foreign military UAVs)
  2. In these cases, the operation of UAVs are not subject to the Canadian Aviation Regulations, but are subject to Military Flying Orders. Military operations being conducted in civil airspace require coordination with NAV CANADA and may require assistance from Transport Canada’s Aerodromes and Air Navigation branch. Where a UAV operator is a civil agency or person and the operation is being conducted in restricted military airspace, the operation will require a Special Flight Operations Certificate issued by Transport Canada, in cooperation with the Department of National Defence in the administration of that airspace.
  3. The staff instructions contained in this document apply to all civil applications to conduct unmanned air vehicle flight operations. In cross border operations, where the UAV pilot is in another state (e.g. control station is in the United States), the Certificate holder is still responsible for compliance with the regulations of the state in which the UAV is operating (i.e. Canada).

4.2  Interpretation

  1. UAVs may be used for experimental, demonstration, developmental or commercial purposes, including aerial surveying, agricultural and fisheries observation, communications relay, railway, pipeline and power line monitoring, minerals and oil surveying, mapping; government roles such as law enforcement, border patrol, fire fighting, disaster relief, traffic and crowd control; weather tracking and atmospheric observation; monitoring of dangerous substances including nuclear, biological and chemical emissions and scientific research (climate, ocean, environment and the earth), just to name a few. UAVs are aircraft that may be remotely controlled or may have automated flight capability. UAVs are systems, and the air vehicle is only a small part of the whole system. The broader system of UAVs consists of the air vehicle and payloads, communications architecture, and the command and control system (control station). Control stations take the place of flight decks and can be considered “remote cockpits”. While the aircraft may be unmanned, the system is not. When considering a request for operating approval, the system as a whole will be assessed including an assessment of the operating personnel.
  2. It is important to note that what is often considered a “model aircraft” by an operator is in fact an “unmanned air vehicle” by definition.  Subsection 101.01(1) of the CARs defines model aircraft as:

    1. “model aircraft”- means an aircraft, the total weight of which does not exceed 35 kg (77.2 pounds), that is mechanically driven or launched into flight for recreational purposes and that is not designed to carry persons or other living creatures.
  3. Confusion may exist because the unmanned air vehicle weighs less than 35 kg, however, this does not make it a “model aircraft”. To be considered a “model aircraft”, three conditions must be met. Every condition is necessary but none is sufficient. Model aircraft weigh 35 kg. (77.2 lbs) or less, are mechanically driven or launched into flight for recreational purposes, and are not designed to carry persons or other living creatures.
  4. While the CARs do not define “recreational purposes” a dictionary definition of recreation is “not for work – done for pleasure or relaxation”. Model aircraft enthusiasts fly their aircraft as a pastime, an unpaid diversion, as an activity that “diverts, amuses, or stimulates”. Section 602.45 of the CARs was put in place to allow sporting enthusiasts to operate model aircraft for personal enjoyment but not for monetary gain or other form of hire and reward. The Aeronautics Act defines hire and reward as:

    1. “any payment, consideration, gratuity or benefit, directly or indirectly charged, demanded, received or collected by any person for the use of an aircraft”.
    2. Equipping model aircraft with a payload does not, in itself, make the model a UAV, however, once the model aircraft is launched for any reason other than recreational purposes, it is an unmanned air vehicle.

4.3  Policy

  1. It is Transport Canada policy that UAVs operating in Canada must meet “equivalent” levels of safety as manned aircraft. UAV system operations must be as safe as manned aircraft insofar as they must not present a hazard to persons or property on the ground or in the air that is any greater than that attributable to the operation of manned aircraft of equivalent class or category. In general, UAVs should be operated in accordance with the rules governing the flight of manned aircraft and meet equipment requirements applicable to the class of airspace within which they intend to operate.
  2. At present, it is Transport Canada policy that Special Flight Operations Certificates, not Air Operator Certificates, be issued to persons wishing to operate civil UAVs in Canada. This staff instruction does not address all the safety issues associated with UAVs operating with passengers carried on board or UAVs operating inside buildings or underground.

4.4  Reference Material

Canadian Aviation Regulations - Part VI, Subpart 3, Division IV – Miscellaneous Special Flight Operations

4.5  Application Processes

Three application processes are identified in this staff instruction. The first applies to all UAV operations except those that fit into one of the other two categories. In general terms, the second process applies to UAVs that are remote-controlled with a MTOW under 35 Kg and operated within visual range (see specific eligibility requirements in Section 5). The third process applies to unmanned air vehicles that would otherwise be considered model aircraft except they are too heavy to meet the definition of model aircraft, and are operated recreationally by members of the Model Aeronautics Association of Canada (MAAC) or the Academy of Model Aeronautics (AMA) (see specific eligibility requirements in Section 6).

4.6  Liability Insurance

Certificate holders need to be aware very early in the application process that they must subscribe for adequate liability insurance covering risks of public liability as outlined in section 606.02 of the CARs. This requirement will be a condition in the SFOC.

Information Note:
The Model Aeronautics Association of Canada’s insurance only covers model aircraft used for recreational purposes (based on the definition of “model aircraft” in the Canadian Aviation Regulations).

4.7  Air Traffic Service Provider Coordination

Certificate holders also need to be made aware that they will need to contact the airspace service provider (i.e. NAV CANADA, DND or Serco) to coordinate airspace requirements. There may also be a need for them to contact Transport Canada’s Aerodromes and Air Navigation branch in the Region in the rare case of special circumstances where the airspace needs to be restricted.

Information Notes:
Certificate applicants should be aware that a request to operate their civil UAV in restricted military airspace or ranges must be forwarded to 1 Cdn Air Div / A3 UAV 2. 1 Cdn Air Division will inform the range whether the operation can be approved or what actions the applicant must take to gain approval, including ensuring that Transport Canada has issued an SFOC.

Additional information on air traffic service provider coordination may be found in paragraph (k).

4.8  Frequency Spectrum

The Radiocommunication Act regulates the use of radio frequency spectrum in Canada and requires that certain radiocommunication equipment or systems be licensed. UAVs are connected to the control station via communication links. The link types vary, related to the operation and the level of automation used by the UAV. Generally, a control data link and a payload link will exist. The bandwidth will vary highly depending on the data being transmitted. Protection of the data link, authenticity of the user and the correctness of data transfer and processing are all security matters for Industry Canada. Industry Canada is the lead department responsible for radio frequencies, spectrum and telecommunications issues. The Inspector shall remind the Certificate applicant of the requirement to contact Industry Canada regarding the assignment of radio frequencies, where they are required e.g. if the frequencies being used are not licence exempt, such as 900 MHz. Industry Canada Regional and District Office addresses and telephone numbers may be found at: http://www.strategis.ic.gc.ca/epic/internet/insmt-gst.nsf/en/sf01742e.html

Information Note:
Currently there is no protected spectrum allocated for civil UAVs. Civil aviation authorities around the world are attempting to bid for spectrum at the World Radio Conference in 2011.

4.9  Radiotelephone Certificates/Radio Licences

Inspectors shall remind Certificate applicants of the requirement under the Radio Act for a Radiotelephone Operations Restricted Certificate, and that it may take up to 30 days to obtain radio frequency clearances, and/or radio licences. Radio communication regulations may be found on the Internet at: http://laws-lois.justice.gc.ca/eng/regulations/SOR-96-484/page-19.html?term=frequency+radio

Information Note:
Communication links will be addressed in more detail in paragraph (k).

4.10  Risk Management

  1. Risk is the chance of injury or loss. Risk management introduces the idea that the likelihood of an event happening can be reduced, or its consequences minimized. Risk management is the process of:

    1. Identifying the Risks – What could go wrong? How could it happen?
    2. Assessing their Implications – What is the level of risk? What are the outcomes?
    3. Deciding on a Course of Action – What needs to be done to reduce/control the risk?
    4. Evaluating the Results – Did the risk reduction measure work?
  2. The Certificate applicant is expected to evaluate the risks associated with the proposed operation and indicate the associated risk mitigation measures in their application. Depending on the nature of the operation, consideration should be given to events such as:
  3. Degradation or loss of:

    1. command and control links
    2. telemetry data links
    3. communication links with ATC, with flight crew
    4. sense and avoid links
    5. payload links
    6. propulsion system
    7. control station power
    8. software system
    9. visual contact with aircraft when operating within visual range
  4. UAV encounters with:

    1. another aircraft
    2. varying weather conditions
    3. airframe and engine icing
  5. Aborted Take-off (launch)/ Landing (recovery)

    1. (a) aborted take-off or aborted landing of the air vehicle
  6. If the applicant wishes to use Transport Canada’s risk assessment forms, refer them to System Safety’s website at: http://www.tc.gc.ca/eng/civilaviation/standards/systemsafety-educational-packages-3189.htm

    Information Note:
    Certificate applicants proposing “see and avoid” strategies in lieu of visual observers, will need to be able to demonstrate in their risk assessment that injury to persons or property along the proposed flight path is extremely improbable.

5.0  REVIEWING AN APPLICATION

5.1  Application and Supporting Documentation

  1. Using the Canadian Aviation Regulations - Part VI, Subpart 3, Division IV – Miscellaneous Special Flight Operations, the standards found under 623.65(d) and this staff instruction as reference, the Inspector will review the application. The requirement for the application to be received at least 20 working days prior to the date of the proposed operation is intended to provide Transport Canada Inspectors with adequate time to review, in sufficient detail, an application and supporting documentation and to carry out any required co-ordination. However, should an application arrive at a Regional office less than 20 working days before the intended operation, if it can be processed accurately and completely without straining existing resources and work schedules, the service should be provided with a reminder to the client that 20 working days notice is the minimum timeframe outlined in the Standard.
  2. Initially, the Certificate applicant can expect the SFOC to be issued for each specific mission. A Certificate applicant will not be granted a long-term authority (i.e. one year), and/or an authority that is not site specific, without a history of demonstrating that the operations have been conducted in a safe manner. Once an initial application has been made and a Certificate has been issued, subsequent SFOC applications should be able to be expedited. For example, if the mission changes, but other parameters remain the same (same UAV system, same UAV pilot) then the focus in processing the next application will be placed on assessing the suitability of the area used for the operation. Where the operating environment and the mission requirements change, the set of safety requirements that the Minister will impose will change accordingly.
  3. Subparagraph 623.65(d)(3), as outlined below, indicates the information that must be submitted to Transport Canada in an application for an SFOC. Since the information required by 623.65(d)(3)(a)-(j) may not be sufficient for Transport Canada to determine whether the operator can conduct a safe operation, the Minister may also ask for any other information pertinent to the safe conduct of the operation, as referenced in 623.65(d)(3)(k).
  4. 623.65(d)(3) The following constitutes an application for a Special Flight Operations Certificate:

    1. (the name, address, and where applicable, the telephone number and facsimile number of the applicant;
    2. the name, address, and where applicable the telephone number and facsimile number of the person designated by the applicant to have operational control over the operation (Operation Manager);
    3. method by which the Operation Manager may be contacted directly during operation;
    4. the type and purpose of the operation;
    5. the dates, alternate dates and times of the proposed operation;
    6. a complete description, including all pertinent flight data on the aircraft to be flown;
    7. the security plan for the area(s) of operation and security plan for the area(s) to be overflown to ensure no hazard is created to persons or property on the surface;
    8. the emergency contingency plan to deal with any disaster resulting from the operation;
    9. the name, address, telephone and facsimile numbers of the person designated to be responsible for supervision of the operation area (Ground Supervisor), if different from the Operation Manager during the operation;
    10. a detailed plan describing how the operation shall be carried out. The plan shall include a clear, legible presentation of the area to be used during the operation. The presentation may be in the form of a scale diagram, aerial photograph or large scale topographical chart and must include at least the following information:

      1. the location and height above ground of all obstacles in the approach and departure path to the areas where the operation will be carried out;
      2. the exact boundaries of the area where the actual operation will be carried out;
      3. the altitudes and routes to be used while carrying out the operation;
    11. any other information pertinent to the safe conduct of the operation requested by the Minister.

      Information Notes:
      While all the information required by 623.65(d)(3) of the Standard must be evident in the application, it is not mandatory that the information be presented in the sequence as outlined in the Standard. In fact, the sequence of information has been changed for the purposes of this staff instruction in order to achieve a more logical flow to the information, although the paragraph lettering still begins at (a) and ends at (k).

      Inspectors may wish to remind Certificate applicants that they are not required to answer each and every question posed in this staff instruction, rather they should strive to submit a comprehensive application appropriate to the scope of the operation and complexity of the UAV system.
  5. 623.65(d)(3) The following constitutes an application for a Special Flight Operations Certificate:

    1. The name, address, and where applicable, the telephone number and facsimile number of the applicant.

      1. The Certificate applicant must provide their name, address, telephone and facsimile numbers, and any other pertinent contact information e.g. e-mail address.
      2. It is vital to establish who has legal custody and control of the unmanned air vehicle. The Special Flight Operations Certificate must be issued to the person or company that has complete responsibility for the operation and safety of the unmanned air vehicle flight operation and responsibility for compliance with the conditions contained in the SFOC. The Certificate holder may be in direct control of the UAV by remote control, co-located with the UAV pilot or monitoring the state and progress of the UAV in the control station, but in all cases, the Certificate holder must be the person or company who has legal custody and control of the aircraft.
    2. It is essential that the Certificate holder is aware of the responsibility to ensure that the UAV operation is conducted in such a way that the safety of persons and property on the ground and other airspace users is not jeopardized. It could be said that the Certificate holder assumes the same operational and safety responsibilities as the owner of a manned aircraft.
    3. Subsection 101.01(1) of the CARs definitions:

      1. “owner" - in respect of an aircraft, means the person who has legal custody and control of the aircraft.
      2. “operator" - in respect of an aircraft, means the person that has possession of the aircraft as owner, lessee or otherwise.
    4. The type and purpose of the operation.
    5. The Certificate applicant must provide a description of the intended role(s) / mission(s) / task(s) / usage of the air vehicle, including whether the proposed operation is being conducted within visual range or beyond visual range.
    6. The dates, alternate dates and times of the proposed operation.
    7. The Certificate applicant must provide the dates, alternate dates and times of the proposed operation.

      Information Note:
      The Certificate applicant should work with the Inspector to determine an appropriate validity period for the operation, taking into account potential mission delays for inclement weather etc. An SFOC with a few extra days validity period is preferable to issuing a second SFOC because the Certificate holder could not complete the operation within the designated validity period.

    8. A complete description, including all pertinent flight data on the aircraft to be flown.

      1. The Certificate applicant must provide a complete description of the unmanned air vehicle system, including all the pertinent flight data.
      2. Three-view drawings or photographs of the air vehicle are desirable.
      Information Notes:
      A UAV system consists of three main components: The air vehicle(s), the control station(s), and the communication links that connect the components. Communication links used by UAV systems can be segmented into command and control, relay of ATC communications, sense and avoid and payload (sensors, cameras etc.). Each segment may have specific spectrum requirements including satellite and terrestrial ones.

      UAVs can range in size from micro UAVs with six inch wing spans weighing 11 oz. to high altitude long range endurance UAVs with over 100 foot wingspans weighing 25,000 pounds. The amount of information that needs to be submitted will vary depending on the complexity of the system and the type of operation and/or the operating environment.

      The following list may be used to guide Inspectors to ensure that the description of the system is complete. See paragraph (k) for additional details on system maintenance and airworthiness.

5.2  Air Vehicle Description

  1. Who is the UAV manufacturer?

    1. General description of the air vehicle, including

      1. Category — e.g. aeroplane, vertical take-off and landing (VTOL), airship
      2. Composition — e.g. graphite, composites
      3. Landing gear — e.g. retractable, tricycle, floats
      4. Measurements — e.g. wingspan, fuselage length, body diameter, rotor diameter
      5. Weight — e.g. payload weight, maximum gross take-off weight, empty weight
      6. Type of propulsion system (make and model) — e.g. battery powered electric propulsion, turboprop, turbofan; rear or forward mount
      7. Fuel / Oil system — e.g. types, capacity, number of tanks
      8. Electric propulsion system — e.g. power output, separate electrical source
      9. Method of take-off/ launch — e.g. taxi and take-off, pneumatic catapult, rocket assisted, hand-launched (with bungee cord), launched from a roof rack that can be fitted to a ground vehicle, airborne launched from a larger aircraft
      10. Method of landing / recovery — e.g. approach and runway landing, glide to a predetermined area, parachute or parasail deployment, belly/skid landing (where aircraft has no undercarriage), skyhook snag, controlled crash such as a deep stall manoeuver that lands the air vehicle safely on a small inflatable cushion (airbag), arrester cable
      11. Navigation system — how does the air vehicle determine its position and how does it navigate? How does it respond to air traffic control directions?
      12. Flight sensors — e.g. altitude determination based on the barometric system
      13. Redundant systems mdash; — e.g. fight controls, avionics
      14. Visual detectability — e.g. high visibility paint scheme
      Information Note:
      Some UAVs are small and hard to see visually, while others, even if larger, are made of composite materials that make them hard to detect by primary radar. Visual detectability has to do with many parameters such as size, colour, lighting conditions, glare, backgrounds, clarity of the air and the light reflection characteristics of the aircraft. For example, a closing C152 can be seen by the human eye, assuming a 30 degree field of view, at about 1 nautical mile (nm) under the best conditions, an F-16 fighter at 1.6 nm and an airliner at 2 nm miles. Many small UAVs can only be seen visually at about 600 to 1000 ft. AGL.
    2. Equipment:

      1. Autopilot
      2. Ballistic parachute system
      3. System to detect icing — e.g. airframe icing sensors
      4. Anti-icing system
      5. Position, anti-collision and landing lights
      6. Automatically activated fail-safe flight termination system in the event of a critical system failure or loss of communications link
      7. Ground support equipment used in the operation — e.g. catapults, pneumatic/hydraulic launch systems, starters, generators
      8. Pertinent flight data on the aircraft to be flown

        1. Performance — e.g. operating speeds, climb and descent rates, maximum altitude, maximum range, maximum endurance
        2. Operating Limitations — e.g. winds (wind shear, gusts), cross-winds, temperatures, day, night, icing
        3. History of operating similar aircraft systems — e.g. number of flights, number of flight hours

5.3  Control Station Description

  1. In its simplest form, a UAV control station consists of a hand held transmitter incorporating basic flight controls and rudimentary displays similar to those of a model aircraft. More sophisticated control stations may include controls and displays for aircraft attitude and performance, propulsion, navigation, aircraft systems and sensor operation as well flight system and voice recording equipment.

    1. Control method — e.g. pre-programmed
    2. Does the control station manage launch/ take-off and landing/recovery?
    3. How does the pilot provide input to the control surfaces — e.g. stick and rudder pedals?
    4. Instrumentation in the control station — e.g. is the UAV system capable of displaying to the pilot accurate air vehicle system and attitude information necessary for safe operation, control and navigation e.g. battery voltage indicator?
    5. Does the control station include automatic diagnostic and monitoring capability for the status of the UAV system?
    6. What visual warning or alarm information is provided to the pilot e.g. low fuel, low battery, critical systems failure?
    7. What indications are provided to the pilot concerning the existence of icing?
    8. Redundant systems — e.g. back-up computer displays, generators
    9. How is the control station powered?
    10. Equipment in the control station — e.g. lights for night operations, fire fighting equipment
    11. Is the control station secure — e.g. capable of being locked?

5.4  Communication Links Description

  1. Control and Control



    1. Control/data frequencies
    2. Line of sight or beyond — e.g. VHF band, Ku-Band, UHF SATCOM, Geostationary (GSO) satellites
    3. What is the range of the line-of-sight control links?
    4. Fault indications to indicate lost links - e.g. “off flags”
    5. Measures for preventing or mitigating radio frequency interference – e.g. will a spectrum analysis be conducted?
    6. Single or dual redundant control links
  • ATC Communications
    1. Although the UAV pilot is not onboard the aircraft, air traffic control communications (digitized voice or data) between the air traffic controller and the UAV pilot is still required. This information flow may be accomplished by relaying the voice, data, or voice and data from the radio in the air vehicle to the remote pilot in the control station and back. Additionally, it may be feasible for direct radio communication from ATC to the control station via line-of-sight radio or satcom, or terrestrial wired networking from ATC to the control station.

      1. Method of communicating with ATC – e.g. radio relay on board the air vehicle, transmitter not on board the air vehicle
      2. Are there communications delay time frames – e.g. is the system able to perform ATC directed actions without undue delay or will there be a number of seconds delay?
      3. Method of communicating with other airspace users – e.g. how does the pilot report positions at non-tower aerodromes?
      4. Independent means of backup communication between the control station and the ATC agency
      5. What type of communication system is used for the pilots, ground support personnel and observers to communicate with each other?
  • Sense and Avoid Systems



    1. System for detecting/avoiding other airborne objects and ground related obstacles – e.g. Traffic Collision Avoidance System (TCAS), optical infrared, an Automatic Dependant Surveillance- Broadcast system (ADS-B), cameras
    2. Transponder - Mode C. Mode S.
    3. Other sense and avoid systems – e.g. radar, developmental system
    Information Notes:
    ADS-B is a relatively new GPS-based traffic management tool, but like TCAS, it is limited in use since it only sees aircraft that are similarly equipped to display ADS-B information.


    Visual observers providing detect, sense and avoid functions are addressed in paragraph (k).
  • 5.5  Payload

    1. In addition to the communication links, some UAVs need additional links for the operation of a payload.

      1. What is the payload - e.g. daylight colour video camera infrared sensor (IR sensors), electro-optical
        infrared cameras (EO-IR), synthetic aperture radar (SAR)?
      2. Nature of payload – e.g. to provide real-time day video imagery of terrain being overflown, to determine real-time meteorological conditions
      3. Payload limitations – e.g. what if the UAV pilot and Payload operator require different operational limits, such as altitudes? What measures are in place to address these potential conflicts?
      4. How is the payload secured to the air vehicle?
      5. Are the payloads pyrotechnic or explosive devices?
      6. Does the payload have a secondary purpose that could affect the control of the air vehicle?
      7. Does the operation of the payload impact the workload of the pilot?
    2. The name, address, and where applicable the telephone number and facsimile number of the person designated by the applicant to have operational control over the operation (Operation Manager).
    3. The Certificate applicant must provide the name, address, telephone and facsimile numbers of the person designated to have operational control over the operation.
    4. It is expected that the SFOC application will also describe how/why the person is qualified to act as the Operation Manager.

      Information Note:
      It is not the intent of this staff instruction to confine a Certificate holder to a mandatory management structure, including position titles. A Certificate holder may or may not use position titles such as “Operation Manager” and “Ground Supervisor” within their organization, however someone must have operational control over the operation and someone must be responsible for supervision of the operation area. It must be clearly indicated in the application who has been designated these responsibilities. In small operations, the Operation Manager and the Ground Supervisor could be the same person.
    5. The Operation Manager is the person designated to assume responsibility for the operational control of the UAV flight operation. The Operation Manager is typically thought of as the person who exercises command of all crew and personnel during UAV operations, including planning and communications. While the standards do not outline what duties have to be assumed by an Operation Manager, they might include:

      1. making application to the appropriate Transport Canada Regional General Aviation office with sufficient advance notice to complete the administrative and coordination duties required to prepare the Special Flight Operations Certificate;
      2. establishing liaison with airport management, property owners, local agencies;
      3. liaising, where applicable, with local aircraft operators to make them aware of the operation;
      4. where applicable, coordinating with military air traffic services; coordinating with NAV CANADA with regard to the publication of a Notice to Airmen (NOTAM) etc.;
      5. ensuring emergency procedures are developed in concurrence with, and approved by, the delegated agency appropriate to the site of the operation - e.g. at an airport the airport authority; over water this could be Coast Guard, Harbour Authority or other local authorities;
      6. providing a sufficient number of capable and informed persons to handle the operation with efficiency and safety;
      7. ensuring all persons connected with the operation are properly informed of their duties and are familiar with the contents of the authorization;
      8. making the decision to cancel or postpone the operation in the event of bad weather, or any other circumstances in accordance with the conditions of the authorization;
      9. During the operation, the Operation Manager, or their delegate, might

        1. ensure compliance of company standard operating procedures (SOPs);
        2. terminate the operation if it is being conducted in an unsafe manner;
        3. communicate with Air Traffic Control;
        4. communicate with the Ground Supervisor;
        5. broadcast to aircraft in the area of operation.
    6. Method by which the Operation Manager may be contacted directly during the operation.

      1. The Certificate applicant must describe the method by which the Operation Manager will be contacted directly during the operation.

        Information Note:
        It is not mandatory that the Operation Manager be on-site during the flight operations, however, a means of contacting the responsible person on-site (e.g. Ground Supervisor) must be provided.
    7. The name, address, telephone and facsimile numbers of the person designated to be responsible for supervision of the operation area (Ground Supervisor), if different from the Operation Manager during the operation.

      1. The Certificate applicant must provide the name, address, telephone and facsimile numbers of the person designated to be responsible for supervision of the operation area.
      2. It is expected that the Certificate applicant will also describe how/why the person is qualified to act as the Ground Supervisor.
      3. Ground Supervisor responsibilities might include:

        1. crowd control where spectators would be viewing an operation - e.g. ensure crowd remains separated from the control station at distances as specified in authorization as well as take-off and landing distances and ground manoeuvring of UAV;
        2. ensuring minimum safety distances are met in terms of occupied buildings, vehicles etc.;
        3. communicating with the Operation Manager during the operation - e.g. portable radio, cell phone;
        4. arranging for the use of special radio frequencies as required;
        5. keeping watch for other airspace users;
        6. ensuring security of the site.
    8. A detailed plan describing how the operation shall be carried out. The plan shall include a clear, legible presentation of the area to be used during the operation.

      1. The presentation may be in the form of a scale diagram, aerial photograph or large scale topographical chart and must include at least the following information:

        1. the altitudes and routes to be used on the approach and departure to and from the area where the operation will be carried out;
        2. the location and height above ground of all obstacles in the approach and departure path to the areas where the operation will be carried out;
        3. the exact boundaries of the area where the actual operation will be carried out;
        4. the altitudes and routes to be used while carrying out the operation.
      2. The Certificate applicant must provide a detailed plan describing how the operation shall be carried out.
      3. A description of the classification of airspace in which the flight is planned is also required. See paragraph (k) for additional airspace considerations.

        Information Note:
        Overhead imagery is acceptable in addition to aerial photographs and/or large-scale topographical charts.
    9. The security plan for the area(s) of operation and security plan for the area(s) to be overflown to ensure no hazard is created to persons or property on the surface.

      1. The Certificate applicant must describe the security plan for the area(s) of operation and for the areas to be overflown.

        Information Note:
        Security plan in this paragraph pertains to safety and security for persons and property on the ground. System security (e.g. unlawful interference) is addressed in paragraph (k).


        1. What safe altitudes and distances are proposed for the operation – e.g. from members of the public, structures, vehicles, vessels etc.?
        2. Are spectators isolated from the UAV during take-off, recovery and during the flight operation? - e.g. fences, barriers
        3. How will the Certificate applicant ensure that adequate separation between the spectators (or persons not associated with the operation) and the UAV is maintained during the flight operation?
        4. Is it necessary to notify property owners and determine that they have no objections?
        5. Is it necessary to notify airport/aerodrome authorities and determine that they have no objections?
        6. Will the UAV be operating in places where it will be necessary for any other people to be made aware of the proposed operation to ensure that they have no objections?
        7. Will the UAV be operating in areas where the public will have to be removed from areas affected by the operation?
        8. Are access routes available for emergency vehicles?
    10. The emergency contingency plan to deal with any disaster resulting from the operation.

      1. The Certificate applicant must describe the emergency contingency plan.
      2. It is expected that the Certificate applicant will:

        1. have an emergency plan in place describing the personnel and equipment available to respond to anticipated emergencies, including incidents and accidents, or a medical emergency involving a spectator in the case where potential clients (or whomever) have been invited to watch the aerial demonstration;
        2. communicate the plan, where applicable to the property owner, airport/aerodrome manager or air traffic service provider; and
        3. have the equipment and personnel described in the emergency plan in place during flight operations.
        Information Note:
        It is not Transport Canada's responsibility to determine minimum requirements or standards for emergency equipment and procedures nor do Inspectors have the necessary expertise to assess the effectiveness or efficiency of a proposed emergency plan.
      3. Airports have emergency plans and procedures in place. A Certificate holder must coordinate with the airport manager or authority. Generally speaking, UAVs operations that require the UAV to depart, operate or land at an airport would adopt the emergency plans and procedures in place at the airport. In the event that the UAV mission requires inviting members of the public, the Certificate applicant should be made aware that the airport manager/authority and provincial or local governments set the requirements for medical facilities and personnel at public gatherings. There may be a need to contact local police depending on the size of the gathering.
      4. When reviewing an application for an operation that is departing, landing or operating at a small airport or at an off-airport site, the emergency contingency plan submitted should be reviewed for obvious omissions - e.g. no first-aid or fire equipment on site. Deficiencies should be brought to the attention of the Certificate applicant.
      5. At minimum, it is expected that the Certificate applicant would:

        1. Be aware of what emergency response service is available in the area of operation.
        2. Where warranted, establish advance contact with the applicable emergency agencies and authorities.
        3. Know how to access emergency services and have the means to do so - e.g. cell phone, sat phone.
        4. Ensure that all persons associated with the operation who may be required to respond to an emergency situation are briefed in advance of the operation.
        5. Have in place operational control measures necessary to ensure the safety and orderly conduct of persons attending the flight demonstration.
        6. In the event of an aircraft emergency, establish that there is no immediate risk to life, then implement procedures for flight termination - i.e. transit the UAV to a safe recovery area.
    11. Any other information pertinent to the safe conduct of the operation requested by the Minister.

      1. Initial applications may not contain all the relevant information that is needed for an Inspector to issue the Special Flight Operations Certificate.
    12. Organization

      1. The Certificate applicant must indicate that they have, and can maintain, an adequate management organization that is capable of exercising supervision and operational control over persons participating in the UAV system operations.
      2. It is important that the Certificate applicant be made aware that it is their responsibility to ensure that the operation is managed and conducted in such a way that the safety of persons and property on the ground and other airspace users is not jeopardized.

      Information Note:
      The management of a UAV system operation will vary according to the scope and complexity of the mission -e.g. a small UAV operating within visual range in a remote area may not require the support of a large number of persons, rather the expertise in a variety of areas could come from one or two key personnel.
    13. Personnel Qualifications

      1. The Certificate applicant must describe the qualifications of the UAV pilot(s) observer(s) and UAV system maintainer(s) in sufficient detail to show that the personnel have been adequately trained and are qualified to fulfill their duties. Where there is intent for the UAV pilot to perform concurrent duties e.g. the UAV pilot is the payload operator or the UAV pilot is the visual observer or the UAV pilot is controlling more than one UAV at the same time, the Certificate applicant will have to demonstrate that the safety of the UAV flight is not jeopardized by virtue of these multiple duties.
      2. While there are no presently no standards governing the minimum qualifications required to maintain or operate a UAV in Canada, Inspectors need to be satisfied that personnel are adequately trained, qualified, proficient and current to operate the UAV in the operating environment.
      Information Notes:
      When reviewing pilot qualifications, it is important to note that UAV pilots who only have experience flying from an exocentric perspective (observing the UAV from a position aside the flight path) may not have well developed situational awareness capabilities. Conversely, UAV pilots who only have experience from a vehicle-centric perspective (i.e. flying manned aircraft) may have difficulty transitioning to flying from an exocentric perspective.

      The operation of some UAVs, particularly large complex UAVs, may require the involvement of a considerable number of personnel, such as operators of launch systems, arresting hooks, payload operators and mission planners.
    14. UAV Pilot

      Information Note:
      The Aeronautics Act states: "pilot-in-command" means, in relation to an aircraft, the pilot having responsibility and authority for the operation and safety of the aircraft during flight time. This responsibility and authority applies even though the pilot is external to the aircraft. The use of the term “pilot” in this staff instruction, however, is not intended to suggest that the pilot is necessarily qualified as a crew member of a manned aircraft.


      1. The following list may be used to guide Inspectors in establishing that the knowledge, experience, training and skill for all personnel conducting UAV flight operations is appropriate to the UAV system for all locations and airspaces within which the UAV will be operated. The UAV pilot must be able to control the UAV throughout its design parameters and potential operating conditions, including dealing correctly with emergencies and system malfunctions.

        1. General

          1. Hold or have held a Pilot Permit or Licence or military equivalent. Ratings held. Are the licence (and ratings) relevant to the UAV being flown and the type of operating environment - e.g. if the UAV is an aeroplane, does the UAV pilot hold an aeroplane pilot licence? If the aircraft is being operated IFR, does the UAV pilot have an IFR rating?
          2. Hold or held an ATC licence
          3. Hold a radiotelephony licence
          4. Expected to comply with company/organization SOPs - e.g. use of checklists, aircraft checks, crew co-coordination, emergency drills, flight time and flight duty time limitations and minimum rest periods
        2. Knowledge

          1. Completed pilot ground school instruction
          2. Written and passed Transport Canada aviation theory exams
          3. Knowledge of air traffic control rules and procedures, communications, radiotelephony
          4. Knowledge of aviation law, meteorology, navigation, airmanship, flight planning
          5. Knowledge specific to the UAV system
        3. Experience

          1. Experience operating manned aircraft
          2. Experience operating model aircraft
          3. Experience on specific UAV type
          4. Total experience flying UAVs
        4. Training

          1. System-specific training on UAV type, including handling all critical emergencies - e.g. engine failure, generator failure, engine over-heating, control station failure, smoke and fire in the control station
          2. UAV system manufacturer’s training
          3. Company/organization ops training
          4. Crew resource management training
          5. Other relevant training courses
        5. Skill

          1. Means by which competency has been demonstrated in the ability to perform normal and emergency procedures appropriate to specific type of UAV - e.g. flight test
        6. Currency

          1. How is currency maintained?
          Information Notes:
          The amount of interaction between the UAV pilot and the unmanned air vehicle ranges across a broad spectrum from a direct control-type system to a fully automated vehicle. In the case of some UAVs, the pilot has no direct control over pitch, bank or power settings. The pilot tells the air vehicle the performance that is desired and the air vehicle’s onboard computer translates that into control inputs. The performance of the air vehicle is relayed back to the UAV pilot through the human computer interface in the control station. With other UAVs, UAV pilot intervention is required to control the air vehicle. The pilot manually controls the flight surfaces of the air vehicle during take-off and landing. With other UAVs, rudder pedals, throttle and joystick are all housed in the control station.

          The psychomotor (eye-hand-foot coordination) skills and cognitive skills required to fly UAVs vary drastically from air vehicle to air vehicle. It is not fair to assume that because one UAV is larger and more complex than another UAV that the workload for the UAV pilot is proportional. Mental work overload may cause loss of situational awareness but not cause loss of control, which may not necessarily be the case with a small UAV.

        7. Observers

          1. Observers are crew members. For within visual range operations, except in rare cases, an observer(s) will be required to perform the detect, sense and avoid function. Observers will be required to maintain visual contact with the UAV at all times while scanning the immediate environment for potential conflicting traffic. Observers will maintain constant communication with the UAV pilot in order to provide instructions on required manoeuvering to steer clear of other aircraft where a potential for conflict exists.
          2. Inspectors will need to be satisfied that observers are adequately trained to perform their duties. The following list may be used to guide Inspectors:

            1. Expected to comply with company/organization established and maintained SOPs
            2. Expected to comply with company/organization established flight time and flight duty time limitations and minimum rest periods
            3. Hold or have held a Pilot Permit or Licence or military equivalent
            4. Hold or have held an ATC Licence
            5. Hold a radiotelephony licence
            6. Understand proper communications and phraseology
            7. Written and passed Transport Canada aviation theory exams
            8. Knowledge of air traffic control rules and procedures - e.g. right of way rules
            9. Knowledge of aviation law, meteorology, navigation, airmanship, flight planning
            10. Experience as an observer
            11. Understand proper visual scan techniques
            12. Company/organization ops training
            13. Crew resource management training
            14. Means by which competency has been demonstrated
            15. Other relevant training courses
        Information Note:
        In the majority of cases, visual observers will be surface-based, however, there may be occasional cases where the observer is onboard a dedicated chase aircraft. In this case, the SFOC will have to contain conditions regarding chase aircraft operations. In this case, Inspectors will need to consider:

        What distance the chase aircraft will need to remain from the UAV in order to ensure collision avoidance should a UAV malfunction occur.

        What distance the chase aircraft will need to remain from the UAV in order to provide visual detection of conflicting aircraft in the path of the UAV.

        Where the UAV pilot is operating the UAV from onboard the chase aircraft, how the Certificate applicant will ensure that the chase aircraft remains within radio control range of the UAV to maintain appropriate signal coverage for flight control or activation of the flight termination system.

        Communication requirements that will be necessary for the chase aircraft - i.e. with the appropriate ATC facility.

        Weather limitations, including flight visibility for chase operations.

        Duties of the chase aircraft pilots - i.e. they must not concurrently perform either observer or UAV pilot duties along with chase pilot duties.

        Section 602.24 of the CARs regarding formation flight requirements.
        1. Payload Operator

          1. Where the pilot has a dual role (e.g. the UAV pilot is also the payload operator), the Certificate applicant will need to address any risks associated with the same person performing two functions.

            1. The Inspector will need to determine if the UAV pilot is performing additional functions. For example,
            2. Does the payload have a secondary purpose that could affect the control of the air vehicle?
            3. Does the operation of the payload impact the workload of the UAV pilot?
        2. System Maintainer

          1. The Certificate applicant will need to provide a description the maintainer(s) qualifications.
          2. While there are presently no standards governing the minimum qualifications required to maintain a UAV system, Inspectors need to be satisfied that the UAV system is being maintained, including both the air and ground components of the system (e.g. engines, air vehicles, communication links etc.) in a fit for flight condition. The following list may be used to guide Inspectors:

            1. Aviation maintenance experience. Specialty.
            2. Hold or held an AME licence. Ratings held.
            3. Written and passed regulatory examination.
            4. Experience on the UAV type.
            5. Experience with control station maintenance. System-specific.
            6. Is software maintenance required, and if so, who is doing it and what is their experience?
            7. Are different individuals maintaining hardware, software, and firmware?
            8. Other relevant experience - e.g. aerospace, other autonomous vehicles, robotics. Does the person performing the maintenance hold professional qualifications in these other area?
            9. Does the system maintainer maintain a logbook
        3. UAV System

          1. The Certificate applicant must provide a description of both the normal and emergency procedures.
        4. Normal UAV Operations

          1. Manuals

            1. Is there a UAV system flight manual?
            2. Are there SOPs outlining how crew members are expected to carry out their duties including, but not limited to:
            3. Pre-flight inspections
            4. Use of checklists
            5. Crew coordination
            6. Take-off /launch and landing/recovery procedures
            7. Emergency drills - e.g. loss of control communication links, abort procedures following critical system failure
            8. Is there a Company Flight Operations Manual?
            9. Are there UAV pilot training manuals that specify required qualifications, levels of training, proficiency and recurrency for flight crew?
            10. Does the UAV pilot maintain a logbook?
          2. Pre-flight Planning

            1. ATC coordination procedures – e.g. NOTAMS, flight plan, transponder codes
            2. Weather briefing – e.g. to ensure compliance with SFOC, ensure compliance with UAV system flight manual
            3. Has the amount of fuel/energy planned for the flight also taken into account emergency contingencies such as weather hazards (cloud layers, icing, turbulence) and the “lost link route of flight” at prescribed altitudes?
            4. Has the mission plan been executed in simulation?
          3. Pre-flight/Taxi Operations

            1. Does the crew use checklists?
            2. How is it determined that the area is clear for taxi in order to avoid taxi-way incursions?
          4. Take-off/launch

            1. Unique procedures – e.g. how and when is manual control switched over to automatic control?
          5. In-Flight

            1. How does the pilot confirm that they are in control of the UAV?
            2. How does the UAV pilot confirm that they are staying within the altitude and distance limitations?
            3. How does the UAV determine where it is?
            4. How does the UAV navigate to its intended destination?
            5. Does the UAV intend to operate into known icing conditions?
            6. Will the aircraft perform aerobatic manoeuvres?
            Information Note:
            Subsection 101.01(1) of the CARs defines "aerobatic manoeuvre" as a manoeuvre where a change in the attitude of an aircraft results in a bank angle greater than 60 degrees, an abnormal attitude or an abnormal acceleration not incidental to normal flying.
          6. Landing/Recovery

            1. Unique procedures – e.g. is the UAV landed automatically?
          7. Post Flight

            1. Is there a post flight inspection of the UAV?
        5. Abnormal Events and Emergency Procedures

          1. The Inspector needs to determine, in the event of a malfunction, failure or other in-flight emergency, how the UAV is going to safely land without creating a hazard to other airspace users or persons or property on the ground. The following questions will guide the Inspector:
          2. Take-off/launch

            1. What are the procedures if an aborted take-off/launch becomes necessary?
          3. In-Flight

            1. What will happen in the event:

              1. propulsion system degradation due to malfunctions - e.g. electrical systems, navigation systems, flight control and management systems, software systems
              2. the engine quits – i.e. can the pilot restart the engine in flight?
              3. “fuel” starvation or fuel contamination
              4. loss of battery voltage
              5. loss of control surface performance - e.g. autopilot failure
              6. loss of heading
              7. loss of altitude
              8. loss of command and control links (uplinks) - e.g. does the UAV pilot have a pre-programmed loss-of-link flight profile including termination actions should the control link not be re-established?
              9. loss of status links (downlinks)
              10. an interfering signal is detected
              11. the flight extends beyond communications range
              12. an ATC communications failure – e.g. does the UAV pilot have a direct telephone number with ATC for contingency use should radio communications fail?
              13. visual contact is lost
              14. the UAV encounters severe weather that is outside its limits or the conditions of the Certificate
              15. an electronics failure
              16. the UAV encounters icing (airframe/engine) - e.g. altitude change
              17. there is a loss of primary and/or secondary power in the control station
              18. abrupt encounter with another aircraft
          4. If flight is automated, how does the UAV pilot override the programming if the UAV is behaving erratically? How reliable, fast and easy is this for the pilot to do? Does the UAV transit to a pre-designated recovery area, followed by an automatic recovery or does it transit to a pre-designated recovery area followed by activation of a flight termination system?
          5. Landing/Recovery

            1. What are the abort procedures for a “botched” landing/recovery?
            2. Can a crash start a fire?
            3. Are there company/organization procedures for notifying first responders after crashes involving hazardous materials – e.g. composite aircraft fires, unactivated ballistic parachutes?
          6. Post Flight

            1. Special maintenance/inspection after abnormal events
            Information Note:
            The Certificate holder should be aware of the legislation regarding reportable aviation incidents and accidents.
        6. UAV System Maintenance

          1. The Certificate applicant must describe how the UAV system is being maintained.
          2. While there are presently no standards governing minimum UAV system maintenance requirements, Inspectors need to be satisfied that the UAV system is being maintained, including both the air and ground components of the system (e.g. engines, air vehicles, communication links etc.) in a fit for flight condition.
          3. How is the UAV system maintained – e.g. is there a maintenance and inspection plan/schedule?
          4. Are check sheets used – e.g. issued by the manufacturer?
          5. Who established the maintenance schedule - e.g. UAV manufacturer?
          6. Are different individuals maintaining hardware, software, and firmware?
          7. Are maintenance records being kept?
          8. Are there maintenance and inspection manuals?
          9. What maintenance records are being kept – e.g. air vehicle, components?
          10. Where type-certified engines are used, are ADs kept up to date?
          11. Are there system-specific maintenance activities – e.g. pneumatic launcher?
          12. How are updates to system software implemented?
        7. UAV System Airworthiness

          1. The Certificate applicant must describe how they have determined that the air vehicle and the system are in a fit and safe state for flight - i.e. airworthy.

            Information Note:
            At present, Transport Canada does not define the matters to be taken into account for the design of UAVs and associated systems. Use of the term “airworthy” in this document means” in a fit and safe state for flight” but it does not mean “in conformity to a type design”.
          2. The following questions may help Inspectors satisfy themselves that the overall condition of the UAV system is conducive to safe operations:

            1. Operational history - how many crashes and failures have occurred? What corrective action has been taken to ensure that the failures do not occur again?
            2. How has the Certificate applicant determined that both the air vehicle and the system are airworthy?
            3. Has an authorization for flight been issued by any other civilian authority or Military authority?
            4. How is the UAV system designed to minimize the potential for failure of any component to prevent continued safe flight and recovery of the UAV?
            5. Are there sufficient abnormality/failure cueing features regarding engine and flight performance instrumentation provided to the UAV pilot?
            6. Does the air vehicle design facilitate control of the UAV by the UAV pilot and provide clear indications of UAV flight status?
            7. Have load or stress analysis been performed that demonstrate positive structural margins of safety during flight?
            8. Does the autopilot employ input parameters to keep the air vehicle within structural limits?
            9. What are the potential sources of RF interference and are there adequate protections from these hazards?
            10. Does the UAV system incorporate a fail-safe flight termination system or automatic recovery system?
            11. What flight critical components are software controlled? Have software safety analyses been performed?
            12. Is software effective and efficient?
            13. Is there a redundancy of flight critical components? If yes, which systems?
            14. Is there a back-up command transmitter and receiver?
            15. Spare part considerations
        8. Weather Limitations

          1. The Certificate applicant must specify in the application the minimum weather conditions appropriate to the operation. The Certificate applicant must have a system in place to monitor and assess the weather in order to comply with the applicable weather minima. This would include actual and forecasted weather along the flight path, and where applicable, the weather along the pre-programmed “lost link route” of flight.

            Information Note:
            As a default, the weather specifications in Part VI, Subpart 2 of the CARs will be applied unless the Certificate applicant is able to provide satisfactory rationale for applying lower limits.
          2. It may be important to distinguish between the types of visibility that the Certificate holder will have to abide by. In some cases there may be a need to establish a condition that is based on visibility at a specific aerodrome.

            1. Ground visibility is defined in subsection 101.01(1) as – “in respect of an aerodrome, means the visibility at that aerodrome as contained in a weather observation reported by

              1. an air traffic control unit,
              2. a flight service station,
              3. a community aerodrome radio station,
              4. an AWOS used by the Department of Transport, the Department of National Defence or the Atmospheric Environment Service for the purpose of making aviation weather observations, or
              5. a radio station that is ground-based and operated by an air operator.”
            2. Flight visibility is defined in subsection 101.01(1) as – “means the visibility forward from the cockpit of an aircraft in flight”.
        9. General Operating &Flight Rules

          1. In general, UAVs should be operated in accordance with the rules governing the flights of manned aircraft.
          2. It is policy to include a condition in the SFOC that states that the unmanned air vehicle shall give way to manned aircraft, however, this may not be practical in all cases, so the Inspector will have to make a determination if this condition is appropriate to the operation. The size, shape and manoeuverability of the UAV will have to be taken into consideration - i.e. the UAV could look and perform like a fixed wing aircraft, a rotary wing aircraft or an airship. While the general rule is that the most manoeuverable aircraft must give way, the “sense and avoid’ response time of the UAV must be taken into consideration when developing SFOC operating conditions.
        10. Air Traffic Service Provider Coordination

          1. The Certificate applicant is responsible for coordination with the air traffic service provider responsible for supplying air traffic services for the airspace affected by the operation. Certificate applicants are also responsible for obtaining necessary permissions/advising aerodrome authorities etc.
          2. Validity of the SFOC is contingent upon the Certificate applicant coordinating with the applicable ATC agency. As with manned aircraft, UAV operations require deconfliction with, coordination with, and notification to other airspace users. All communications with ATC must be continuously monitored by the UAV pilot and the UAV pilot must be capable of complying with ATC instructions.
          3. When the airspace being operated in is under military authority, the Certificate applicant will need permission from that authority. Inspectors should remind Certificate applicants that they should be seeking this approval simultaneously while making application for the SFOC.
          4. In many cases, the Certificate applicant will need to ensure that other airspace users are notified of the UAV activity - e.g... issuance of a NOTAM.

            Information Note:
            The times entered in the NOTAM obviously cannot exceed the valid-to-date of the SFOC.

            UAVs are often slower than most manned aircraft that routinely fly in the same operational stratum. This raises the question of whether UAVs will need to have increased separation minima where a UAV is unable to operate at performance levels consistent with ATC control clearances. Additionally, specific UAV SIDS/STARS may be required and they may need specific designation. However, these are not issues that will be addressed in this staff instruction.
        11. UAV System Security

          1. The Certificate applicant must describe what security measures are in place to prevent interference with someone taking control or jamming the communication links.

            Information Note:
            Unlawful interference is a concern since it may be more difficult to protect a control station against unlawful interference or seizure than the cockpit of a manned aircraft. Ground-based screening needs to be continuous, unlike one-time screening where passengers are screened before boarding a manned aircraft. Security measures need to be incorporated into the UAV system to provide assurance that the UAV will be used only for its intended and authorized purpose. The security risks need to be evaluated and mitigated as appropriate.
        12. Environmental Considerations

          1. The Certificate applicant must describe the considerations given to the environmental impact of the operation – e.g. battery disposal, fuel/oil spills, provincial/federal government authorities consulted regarding bird migration/nesting (Ministry of Natural Resources, Canada Wildlife Service / Environment Canada).
          2. The elimination of humans on board UAVs relieves the UAV system designer of a number of onboard environmental requirements. However, there may be “external” environmental issues, such as the disposal of fuel from routine pre-flight fuel drains, inadvertent fuel and oil spills, fuel jettisoning in flight etc. that apply to the UAV operation. Procedures to address these issues should be set out in the company’s operations manual.
        13. Reporting Occurrences

          1. The Transportation Safety Board, established under the Canadian Transportation Accident Investigation and Safety Board Act, is responsible for investigating all transportation occurrences in Canada. Since many UAVs have a take-off weight less than 5 700 Kg, they do not fall within the criteria of a “reportable aviation incident”. The Certificate holder should be aware of the legislation regarding incidents and accidents and that the release of names in fatal accidents is at the discretion of the Coroner.
          2. A condition will be added to the Certificate that requires the Certificate holder to report:

            1. Injuries to persons requiring medical attention;
            2. Unintended contact between the UAV and persons, livestock, vehicles, vessels or other structures;
            3. Unanticipated damage incurred to the airframe, control station, payload or communications links; and
            4. Any time the aircraft is not kept within the geographic and altitude limits as outlined in the SFOC.
            5. The Certificate holder shall report these occurrences to Transport Canada as soon as possible after the occurrence and not operate the UAV following the occurrences until such time as the Regional office approves its further operation.
            6. In their SFOC application, the Certificate applicant should be able to specify an expected level of equipment attrition for the operation - e.g. if the air vehicle routinely suffers damage on landing.
            Information Note:
            It is anticipated that both ICAO and TSB may be changing their legislation to specifically address UAV operations.

            Reviews of UAV occurrences have reported the proportion of human error induced mishaps to be within a 17% - 60% range with maintenance errors accounting for about 20% of the occurrences. Further investigation into UAV pilot error and equipment failure mishaps needs to be done to identify the systemic factors that made the errors or failures inevitable.
        14. Exemptions

          1. The Certificate applicant will need to be aware of any Ministerial Exemption(s) that may be in place for UAV operations. Copies of these exemption(s) will have to accompany the SFOC.

            Information Note:
            While no exemptions are currently in force, there may be exemptions put in place until appropriate provisions of the CARs come into effect - e.g. exemptions for UAVs operating without a Certificate of Registration, aircraft markings or a flight authority.
        15. Aerial Demonstrations before Invited Assemblies of Persons

          1. In cases where the mission of the UAV is to demonstrate system capabilities in front of an invited assembly of persons, the Certificate applicant may wish to consult the Special Flight Operations Standards - Special Aviation Events - Air Show Standards for matters of crowd control, flight lines, distances from spectators etc. The Certificate applicant can expect that appropriate conditions will be added to the SFOC.

            Information Note:
            Subsection 101.01(1) of the CARs, defines “invited assembly of persons” as any number of persons who have been invited, by any means, to attend a special aviation event. The term excludes competition judges, the holder of a special flight operations certificate, members of a certificate holder’s staff and members of a participant’s support team.
        16. Gathering Statistics

          1. While Transport Canada does not presently keep statistics on UAV flying hours, Certificate holders should be maintaining flight records. The Inspector may ask the Certificate holder at the end of the operation to provide the following information:

            1. How many flights were conducted,
            2. Total hours accumulated in flight, and
            3. Total number of UAVs flown.
        17. Noise &Emissions

          1. Aircraft noise standards are defined in ICAO Annex 16 Volume 1. The scope of this standard is limited to aircraft issued with a Certificate of Airworthiness. In Canada, Chapter 516 of the Airworthiness Manual specifies maximum noise emission levels for the issuance of a type certificate. In future, if certification standards for UAVs are developed, it is reasonable to expect noise certification to be part of the UAV system type certification process.
          2. Emission standards are contained in ICAO Annex 16 Volume 11. Applicability is currently limited to large turbo-jet and turbofan engines with compliance being demonstrated as part of the engine type certification process. In Canada, Chapter 516 of the Airworthiness Manual specifies engine emission levels. In the event that future standards for UAV systems require certified engines, then noise certification issues would be addressed as part of the engine type certification process.

    6.0  ISSUING THE SPECIAL FLIGHT OPERATIONS CERTIFICATE

    6.1  General

    1. When a Certificate applicant’s submission has been reviewed and it is determined that the requirements of the Standards have been met, a Special Flight Operations Certificate for the operation shall be prepared for the signature of the Regional Superintendent, General Aviation. As the documentation required to approve these operations can be quite extensive, it is imperative that it is presented to a Superintendent in an orderly and comprehensive manner for his or her review.
    2. Operating conditions will vary depending on aircraft performance capabilities, equipment on the UAV (i.e. payload), mission requirements, operating environment, complexity of the operation (i.e. multiple UAVs) etc. Therefore, the sample Certificate below outlines an extensive, although not exhaustive, list of conditions. Some conditions are essential to all operations and others may or may not apply. There may also be a need to impose additional conditions that have not been considered. In this case, please advise the Special Flight Operations Inspector at HQ so the new conditions may be added to these staff instructions.
    3. Some existing restrictions or prohibitions on UAV flights are not intended to be permanent. As experience is gained in UAV operations and UAV system technology evolves, some of these conditions/restrictions will need to be revisited.

    6.2  Record Keeping

    1. All information, documentation, correspondence and records of telephone conversations received and used to issue the Certificate for the conduct an unmanned air vehicle flight operation should be kept together and placed on the appropriate regional files and in RDIMS.

    6.3  Extensions to SFOCs

    1. The wording in an SFOC states, “This Certificate is not transferable and is valid from … until… or until it is suspended or cancelled”. There is no provision to extend an SFOC. If there is a requirement to “extend” an SFOC before the original one expires, then a new SFOC will have to be issued with the following statement, “This Certificate cancels and supersedes the Special Flight Operations Certificate issued to (enter name of applicant) on (enter date) at (enter city, province) by (enter title of person who signed the original SFOC) on behalf of the Minister of Transport, Infrastructure and Communities”. If the original SFOC is expired, then a new one may be issued, and there will be no need to include the above statement.

    6.4  Standard Format for a Special Flight Operations Certificate – Unmanned Air Vehicle System

    1. All Special Flight Operations Certificates – unmanned air vehicle systems shall be issued in a standard letter format using Transport Canada, Safety And Security letterhead as outlined below.

      1. The letter shall be addressed to the applicant as listed or named in the application.
      2. The date of issue shall be entered on the letter.
      3. Enter the number corresponding to the regional file and RDIMS number.
      4. Following the appropriate salutation (e.g. Dear Sir etc.), the following wording shall be used in all Special Flight Operations Certificates for this activity.


    SAMPLE AUTHORIZATION

    Pursuant to section 603.67 of the Canadian Aviation Regulations, this constitutes your Special Flight Operations Certificate (SFOC) for the operation of the (enter name/model of UAV) unmanned air vehicle system as described in your SFOC application dated (enter the application date and, if necessary, the amended application date).

    This Certificate is issued to (enter name as it appears on the on the application). It may be suspended or cancelled at any time by the Minister for cause, including failure on the part of the Certificate holder, its servants or agents to comply with the provisions of the Aeronautics Act and the Canadian Aviation Regulations (CARs). This Certificate is not transferable and is valid from (enter start date of the operation) until (enter the end date of the operation) or until it is suspended or cancelled.

    This Certificate is valid for the operation of the (enter name/model of UAV) unmanned air vehicle for the purpose of (enter purpose of flight operation, and if applicable, number of flights) at the (enter the location where the operation is being conducted).

    Nothing in this Certificate shall be held to relieve the Certificate holder from requirements to comply with the provisions of such Canadian Aviation Documents as may have been issued to him pursuant to the Aeronautics Act or the Canadian Aviation Regulations.

    Issued under the authority of the Minister pursuant to the Aeronautics Act, this document certifies that the Certificate holder is adequately equipped and able to conduct a safe operation, subject to the observance and performance by the Certificate holder of the following conditions:

    Information Note:
    It is anticipated that the following key conditions will apply to all operations, although there may be a need to amend the wording of the condition based on the operation.

    6.5  Key Conditions

    1. Except where otherwise referred to in this Certificate, the Certificate holder shall comply with the applicable provisions of the Aeronautics Act and the Canadian Aviation Regulations (CARs).
    2. The Certificate holder shall maintain an adequate management organization that is capable of exercising supervision and operational control over persons participating in the (enter name/model of UAV) operation.
    3. The Certificate holder shall conduct the operation of the (enter name/model of UAV) unmanned air vehicle in a safe manner.
    4. The Certificate holder shall have subscribed for adequate liability insurance covering risks of public liability at the levels described in subsection 606.02 (enter applicable paragraph number) of the Canadian Aviation Regulations for the period of the (enter name/model of UAV) unmanned air vehicle operation.
    5. The Certificate holder shall adhere to the security plan for the selected area of operation in accordance with the data provided in (enter name of Certificate applicant) SFOC application, dated (enter the application date and, if necessary, the amended application date) or as otherwise agreed upon between (enter name of Certificate applicant), Transport Canada and (enter name of any other pertinent authorities).
    6. The normal and emergency procedures for the selected areas of operation shall be conducted in accordance with data provided in (enter name of Certificate applicant) SFOC application, dated (enter the application date and, if necessary, the amended application date) or as otherwise agreed upon between (enter name of Certificate applicant), Transport Canada and (enter name of any other pertinent authorities).
    7. The Certificate holder is responsible for ensuring that (enter name of applicable authority i.e. aerodrome operator, landowner, tenant, MAAC local field operator etc.) has been advised of the proposed operations and has no objections.
    8. Throughout flight operations, the Certificate holder shall ensure that the (enter name/model of UAV) unmanned air vehicle is flown over areas that would permit a safe landing on the surface without hazard to persons or property in the event of any emergency requiring immediate descent.
    9. The (enter name/model of UAV) unmanned air vehicle shall give way to manned aircraft.
    10. The (enter name/model of UAV) unmanned air vehicle shall only be operated during the (enter “day”, “night” etc.).
    11. The (enter name/model of UAV) unmanned air vehicle shall be operated (enter weather minima e.g. visibility, distance from cloud etc.) or make a statement, such as - in accordance with the weather minima provided in (enter name of Certificate applicant) SFOC application, dated (enter the application date and, if necessary, the amended application date).
    12. The observer(s) (enter names if known) shall maintain continuous unaided visual contact with the (enter name/model of UAV) unmanned air vehicle at all times.
    13. The observer(s) (or enter name, if known) shall maintain constant communication with the UAV pilot (enter name if known) at all times.
    14. (Enter name/model of UAV) unmanned air vehicle operations shall be limited to a maximum altitude of (enter altitude) above ground level (AGL).
    15. Notwithstanding the requirements of paragraph 602.14(2) (b) of the Canadian Aviation Regulations, the (enter name/model of UAV) unmanned air vehicle shall not be operated (including take-offs, landings and flight demonstrations) at a distance of less than (enter distances) away from inhabited structures such as buildings, vehicles, vessels and other persons who are not associated with the operation.
    16. Flight of the (enter name/model of UAV) unmanned air vehicle over spectators is prohibited.
    17. The (enter name/model of UAV) unmanned air vehicle shall be operated by (enter name of UAV pilot(s). or
    18. The (enter name/model of UAV) unmanned air vehicle pilot(s), observer(s), and payload operator(s) (enter names if known) shall be (enter appropriate company name) employees (and, if appropriate make a reference to the experience, training or licence held, as appropriate).
    19. The Certificate holder shall not require any person to operate the controls of the (enter name/model of UAV) unmanned air vehicle if either the person or the Certificate holder has any reason to believe that the person is suffering or is likely to suffer from fatigue so that they are unfit to perform their duties.
    20. No person shall operate the (enter name/model of UAV) unmanned air vehicle within eight hours after consuming an alcoholic beverage or while under the influence of alcohol or while using any drug that impairs the person’s faculties to the extent that the safety of the operation is endangered in any way.
    21. The Certificate holder is responsible for coordination with the air traffic control agency responsible for supplying air traffic services for the airspace affected by the operation. Validity of this Certificate is contingent upon the Certificate holder coordinating with the air traffic service provider. and/or
    22. (Enter name/model of UAV) unmanned air vehicle operators shall broadcast intentions on and monitor (enter appropriate frequency, or in the case of a military range, the frequency assigned by the Range Safety Officer) at all times during flight operations. and/or
    23. The Certificate holder shall, prior to flight, contact the (enter name of air traffic agency) to issue a NOTAM.
    24. The Certificate holder shall report to this office, on the first working day following, details of any of the following occurrences:

      1. Injuries to persons requiring medical attention;
      2. Unintended contact between the (enter name/model of UAV) unmanned air vehicle and persons, livestock, vehicles, vessels or other structures;
      3. Unanticipated damage incurred to the air vehicle, control station, payload or communications links; and
      4. Any time the (enter name/model of UAV) unmanned air vehicle is not kept within the geographic and altitude limits as outlined in this SFOC.
    25. The Certificate holder shall not operate the (enter name/model of UAV) unmanned air vehicle following any of the occurrences listed in Condition (enter # of condition above), until such time as this office approves its further operation.
    26. All persons connected with this operation shall be familiar with the contents of this Certificate.
    27. A copy of this Certificate and a copy of the application dated (enter date of application and appendices if appropriate) shall be on site any time the (enter name/model of UAV) unmanned air vehicle is in operation.

      Yours truly,

      Insert signature block,

      for Minister of Transport, Infrastructure and Communities

      Information Note:
      The following additional conditions may not be appropriate for all operations, therefore, use only the conditions that apply and delete the remainder. Also, there may be a need to impose conditions that have not been considered here, subject to the risk assessment.

    6.6  Additional Conditions

    1. The observer(s) (enter name if known) shall not perform crew duties for more than one (enter name/model of UAV) unmanned air vehicle at a time.
    2. The chase aircraft must remain within radio control range of the (enter name/model of UAV) unmanned air vehicle to maintain appropriate signal coverage for flight control or activation of the flight termination system.
    3. Flight visibility for the chase aircraft shall be (enter distance e.g. three statute miles or greater).
    4. No more than one (name/model of UAV) unmanned air vehicle shall be operated by a single UAV pilot in-flight at any one time. Or
    5. No more than one (name/model of UAV) unmanned air vehicle shall be operated in-flight at any one time.
    6. The (enter name/model of UAV) unmanned air vehicle shall be operated in accordance with (enter any third party guidelines that may be appropriate to the operation, such as, the Model Aeronautics Association of Canada Safety Code, dated (enter valid date), and, if applicable, the Safety Guidelines for (enter the name of Field) Field Operations).
    7. During the operation, the Certificate holder shall comply with instructions received from the air traffic control agency responsible for the airspace in use.
    8. The Certificate holder is responsible for ensuring that (enter name of applicable authority (e.g. aerodrome operator, landowner, tenant, MAAC local field operator etc.) has been advised of the proposed operation and has no objections.
    9. The Certificate holder is responsible for ensuring that property owners, over which flights of the (enter name/model) unmanned air vehicle will take place, have been advised of the proposed operation and have no objections.
    10. The (enter name/model of UAV) unmanned air vehicle shall have (strobe lights, position lights, landing lights, as appropriate) on at all times during operation.

    SAMPLE COVERING LETTER

    TC Logo
    Return Address

    Our File Notre reference

    Date

    Person or Organization
    Address
    Address
    City, Province / State
    Postal Code / Zip code

    Dear Person, Sir/Madam:

    Please find attached the requested Special Flight Operations Certificate in accordance with your Special Flight Operations Certificate application of (enter the application date and, if necessary, the amended application date).

    Should you have any questions or concerns please do not hesitate to communicate with (enter name of representative of Transport Canada, Civil Aviation).

    Yours truly,

    Insert Signature Block

    7.0  SIMPLIFIED APPLICATION PROCESS

    7.1  Purpose

    1. The purpose of this section is to provide guidance to Inspectors and Certificate applicants for Special Flight Operations Certificate applications involving UAVs that are remote-controlled with a MTOW under 35 Kg and operated within visual range. This material was developed to better respond to the demands of a large portion of UAV operators.
    2. The following flow chart offers an overview of this simplified application process. Specific eligibility requirements follow the flow chart.

    Simplified SFOC Application Process Selection Guide

    7.2  Background

    More and more applications are being received by persons, including model aircraft hobbyists, who wish to operate unmanned air vehicles that are equipped with miniaturized payloads, at low altitudes, often over or near built-up areas of cities and towns, for purposes of aerial photography and aerial inspection. UAV services are being sought by realtors, movie producers, sporting event organizers, land owners, marina operators, engineering firms, land developers and architects, just to name a few. In addition, model-sized UAVs are being flown for the purposes of research and development, flight testing and crew training, prior to being operated on a routine basis.

    7.3  Applicability

    This simplified application process applies to unmanned air vehicle system operations that are able to meet all of the eligibility requirements outlined below. Applications will be assessed on a case-by-case basis and an SFOC will only be issued once it is demonstrated that the risks associated with the operation of the UAV can be managed to an acceptable level. Where the UAV and/or mission requirements cannot meet these criteria, Certificate applicants will be required to make application in accordance with the guidance provided in Sections 1-4 of this staff instruction.

    7.4  Eligibility

    1. In order to use the simplified SFOC application process, the UAV system operation must meet the following eligibility requirements:
      1. The UAV shall be remote controlled;
      2. The UAV shall have a maximum take-off weight not exceeding 35 Kg (77.2 lbs);
      3. The UAV shall continuously be kept within unaided visual line-of-sight of the UAV pilot, or observer(s);
      4. Control of the UAV shall originate from a single ground control (i.e. airborne relays between multiple ground control stations are not permitted);
      5. The UAV shall be operated at a maximum altitude not exceeding 400 ft. above ground level (AGL);
      6. The UAV operation shall be conducted wholly within Class G airspace or military restricted airspace;
      7. The UAV shall be operated during day VFR conditions only;
      8. No more than one UAV shall be operated in flight by a single pilot at any one time;
      9. The UAV shall not have automated control of flight or navigation (stabilization systems are permitted);
      10. A serviceable “fail-safe” mechanism shall be incorporated into the UAV to terminate the flight following loss of signal;
      11. During flight, the unmanned air vehicle fail-safe function shall be programmed so that the throttle is set to idle or cut-off;
      12. The UAV shall remain at all times during the operation at a lateral distance of not less than 30 metres away from inhabited structures such as buildings, vehicles, vessels and other persons who are not associated with the operation; and
      13. The UAV shall not carry a payload that disperses products, drops objects or is an explosive device.
    2. Depending on the area of operation, consideration should be given to an Independent Flight Termination System and/or a redundant battery system for the fail-safe mechanism in paragraph (j).

    7.5  Observers

    Except in rare cases, an observer(s) will be required to perform the detect, sense and avoid function. This observer must have received training in visual scanning techniques and must have the ability to communicate timely instructions to the UAV pilot in order to keep the UAV clear of conflicting traffic.

    8.0  SUBMITTING AN APPLICATION

    8.1  General

    Prior to submitting an application for an SFOC, it is recommended that Certificate applicants review Sections 1 and 2 of this staff instruction. These sections, while written with Transport Canada Inspectors in mind, provide useful information to Certificate applicants on topics such as: risk management, liability insurance requirements, radiotelephone certificate requirements and terms and definitions.

    8.2  Application and Supporting Documentation

    1. As outlined in paragraph 623.65(d) of the Canadian Aviation Regulations, there is a requirement for the Special Flight Operations Certificate (SFOC) application to be received by Transport Canada at least 20 working days prior to the date of the proposed operation. This requirement is intended to provide Transport Canada Inspectors adequate time to review, in sufficient detail, an application and supporting documentation and to carry out any required co-ordination.
    2. Initially, the Certificate applicant can expect the SFOC to be issued for each specific mission. A Certificate applicant will not be granted a long-term authority (i.e. one year), and/or an authority that is not site specific, without a history of demonstrating that the operations have been conducted in a safe manner. Once an initial application has been made and a Certificate has been issued, subsequent SFOC applications should be able to be expedited. For example, if the mission changes, but other parameters remain the same (same UAV system, same UAV pilot) then the focus in processing the next application will be placed on assessing the suitability of the area used for the operation. Where the operating environment and the mission requirements change, the set of safety requirements that the Minister will impose will change accordingly.
    3. Subparagraph 623.65(d)(3), as outlined below, indicates the information that must be submitted to Transport Canada in an application for a SFOC. Since the information required by 623.65(d)(3)(a)-(j) may not be sufficient for Transport Canada to determine whether the operator can conduct a safe operation, Certificate applicants will also be asked for any other information pertinent to the safe conduct of the operation, as referenced in 623.65(d)(3)(k).
    4. 623.65(d)(3) The following constitutes an application for a Special Flight Operations Certificate:

      1. the name, address, and where applicable, the telephone number and facsimile number of the applicant;
      2. the name, address, and where applicable the telephone number and facsimile number of the person designated by the applicant to have operational control over the operation (Operation Manager);
      3. method by which the Operation Manager may be contacted directly during operation;
      4. the type and purpose of the operation;
      5. the dates, alternate dates and times of the proposed operation;
      6. a complete description, including all pertinent flight data on the aircraft to be flown;
      7. the security plan for the area(s) of operation and security plan for the area(s) to be overflown to ensure no hazard is created to persons or property on the surface;
      8. the emergency contingency plan to deal with any disaster resulting from the operation;
      9. the name, address, telephone and facsimile numbers of the person designated to be responsible for supervision of the operation area (Ground Supervisor), if different from the Operation Manager during the operation;
      10. a detailed plan describing how the operation shall be carried out. The plan shall include a clear, legible presentation of the area to be used during the operation. The presentation may be in the form of a scale diagram, aerial photograph or large scale topographical chart and must include at least the following information;

        1. the altitudes and routes to be used on the approach and departure to and from the area where the operation will be carried out;
        2. the location and height above ground of all obstacles in the approach and departure path to the areas where the operation will be carried out;
        3. the exact boundaries of the area where the actual operation will be carried out;
        4. the altitudes and routes to be used while carrying out the operation.
      11. any other information pertinent to the safe conduct of the operation requested by the Minister.

        Information Note:
        While all the information required by subparagraph 623.65(d) (3) of the Standard must be evident in the application, it is not mandatory that the information be presented in the sequence as outlined in the Standard. In fact, the sequence of information has been changed for the purposes of this staff instruction in order to achieve a more logical flow to the information, although the paragraph lettering still begins at (a) and ends at (k).

        Certificate applicants are not required to answer each and every question posed in this staff instruction, rather they should strive to submit a comprehensive application appropriate to the scope of the operation and complexity of the UAV system.
    5. 623.65(d)(3) The following constitutes an application for a Special Flight Operations Certificate:

      1. The name, address, and where applicable, the telephone number and facsimile number of the applicant.

        1. The Certificate applicant must provide their name, address, telephone and facsimile numbers, and any other pertinent contact information e.g. e-mail address.
        Information Note:
        It is vital to establish who has legal custody and control of the unmanned air vehicle. The Special Flight Operations Certificate is issued to the person or company that has complete responsibility for the operation and safety of the unmanned air vehicle flight operation and responsibility for compliance with the conditions contained in the SFOC. The Certificate holder may be in direct control of the UAV by remote control, co-located with the UAV pilot or monitoring the state and progress of the UAV in the control station, but in all cases, the Certificate holder must be the person or company who has legal custody and control of the aircraft.

        It is essential that the Certificate holder is aware of the responsibility to ensure that the UAV operation is conducted in such a way that the safety of persons and property on the ground and other airspace users is not jeopardized. It could be said that the Certificate holder assumes the same operational and safety responsibilities as the owner of a manned aircraft.

        Subsection 101.01(1) of the CARs definitions:

        “owner” - in respect of an aircraft, means the person who has legal custody and control of the aircraft.

        “operator” - in respect of an aircraft, means the person that has possession of the aircraft as owner, lessee or otherwise.

      2. The type and purpose of the operation.

        1. The Certificate applicant must provide a description of the intended role(s) / mission(s) / task(s) / usage of the air vehicle.
      3. The dates, alternate dates and times of the proposed operation.

        1. The Certificate applicant must provide the dates, alternate dates and times of the proposed operation.
        Information Note:
        The Certificate applicant should work with the Inspector to determine an appropriate validity period for the operation, taking into account potential mission delays for inclement weather etc. An SFOC with a few extra days validity period is preferable to issuing a second SFOC because the Certificate applicant could not complete the operation within the designated validity period.
      4. A complete description, including all pertinent flight data on the aircraft to be flown.

        1. The Certificate applicant must provide a complete description of the unmanned air vehicle system, including all the pertinent flight data.
        2. Three-view drawings or photographs of the air vehicle are desirable.
        3. The Certificate applicant may wish to use the following list to guide the content of their submission:

    8.3  Air Vehicle Description

    1. Who is the UAV manufacturer? Is this a commercially available aircraft? If so, include the Internet address of the manufacturer?
    2. General description of the air vehicle, including

      1. Category – e.g. aeroplane, vertical take-off and landing (VTOL), airship

        1. Composition – e.g. graphite, composites
        2. Landing gear - e.g. retractable, tricycle, floats
        3. Measurements – e.g. wingspan, fuselage length, body diameter, rotor diameter
        4. Weight – e.g. payload weight, maximum gross take-off weight, empty weight
        5. Type of propulsion system – e.g. battery powered electric propulsion, turboprop, turbofan; rear or forward mount
        6. Fuel / Oil system – e.g. types, capacity, number of tanks
        7. Electric propulsion system – e.g. power output, separate electrical source
        8. Method of take-off/ launch – e.g. taxi and take-off, pneumatic catapult, rocket assisted, hand-launched (with bungee cord), launched from a roof rack that can be fitted to a ground vehicle
        9. Method of landing / recovery – e.g. approach and runway landing, glide to a predetermined area, parachute or parasail deployment, belly/skid landing (where aircraft has no undercarriage), skyhook snag, controlled crash such as a deep stall manoeuver that lands the air vehicle safely on a small inflatable cushion (airbag), arrester cable
        10. Flight sensors – e.g. altitude determination based on the barometric system
        11. Redundant systems – e.g. fight controls, avionics
        12. Visual detectability – e.g. high visibility paint scheme
      2. Equipment:

        1. Stabilization system
        2. Ballistic parachute system
        3. Position, anti-collision and landing lights
        4. Automatically activated fail-safe flight termination system in the event of a critical system failure or loss of communications link
        5. Independent Flight Termination System and/or a redundant battery system for the fail-safe mechanism
        6. Ground support equipment used in the operation – e.g. catapults, pneumatic/hydraulic launch systems, starters, generators

    8.4  Pertinent flight data on the aircraft to be flown

    1. Performance – e.g. operating speeds, climb and descent rates, maximum altitude, maximum range, maximum endurance
    2. Operating Limitations – e.g. winds (wind shear, gusts), cross-winds, temperatures
    3. History of operating similar aircraft systems – e.g. number of flights, number of flight hours

    8.5  Remote Control System Description

    1. Manufacturer(s) and model(s)
    2. Describe transmitter, receiver, battery pack, servos, frequency and number of channels used
    3. Duration of airborne power supply and transmitter
    4. That are the sources of RF interference and is there adequate protection from these hazards?
    5. Instrumentation, if installed – e.g. is the UAV system capable of displaying information to the UAV pilot?
    6. Does the control system include visual warning or alarm information provided to the UAV pilot - e.g. low fuel, low battery, critical systems failure
    7. Redundant systems – e.g. servos, power supplies, receivers

    8.6  Communication Links Description

    1. Command and Control

      1. What steps are taken to ensure there is no radio interference – e.g. using a frequency monitor/scanner or using 2.4 GHz spread spectrum equipment?
      2. Control/data frequencies
      3. What is the range of the line-of-sight control links?
      4. Fault indications to indicate lost links e.g. “off flags”
      5. Single or dual redundant control links
    2. Communications

      1. Where there is an operational requirement for radio communication for monitoring other aircraft movements or communicating with other airspace users, describe

        1. The method for communicating with other airspace users – e.g. how does the pilot report positions?
        2. Independent means of backup communication
        3. What type of communication system is used for the pilots, ground support personnel and observers to communicate with each other?
    3. Sense and Avoid Systems

      1. Visual observers for detecting/avoiding other airborne objects and ground related obstacles is addressed in paragraph (k).
    4. Payload

      1. What is the payload - e.g. daylight colour video camera infrared sensor (IR sensors), electro-optical infrared cameras (EO-IR), synthetic aperture radar (SAR)?
      2. Nature of payload – e.g. to provide real-time day video imagery of terrain being overflown, to determine real-time meteorological condition.
      3. Payload limitations – e.g. what if the UAV pilot and Payload operator require different operational limits, such as altitudes? What measures are in place to address these potential conflicts?
      4. How is the payload secured to the air vehicle?
      5. Does the payload have a secondary purpose that could affect the control of the air vehicle?
      6. Does the operation of the payload impact the workload of the pilot?

    Information Note:
    It is not Transport Canada’s responsibility to determine minimum requirements or standards for emergency equipment and procedures nor do Inspectors have the necessary expertise to assess the effectiveness or efficiency of a proposed emergency plan.

    1. The name, address, and where applicable the telephone number and facsimile number of the person designated by the applicant to have operational control over the operation (Operation Manager).
    2. The Certificate applicant must provide the name, address, telephone and facsimile numbers of the person designated to have operational control over the operation.
    3. It is expected that the SFOC application will also describe how/why the person is qualified to act as the Operation Manager.

      Information Note:
      It is not the intent of this staff instruction to confine the Certificate applicant to a mandatory management structure, including position titles. They may or may not use position titles such as “Operation Manager” and “Ground Supervisor” within their organization, however someone must have operational control over the operation and someone must be responsible for supervision of the operation area. It must be clearly indicated in the application who has been designated these responsibilities. If the operation is small, the Operation Manager and the Ground Supervisor could be the same person.
    4. The Operation Manager is the person designated to assume responsibility for the operational control of the UAV flight operation. The Operation Manager is typically thought of as the person who exercises command of all crew and personnel during UAV operations, including planning and communications. While the standards do not outline what duties have to be assumed by an Operation Manager, they might include.
    5. making application to the appropriate Transport Canada Regional General Aviation office with sufficient advance notice to complete the administrative and coordination duties required to prepare the Special Flight Operations Certificate;
    6. establishing liaison with airport management, property owners, local agencies;
    7. liaising, where applicable, with local aircraft operators to make them aware of the operation;
    8. where applicable, coordinating with military air traffic services; coordinating with NAV CANADA with regard to the publication of a Notice to Airmen (NOTAM) etc.;
    9. ensuring emergency procedures are developed in concurrence with, and approved by, the delegated agency appropriate to the site of the operation (e.g. at an airport the airport authority; over water this could be Coast Guard, Harbour Authority or other local authorities);
    10. providing a sufficient number of capable and informed persons to handle the operation with efficiency and safety;
    11. ensuring all persons connected with the operation are properly informed of their duties and are familiar with the contents of the authorization;
    12. making the decision to cancel or postpone the operation in the event of bad weather, or any other circumstances in accordance with the conditions of the authorization;
    13. During the operation, the Operation Manager, or their delegate, might
    14. ensure compliance of company standard operating procedures (SOPS);
    15. terminate the operation if it is being conducted in an unsafe manner;
    16. communicate with Air Traffic Control;
    17. communicate with the Ground Supervisor;
    18. broadcast to aircraft in the area of operation.
    19. Method by which the Operation Manager may be contacted directly during the operation.
    20. The Certificate applicant must describe the method by which the Operation Manager will be contacted directly during the operation.
    21. Information Note:
      It is not mandatory that the Operation Manager be on-site during the flight operations, however, a means of contacting the responsible person on-site (e.g. Ground Supervisor) must be provided.

    22. The name, address, telephone and facsimile numbers of the person designated to be responsible for supervision of the operation area (Ground Supervisor), if different from the Operation Manager during the operation.
    23. The Certificate applicant must provide the name, address, telephone and facsimile numbers of the person designated to be responsible for supervision of the operation area.
    24. It is expected that the Certificate applicant will also describe how/why the person is qualified to act as the Ground Supervisor.
    25. While the standards do not outline what duties have to be assumed by a Ground Supervisor, they might include:
    26. crowd control where spectators would be viewing an operation e.g. ensure crowd remains separated from the control station at distances as specified in authorization as well as take-off and landing distances and ground manoeuvring of UAV;
    27. ensuring minimum safety distances are met in terms of occupied buildings, vehicles etc.;
    28. communicating with the Operation Manager during the operation - e.g. portable radio, cell phone;
    29. arranging for the use of special radio frequencies as required;
    30. keeping watch for other airspace users;
    31. ensuring security of the site.
    32. A detailed plan describing how the operation shall be carried out. The plan shall include a clear, legible presentation of the area to be used during the operation.
    33. The presentation may be in the form of a scale diagram, aerial photograph or large scale topographical chart and must include at least the following information:
    34. the altitudes and routes to be used on the approach and departure to and from the area where the operation will be carried out;
    35. the location and height above ground of all obstacles in the approach and departure path to the areas where the operation will be carried out;
    36. the exact boundaries of the area where the actual operation will be carried out;
    37. the altitudes and routes to be used while carrying out the operation.
    38. The Certificate applicant must provide a detailed plan describing how the operation shall be carried out. In addition, the Certificate applicant will be required to provide information to support the fact that the operation will be conducted entirely within Class G airspace, or restricted military airspace.
    39. Information Note:
      Overhead imagery is acceptable in addition to aerial photographs and/or large-scale topographical charts.
    40. The security plan for the area(s) of operation and security plan for the area(s) to be overflown to ensure no hazard is created to persons or property on the surface.
    41. The Certificate applicant must describe the security plan for the area(s) of operation and for the areas to be overflown.

      Information Note:
      Security plan in this paragraph pertains to safety and security for persons and property on the ground.
    42. The Certificate applicant may wish to use the following list to guide the content of their submission:
    43. that safe altitudes and distances are proposed for the operation – e.g. from members of the public, structures, vehicles, vessels?
    44. How are persons not associated with the operation isolated from the UAV during take-off, recovery and during the flight operation - e.g. fences, barriers?
    45. Is it necessary to notify property owners and determine that they have no objections?
    46. Is it necessary to notify airport/aerodrome authorities and determine that they have no objections?
    47. Will the UAV be operating in places where it will be necessary for any other people to be made aware of the proposed operation to ensure that they have no objections?
    48. Will the UAV be operating in areas where the public will have to be removed from areas affected by the operation?
    49. Are access routes available for emergency vehicles.
    50. The emergency contingency plan to deal with any disaster resulting from the operation.
    51. The Certificate applicant must describe the emergency contingency plan.
    52. It is expected that they will:
    53. have an emergency plan in place describing the personnel and equipment available to respond to anticipated emergencies, including incidents and accidents, or a medical emergency involving a spectator in the case where potential clients (or whomever) have been invited to watch the aerial demonstration;
    54. communicate the plan, where applicable to the property owner, airport/aerodrome manager or air traffic service provider; and
    55. have the equipment and personnel described in the emergency plan in place during flight operations.
    56. At minimum, the Certificate applicant would:
    57. Be aware of what emergency response service is available in the area of operation.
    58. Where warranted, establish advance contact with the applicable emergency agencies and authorities.
    59. Know how to access emergency services and have the means to do so - e.g. cell phone, sat phone.
    60. Ensure that all persons associated with the operation who may be required to respond to an emergency situation are briefed in advance of the operation.
    61. Have in place operational control measures necessary to ensure the safety and orderly conduct of persons attending the flight demonstration.
    62. In the event of an aircraft emergency, establish that there is no immediate risk to life, then implement procedures for flight termination - i.e. transit to a safe recovery area.
    63. Any other information pertinent to the safe conduct of the operation requested by the Minister.
  • Organization
  • The Certificate applicant must indicate in their application that they have, and can maintain, an adequate management organization that is capable of exercising supervision and operational control over persons participating in the UAV system operations.
  • Information Note:
    The Certificate applicant is responsible for ensuring that the operation is managed and conducted in such a way that the safety of persons and property on the ground and other airspace users is not jeopardized. The management of a UAV system operation will vary according to scope and complexity of the mission - e.g. a small UAV may not require the support of a large number of persons, rather the expertise in a variety of areas could come from one or two key personnel.
  • Personnel Qualifications
  • The Certificate applicant must describe the qualifications of the UAV pilot(s) observer(s) and UAV system maintainer(s) in sufficient detail to show that the personnel have been adequately trained and are qualified to fulfill their duties. Where there is intent for the UAV pilot to perform concurrent duties e.g. the UAV pilot is the payload operator or the UAV pilot is the visual observer, the Certificate applicant will have to demonstrate that the safety of the UAV flight is not jeopardized by virtue of these multiple duties.
  • UAV Pilot
  • Information Note:
    The Aeronautics Act states: "pilot-in-command" means, in relation to an aircraft, the pilot having responsibility and authority for the operation and safety of the aircraft during flight time. This responsibility and authority applies even though the pilot is external to the aircraft. The use of the term “pilot” in this staff instruction, however, is not intended to suggest that the pilot is necessarily qualified as a crew member of a manned aircraft.
  • The UAV pilot must be able to control the UAV throughout its design parameters and potential operating conditions, including dealing correctly with emergencies and system malfunctions. The Certificate applicant may wish to use the following list to guide the content of their submission:
  • General
  • Knowledge of MAAC Safety Codes
  • Hold or have held a Pilot Permit or Licence (or military equivalent) Ratings held. Are the licence (and ratings) relevant to the UAV being flown and the type of operating environment - e.g. if the UAV is an aeroplane, does the UAV pilot hold an aeroplane pilot licence?
  • Hold or held an ATC licence
  • Hold a radiotelephony licence
  • Expected to comply with company/organization SOPs - e.g. use of checklists, aircraft checks, crew co-coordination, emergency drills, flight time and flight duty time limitations and minimum rest periods
  • Knowledge
  • Completed pilot ground school instruction
  • Written and passed Transport Canada aviation theory exams
  • Knowledge of air traffic control rules and procedures, communications, radiotelephone
  • Knowledge of aviation law, meteorology, navigation, airmanship, flight planning
  • Knowledge specific to the UAV system
  • Experience
  • Experience operating manned aircraft
  • Experience operating radio controlled model aircraft
  • Experience operating model aircraft or UAVs of similar performance
  • Experience on specific UAV type
  • Total experience flying UAVs
  • Training
  • Radio controlled simulator training
  • System-specific training on UAV type including handling critical emergencies - e.g. engine failure, engine over-heating, battery failure
  • UAV system manufacturer’s training
  • Company/organization ops training
  • Crew resource management training
  • Other relevant training courses
  • Skill
  • Means by which competency has been demonstrated in the ability to perform normal and emergency procedures appropriate to specific type of UAV - e.g. flight test
  • Currency
  • How is currency maintained?
  • 8.7  Observers

    1. Observers are crew members. For within visual range operations, except in rare cases, an observer(s) will be required to perform the detect, sense and avoid function. Observers will be required to maintain visual contact with the UAV at all times while scanning the immediate environment for potential conflicting traffic. Observers will maintain constant communication with the UAV pilot in order to provide instructions on required manoeuvering to steer clear of other aircraft where a potential for conflict exists.
    2. The Certificate applicant may wish to use the following list to guide the content of their submission:

      1. Expected to comply with company/organization established and maintained SOPs
      2. Expected to comply with company/organization established flight time and flight duty time limitations and minimum rest periods
      3. Hold or have held a Pilot Permit or Licence, or military equivalent
      4. Hold or have held an ATC Licence
      5. Hold a radiotelephony licence
      6. Understand proper communications and phraseology
      7. Written and passed Transport Canada aviation theory exams
      8. Knowledge of air traffic control rules and procedures - e.g. right of way rules
      9. Knowledge of aviation law, meteorology, navigation, airmanship, flight planning
      10. Experience as an observer
      11. Understand proper visual scan techniques
      12. Company/organization ops training
      13. Crew resource management training
      14. Means by which competency has been demonstrated
      15. Other relevant training course.

    8.8  Payload Operator

    1. Where the pilot has a dual role (e.g. the UAV pilot is also the payload operator), the Certificate applicant will need to address any risks associated with the same person performing two functions.
    2. For example,

      1. Does the payload have a secondary purpose that could affect the control of the air vehicle?
      2. Does the operation of the payload impact the workload of the UAV pilot?

    8.9  System Maintainer

    1. The Certificate applicant must describe who is maintaining the UAV system, including both the air and ground components of the system (e.g. engines, air vehicles, communication links) in a fit for flight condition. What are their qualifications? Do they have knowledge of MAAC Safety Codes.

    8.10  UAV System

    1. The Certificate applicant must provide a description of both the normal and emergency procedures.
    2. The Certificate applicant may wish to use the following list to guide the content of their submission:
    3. Normal UAV Operations

      1. Manuals

        1. Is there UAV system flight manual?
        2. Are there SOPs outlining how crew members are expected to carry out their duties including, but not limited to:

          1. Pre-flight inspections
          2. Use of checklists
          3. Crew coordination
          4. Take-off /launch and landing/recovery procedures
          5. Emergency drills - e.g. loss of control communication links, abort procedures following critical system failure
        3. Is there a Company Flight Operations Manual?
        4. Are there UAV pilot training manuals that specify required qualifications, levels of training, proficiency and recurrency for flight crew?
        5. Does the UAV pilot maintain a logbook?
      2. Pre-flight Activities

        1. Has the amount of fuel/energy planned for the flight also taken into account emergency contingencies?
        2. Weather considerations
        3. Have NOTAMS affecting the area of operation been checked?
        4. Does the crew use checklists?
        5. Is the area clear for taxi and take-off/launch?
      3. Take-off / launch

        1. Procedures – e.g. hand launched
      4. In-Flight

        1. How does the pilot confirm that they are staying within the altitude and distance limitations?
      5. Landing / Recovery

        1. Any unique procedures?
      6. Post Flight

        1. Is there a post flight inspection of the UAV?

    8.11  Abnormal Events and Emergency Procedures

    1. In the event of a malfunction, failure or other in-flight emergency, how is the UAV going to safely land without creating a hazard to other airspace users or persons or property on the ground?
    2. The Certificate applicant may wish to use the following list to guide the content of their submission:

      1. Take-off / launch

        1. What are the procedures if an aborted take-off/launch becomes necessary?
      2. In-Flight

        1. What will happen in the event:

          1. propulsion system degradation due to malfunctions – e.g. electrical systems
          2. the engine quits – i.e. can the pilot restart the engine in flight?
          3. “fuel” starvation or fuel contamination
          4. loss of battery voltage
          5. loss of control surface performance
          6. loss of altitude
          7. loss of command and control links (uplinks) - e.g. does the UAV have a pre-programmed loss-of-link flight profile including termination actions should the control link not be re-established?
          8. loss of status links (downlinks)
          9. electronics failure
          10. an interfering signal is detected
          11. visual contact is lost
      3. Landing / Recovery

        1. What are the abort procedures for a “botched” landing/recovery?
        2. Can a crash start a fire?
      4. Post Flight

        1. Special maintenance/inspection after abnormal events
        Information Note:
        The Certificate applicant should be aware of the TSB legislation regarding reportable aviation incidents and accidents.

    8.12  UAV System Maintenance

    1. The Certificate applicant must describe how the UAV system is being maintained, including both the air and ground components of the system (e.g. engines, air vehicles, communication links) in a fit for flight condition.
    2. For example,

      1. Is there a maintenance and inspection plan/schedule?
      2. Who established the maintenance schedule - e.g. UAV manufacturer?
      3. Are maintenance records being kept?
      4. Are there maintenance and inspection manuals?

    8.13  UAV System Airworthiness

    1. The Certificate applicant must describe how they have determined that the air vehicle and the system are in a fit and safe state for flight - i.e. airworthy.

      Information Note:
      It present, Transport Canada does not define the matters to be taken into account for the design of UAVs and associated systems. Use of the term “airworthy” in this document means “in a fit and safe state for flight” but it does not mean “in conformity to a type design”.
    2. The Certificate applicant may wish to use the following list to guide the content of their submission:

      1. Operational history - how many crashes and failures have occurred? What corrective action has been taken to ensure that the failures do not occur again?
      2. Has an authorization for flight been issued by any other civilian authority or Military authority?

    8.14  Weather Limitations

    1. The Certificate applicant must specify the minimum weather conditions appropriate to the operation -e.g. maximum wind limitations. The Certificate applicant must describe the system in place to monitor and assess the weather in order to comply with the applicable weather minima.

      Information Note:
      As a default, the weather specifications in Part VI, Subpart 2 of the CARs will be applied unless the Certificate applicant is able to provide satisfactory rationale for applying lower limits.

    8.15  General Operating &Flight Rules

    1. In general, UAVs should be operated in accordance with the rules governing the flights of manned aircraft.
    2. It is policy to include a condition in the SFOC that states that the unmanned air vehicle shall give way to manned aircraft.

    8.16  Air Traffic Service Provider Coordination

    1. The Certificate applicant is responsible for coordination with the air traffic service provider responsible for supplying air traffic services for the airspace affected by the operation. Certificate applicants are also responsible for obtaining necessary permissions/advising aerodrome authorities etc.
    2. When the airspace being operated in is under military authority, the Certificate applicant will need permission from that authority. Certificate applicants should be seeking this approval simultaneously while making application for the SFOC.
    3. In many cases, the Certificate applicant will need to ensure that other airspace users are notified of the UAV activity - e.g. issuance of a NOTAM.

      Information Note:
      The times entered in the NOTAM obviously cannot exceed the valid-to-date of the SFOC.

    8.17  Environmental Considerations

    1. The Certificate holder must describe the considerations given to the environmental impact of the operation – e.g. battery disposal, fuel/oil spills, provincial/federal government authorities consulted regarding bird migration/ nesting (Ministry of Natural Resources, Canada Wildlife Service / Environment Canada).

    8.18  Reporting Occurrences

    1. A condition will be added to the Certificate that requires the Certificate holder to report:

      1. Injuries to persons requiring medical attention;
      2. Unintended contact between the UAV and persons, livestock, vehicles, vessels or other structures;
      3. Unanticipated damage incurred to the airframe, control station, payload or communications links; and
      4. Any time the aircraft is not kept within the geographic and altitude limits as outlined in the SFOC.
    2. The Certificate holder shall report these occurrences to Transport Canada as soon as possible after the occurrence and not operate the UAV following the occurrences until such time as the Regional office approves its further operation.
    3. In the SFOC application, the Certificate applicant must be able to specify an expected level of attrition for the operation - e.g. if the air vehicle routinely suffers damage on landing.

    8.19  Exemptions

    1. The Certificate applicant will need to be aware of any Ministerial Exemption(s) that may be in place for UAV operations. Copies of these exemption(s) will have to accompany the SFOC.

      Information Note:
      While no exemptions are currently in force, there may be exemptions put in place until appropriate provisions of the CARs come into effect - e.g. exemptions for UAVs operating without a Certificate of Registration, aircraft markings or a flight authority.

    8.20  Aerial Demonstrations before Invited Assemblies of Persons

    1. In cases where the mission of the UAV is to demonstrate system capabilities in front of an invited assembly of persons, the Certificate applicant may wish to consult the Special Flight Operations Standards - Special Aviation Events - Air Show Standards for matters of crowd control, flight lines, distances from spectators etc. The Certificate applicant can expect that appropriate conditions will be added to the SFOC.

      Information Note:
      Subsection 101.01(1) of the CARs, defines “invited assembly of persons” as any number of persons who have been invited, by any means, to attend a special aviation event. The term excludes competition judges, the holder of a special flight operations certificate, members of a certificate holder’s staff and members of a participant’s support team.

    8.21  Gathering Statistics

    1. While Transport Canada does not presently keep statistics on UAV flying hours, Certificate holders should be maintaining flight records. The Inspector may ask the Certificate holder at the end of the operation to provide the following information:

      1. How many flights were conducted,
      2. Total hours accumulated in flight, and
      3. Total number of UAVs flown.

    9.0  SFOC APPLICATION FOR MAAC AND AMA MEMBERS

    9.1  Purpose

    1. The purpose of this section is to provide guidance to Inspectors and Certificate applicants for SFOC applications involving unmanned air vehicles that would otherwise be considered model aircraft except they are too heavy to meet the definition of model aircraft. Certificate applicants operating UAVs for recreational purposes who are not MAAC members or do not hold AMA Flight Permits will be required to make application for an SFOC in accordance with the guidance provided in either Sections 1-4 or Section 5 of this staff instruction, as applicable.
    2. The following flow charts offer an overview of the MAAC and AMA member application process.

    SFOC Application Process for MAAC and AMA Members

    9.2  UNMANNED AIR VEHICLES THAT WOULD OTHERWISE BE CONSIDERED MODEL AIRCRAFT EXCEPT THEY ARE TOO HEAVY TO MEET THE DEFINITION OF MODEL AIRCRAFT

    1. Background

      1. The Model Aeronautics Association of Canada (MAAC) exists for the benefit of recreational remote control (r/c) model aircraft enthusiasts. MAAC has developed minimum standards in terms of safety codes for field operations, wings training programs and aircraft safety/worthiness inspection programs. (although MAAC has no regulatory authority). MAAC Safety Code prohibits pilots from use of “autonomous” flight capabilities or the navigating their aircraft to a point beyond their unaided visual line of sight. Adherence to The safety code and permission of the site owner is a are prerequisites for insurance coverage of modeling activities covered by MAAC. Commercial use of a model aircraft is “disqualifying”.
      2. The Academy of Model Aeronautics (AMA) is the official national body for model aviation in the United States. AMA’s purpose is to promote development of model aviation as a recognized sport and worthwhile recreation activity.
      3. Both MAAC and AMA are chartering organizations for model aircraft clubs across the country (Canada and the U.S. respectively) and offer chartered clubs official contest sanction, insurance, and assistance in getting and keeping flying sites.
    2. Applicability

      1. This simplified application process applies to unmanned air vehicles that would otherwise be considered model aircraft except they are too heavy to meet the definition of model aircraft. They are unmanned air vehicles that are operated recreationally by MAAC members, in accordance with the relevant MAAC Safety Codes, and/or are operated by AMA members who are visitors to Canada that hold a valid Flight Permit for the AMA Experimental Class for models weighing 55-100 lbs and who are demonstrating at events sponsored by MAAC. Applications will be assessed on a case-by-case basis and an SFOC will only be issued once it is demonstrated that the risks associated with the operation of the UAV can be managed to an acceptable level.
    3. Eligibility

      1. This simplified application process is not available to Certificate applicants operating UAVs for recreational purposes who are not MAAC members or do not hold AMA Flight Permits. Those Certificate applicants will be required to make application for an SFOC in accordance with the guidance provided in either Sections 1-4 or Section 5 of this staff instruction, as applicable.
    4. Insurance

      1. The SFOC will have a condition requiring the Certificate applicant to subscribe for adequate liability insurance covering risks of public liability at the levels required in subsection 606.02(8) of the Canadian Aviation Regulations (CARs). It should be noted that MAAC has insurance requirements for Canadian operators and requires visiting U.S. AMA members to hold AMA insurance. The level of coverage offered by these policies is likely to be higher than that required by the CARs, therefore, Certificate applicants should be adequately covered with MAAC or AMA insurance.
    5. Admission to MAAC Sanctioned Event

      1. Certificate applicants should be aware that the event organizer (e.g. Contest Director in charge of the event) will expect to see a copy of the SFOC prior to participating in the event.
    6. Submitting an Application

      1. See MAAC’s website at http://www.maac.ca/
    7. Sample Authorization for AMA Members

      1. Pursuant to section 603.67 of the Canadian Aviation Regulations, this constitutes your Special Flight Operations Certificate (SFOC) for the operation of the (enter name/model of UAV) unmanned air vehicle system as described in your SFOC application dated (enter application date and, if necessary, the amended application date).
      2. This Certificate is issued to (enter name as it appears on the on the application). It may be suspended or cancelled at any time by the Minister for cause, including failure on the part of the Certificate holder, its servants or agents to comply with the provisions of the Aeronautics Act and the Canadian Aviation Regulations (CARs). This Certificate is not transferable and is valid from (enter start date of the operation) until (enter end date of the operation) or until it is suspended or cancelled.
      3. This Certificate is valid for the operation of the (enter name/model of UAV) unmanned air vehicle for the purpose of demonstration flights while participating in the (enter name of MAAC sanctioned event) at the (enter location where the event is being conducted).
      4. Nothing in this Certificate shall be held to relieve the Certificate holder from requirements to comply with the provisions of such Canadian Aviation Documents as may have been issued to him pursuant to the Aeronautics Act or the Canadian Aviation Regulations.
      5. Issued under the authority of the Minister pursuant to the Aeronautics Act, this document certifies that the Certificate holder is adequately equipped and able to conduct a safe operation, subject to the observance and performance by the Certificate holder of the following conditions:

        Information Note:
        It is anticipated that the following conditions will apply to all operations, although there may be a need to amend the wording of the condition based on the operation and/or impose additional conditions that have not been considered here:


        1. Conditions

          1. Except where otherwise referred to in this Certificate, the Certificate holder shall comply with the applicable provisions of the Aeronautics Act and the Canadian Aviation Regulations (CARs).
          2. The Certificate holder shall conduct the operation of the (enter name/model of UAV) unmanned air vehicle in a safe manner.
          3. The Certificate holder shall have subscribed for adequate liability insurance covering risks of public liability at the levels described in subsection 606.02 (8) of the Canadian Aviation Regulations for the period of the (enter name/model of UAV) unmanned air vehicle operation.
          4. The Certificate holder is responsible for ensuring that the Contest Director of the MAAC sanctioned event has authorized the participation of the (enter name/model of UAV) of the unmanned air vehicle in the (enter name of MAAC sanctioned event).
          5. The (enter name/model of UAV) unmanned air vehicle shall be operated in accordance with the Model Aeronautics Association of Canada Safety Code, dated May 11, 2006, the Safety Guidelines for the (enter name of Field) Field Operations, the (enter name of MAAC sanctioned event) event rules.
          6. The (enter name/model of UAV) unmanned air vehicle shall give way to manned aircraft.
          7. The (enter name/model of UAV) unmanned air vehicle shall only be operated during the day.
          8. The Certificate holder is responsible for ensuring that their AMA membership remains valid and is in good standing.
          9. The (enter name/model of UAV) unmanned air vehicle shall continuously be operated within unaided visual line of sight of (enter name of UAV pilot) and (enter name of UAV observer) at all times.
          10. Notwithstanding the requirements of paragraph 602.14(2) (b) of the Canadian Aviation Regulations, the (enter name/model of UAV) unmanned air vehicle shall not be operated (including take-offs, landings and flight demonstrations) at a distance of less than 30 metres away from inhabited structures such as buildings, vehicles, vessels and other persons who are not associated with the operation.
          11. Throughout flight operations, the Certificate holder shall ensure that the (enter name/model of UAV) unmanned air vehicle is flown over areas that would permit a safe landing on the surface without hazard to persons or property in the event of any emergency requiring immediate descent.
          12. Flight of the (enter name/model of UAV) unmanned air vehicle over spectators is prohibited.
          13. The (enter name/model of UAV) unmanned air vehicle shall be operated in accordance with the weather conditions approved by the Contest Director (or Event Director – whichever title is appropriate).
          14. The (enter name/model of UAV) unmanned air vehicle shall be operated by (enter name of UAV pilot).
          15. The Certificate holder shall not require any person to operate the controls of the (enter name/model of UAV) unmanned air vehicle if either the person or the Certificate holder has any reason to believe that the person is suffering or is likely to suffer from fatigue so that they are unfit to perform their duties.
          16. No person shall operate the (enter name/model of UAV) unmanned air vehicle within eight hours after consuming an alcoholic beverage or while under the influence of alcohol or while using any drug that impairs the person’s faculties to the extent that the safety of the operation is endangered in any way.
          17. The Certificate holder shall report to this office, on the first working day following, details of any of the following occurrences:

            1. Injuries to persons requiring medical attention;
            2. Unintended contact between the (enter name/model of UAV) unmanned air vehicle and persons, livestock, vehicles, vessels or other structures;
            3. Unanticipated damage incurred to the air vehicle or other essential parts of the UAV system that renders it unfit for flight; and
            4. Any time the aircraft is not kept within the geographic and altitude limits as outlined in this SFOC.
          18. The Certificate holder shall not operate the (enter name/model of UAV) unmanned air vehicle following any of the occurrences listed in Condition (enter above condition #), until such time as this office approves its further operation.
          19. All persons connected with this operation shall be familiar with the contents of this Certificate.
          20. A copy of this Certificate and a copy of the application dated (enter date of application and appendices if appropriate) shall be on site any time the (enter name/model of UAV) unmanned air vehicle is in operation.
      Yours truly,

      Insert appropriate signature Block

      for Minister of Transport, Infrastructure and Communities

    9.3  Sample Authorization for MAAC Members

    1. Pursuant to section 603.67 of the Canadian Aviation Regulations, this constitutes your Special Flight Operations Certificate (SFOC) for the operation of the (enter name/model of UAV) unmanned air vehicle system as described in your SFOC application dated (enter application date and, if necessary, the amended application date).
    2. This Certificate is issued to (name as it appears on the on the application). It may be suspended or cancelled at any time by the Minister for cause, including failure on the part of the Certificate holder, its servants or agents to comply with the provisions of the Aeronautics Act and the Canadian Aviation Regulations (CARs). This Certificate is not transferable and is valid from (enter start date of the operation) until (enter end date of the operation) or until it is suspended or cancelled.
    3. This Certificate is valid for the operation of the (enter name/model of UAV) unmanned air vehicle for recreational purposes at (enter location where the flights are conducted, or make a statement such as: at MAAC approved sites).
    4. Nothing in this Certificate shall be held to relieve the Certificate holder from requirements to comply with the provisions of such Canadian Aviation Documents as may have been issued to him pursuant to the Aeronautics Act or the Canadian Aviation Regulations.
    5. Issued under the authority of the Minister pursuant to the Aeronautics Act, this document certifies that the Certificate holder is adequately equipped and able to conduct a safe operation, subject to the observance and performance by the Certificate holder of the following conditions:

      Information Note:
      It is anticipated that the following key conditions will apply to all operations, although there may be a need to amend the wording of the condition based on the operation.

    9.4  Key Conditions

    1. Except where otherwise referred to in this Certificate, the Certificate holder shall comply with the applicable provisions of the Aeronautics Act and the Canadian Aviation Regulations (CARs).
    2. The Certificate holder shall conduct the operation of the (enter name /model of UAV) unmanned air vehicle in a safe manner.
    3. The Certificate holder shall have subscribed for adequate liability insurance covering risks of public liability at the levels described in subsection 606.02 (8) of the Canadian Aviation Regulations for the period of the (enter name/model of UAV) unmanned air vehicle operation.
    4. The (enter name/model of UAV) unmanned air vehicle shall be operated in accordance with the Model Aeronautics Association of Canada Safety Code, dated May 11, 2006 and MAAC’s Giant Scale Safety Code, dated October 21, 2006 and MAAC’s Giant Scale Safety Code, dated October 21, 2006 (and where applicable, the Safety Guidelines for the (enter name of Fields) Field Operations).
    5. The Certificate holder shall adhere to the security plan for the selected area of operation in accordance with the data provided in (enter name of Certificate applicant) SFOC application dated (enter the application date and, if necessary, the amended application date).
    6. The normal and emergency procedures for the selected areas of operation shall be conducted in accordance with data provided in (enter name of Certificate applicant) SFOC application, dated (enter the application date and, if necessary, the amended application date) or as otherwise agreed upon between (enter name of Certificate applicant) and Transport Canada.
    7. The (enter name/model of UAV) unmanned air vehicle shall be operated at a maximum altitude not exceeding (enter altitude) above ground level (AGL).
    8. The Certificate holder is responsible for ensuring that their MAAC membership remains valid and is in good standing.
    9. The (enter name/model of UAV) unmanned air vehicle shall give way to manned aircraft.
    10. The (enter name/model of UAV) unmanned air vehicle shall only be operated during the day.
    11. The (enter name/model of UAV) unmanned air vehicle shall continuously be operated within unaided visual line of sight of (enter name of UAV pilot) and/or (enter name of UAV observer) at all times.
    12. The observer (enter name, if known) shall maintain constant communication with the UAV pilot (name if known) at all times.
    13. Notwithstanding the requirements of paragraph 602.14(2) (b) of the Canadian Aviation Regulations, the (enter name/model of UAV) unmanned air vehicle shall not be operated (including take-offs, landings and flight demonstrations) at a distance of less than 30 metres away from inhabited structures such as buildings, vehicles, vessels and other persons who are not associated with the operation.
    14. Throughout flight operations, the Certificate holder shall ensure that the (enter name/model of UAV) unmanned air vehicle is flown over areas that would permit a safe landing on the surface without hazard to persons or property in the event of any emergency requiring immediate descent.
    15. Flight of the (enter name/model of UAV) unmanned air vehicle over spectators is prohibited.
    16. The (enter name/model of UAV) unmanned air vehicle shall be operated in day VMC conditions or (enter weather minima or make a statement such as: with the flight visibility or ground visibility or aerodrome visibility and distance from cloud and minimum ceiling criteria as specified in the SFOC application) or where the SFOC application is only for flying at an event, enter “in accordance with the weather conditions approved by the Contest.
    17. The (enter name/model of UAV) unmanned air vehicle shall be operated by (enter name of UAV pilot).
    18. The Certificate holder shall not require any person to operate the controls of the (enter name/model of UAV) unmanned air vehicle if either the person or the Certificate holder has any reason to believe that the person is suffering or is likely to suffer from fatigue so that they are unfit to perform their duties.
    19. No person shall operate the (enter name/model of UAV) unmanned air vehicle within eight hours after consuming an alcoholic beverage or while under the influence of alcohol or while using any drug that impairs the person’s faculties to the extent that the safety of the operation is endangered in any way.
    20. The Certificate holder shall report to this office, on the first working day following, details of any of the following occurrences:

      1. Injuries to persons requiring medical attention;
      2. Unintended contact between the (enter name/model of UAV) unmanned air vehicle and persons, livestock, vehicles, vessels or other structures;
      3. Unanticipated damage incurred to the air vehicle or other essential parts of the UAV system that renders it unfit for flight; and
      4. Any time the aircraft is not kept within the geographic and altitude limits as outlined in this SFOC.
    21. The Certificate holder shall not operate the (enter name/model of UAV) unmanned air vehicle following any of the occurrences listed in Condition (enter above condition #), until such time as this office approves its further operation.
    22. All persons connected with this operation shall be familiar with the contents of this Certificate.
    23. A copy of this Certificate and a copy of the application dated (enter date of application and appendices if appropriate) shall be on site any time the (enter name/model of UAV) unmanned air vehicle is in operation.

      Yours truly,

      Enter appropriate signature block

      for Minister of Transport, Infrastructure and Communities

      Information Note:

      The following additional conditions may not be appropriate for all operations, therefore, use only the conditions that apply and delete the remainder. Also, there may be a need to impose conditions that have not been considered here.

    9.5  Additional Conditions

    1. The Certificate holder is responsible for coordination with the air traffic control agency responsible for supplying air traffic services for the airspace affected by the operation. Validity of this Certificate is contingent upon the Certificate holder coordinating with the air traffic service provider. and/.or
    2. (Enter name/model of UAV) unmanned air vehicle operators shall broadcast intentions on and monitor (enter appropriate frequency), at all times during flight operations. and/or
    3. The Certificate holder shall, prior to flight, contact the (enter name of air traffic agency) to issue a NOTAM.
    4. The (enter name/model of UAV) unmanned air vehicle shall not be operated over or within a built-up area of a city or town. or
    5. The (name/model of UAV) unmanned air vehicle shall not be operated within (enter distance) of any built-up area of a city or town.
    6. The (enter name/model of UAV) unmanned air vehicle shall not be operated (enter time or distance restrictions) near noise sensitive areas (such as churches, hospitals, parks and schools)

    10.0  CONTACT OFFICE

    Suggestions for amendment to this document are invited and should be submitted via the Transport Canada Civil Aviation Issues Reporting System (CAIRS) at the following Internet address:

    http://www.tc.gc.ca/CAIRS

    or by e-mail at: CAIRS_NCR@tc.gc.ca

    Manzur Huq
    Director, General Aviation