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    Transport Canada Compliance Requirements for SFOC–RPAS | CAR 903.01(a) | Operation of a RPA Having a Weight of More Than 25 kg

    Introduction

    In the rapidly evolving field of Remotely Piloted Aircraft Systems (RPAS), ensuring compliance with regulatory standards is paramount for safe and effective operations.  The Canadian Aviation Regulations (CAR) 903.01(a) mandate specific requirements for the operation of RPAS that include a Remotely Piloted Aircraft (RPA) weighing more than 25 kg.  This article outlines the comprehensive compliance framework required for obtaining a Special Flight Operations Certificate (SFOC-RPAS), detailing critical components such as the Concept of Operations (CONOPS) document, Specific Operational Risk Assessment (SORA), and various operational, safety, and technical requirements.  By adhering to these guidelines, RPAS operators can ensure their operations are conducted safely, mitigating risks to people, property, and other airspace users.

    RPAS Operation/Risk Assessment

    CONOPS Document

    • Document must describe, in detail, the purpose of the operation.
    • Covers the scope of the proposed operation, to include a detailed description of the operation and how the operation will take place.
    • A Concept of Operations (CONOPS) is a document which clearly defines and details the purpose of the system/operation intended for the RPAS. 
    • This includes a description of the operational aspects of the crew, RPAS system, Processes and Procedures, and the expected operational environment.

    Specific Operational Risk Assessment (SORA)

    • A Specific Operational Risk Assessment (SORA) is a methodology developed by the Joint Authorities for Rulemaking on Unmanned Systems (JARUS) to assess the risks associated with the operation of drones (unmanned aerial vehicles, UAVs) and ensure their safe integration into airspace FOR A SPECIFIC SITE.  
    • It is a comprehensive risk assessment process that helps drone operators and regulatory authorities evaluate and mitigate potential risks to people, property, and other airspace users.
    • The SORA process involves several key steps:
    1. Operational Parameters.  This involves describing the planned operation in detail, including the type of drone, its purpose, the operating environment, and any specific operational limitations or conditions.
    2. Initial Ground Risk Class (GRC) Determination.  This step involves evaluating the risk to people and property on the ground.  Factors such as the population density in the operating area, the size and weight of the drone, and the operational altitudes are considered to classify the ground risk.
    3. Initial Air Risk Class (ARC) Determination.  This step assesses the risk to other airspace users.  Factors include the type of airspace, the likelihood of encountering manned aircraft, and the operational procedures in place to avoid mid-air collisions.
    4. Specific Assurance and Integrity Levels (SAIL) Determination.  Based on the initial GRC and ARC, the SAIL level is determined.  The SAIL level indicates the level of robustness and stringency required for the operation.  Higher SAIL levels require more comprehensive safety measures.
    5. Operational Safety Objectives (OSO) Identification.  This step involves identifying specific safety objectives that must be met to mitigate the identified risks.  These objectives are tailored to the SAIL level and address various aspects such as the drone's technical capabilities, operator competence, and operational procedures.
    6. Mitigation Measures Implementation.  This involves implementing the necessary mitigation measures to achieve the identified OSOs.  Mitigations may include technical solutions (e.g., collision avoidance systems), operational procedures (e.g., pilot training and certification), and organizational measures (e.g., maintenance and safety management systems).
    7. Residual Risk Evaluation.  After implementing the mitigation measures, the residual risk is evaluated to ensure it is within acceptable levels. If the residual risk is deemed too high, either additional mitigations may be required, or the operation may be designated as not feasible.
    8. Review and Approval.  The completed SORA, along with supporting documentation, is reviewed by the relevant regulatory authority for approval.  Transport Canada assesses the thoroughness of the risk assessment and the adequacy of the proposed mitigations.
    • SORA is an iterative process, meaning that it may require revisiting and refining earlier steps based on new information or changes in the operational environment.
    • It is designed to be flexible and scalable, allowing it to be applied to a wide range of drone operations, from simple visual line-of-sight (VLOS) flights to complex beyond visual line-of-sight (BVLOS) missions.
    • By following the SORA methodology, drone operators can systematically identify and mitigate risks, ensuring safe and compliant operations.

    Company Operations Manual

    • The Company Operations Manual (COM) describes the company and procedures in compliance with the SORA SAIL level OSOs.
    • At the heart of your organization, an Company Operations Manual describes your operation and acts as the go-to resource to ensure everyone on your team can operate safely and efficiently together. 
    • Known by a variety of names such as Flight or General Operations Manual, a quality Company Operations Manual can improve everything from streamlining processes to onboarding new employees.  This is a standard requirement in manned/crewed aviation operations.

    Safety Plan

    • The Safety Plan for the proposed area of operation in compliance must detail how are you going to be proactively safe and not endanger Aviation Flight Safety of other aircraft or any person.
    • It must also detail the precautions that are in place to ensure public safety.  This is to include a set of instructions and procedures that outlines actions to be taken to identify the hazards and mitigate the risks and ensure safety to persons and property.

    Emergency Contingency Plan and Emergency Response Plan

    • This document must contain instructions and procedures that outline actions to be taken to address various types of emergency or abnormal situations in order to mitigate the impacts of the event on safety.  
    • This must describe the personnel, equipment & other resources available to respond to anticipated emergencies.  
    • Communication protocols must also be described with applicable first responder agencies and ATC that could be affected.
    • Detailed LOST LINK and FLY AWAY procedures shall be carefully planned for all route segments for all RPAS operations.

    Interest in the Public Good

    • The SFOC applicant must demonstrate how the proposed RPAS operation is in the interest of the public good.

    Risk Mitigation of Loss of Control of the RPA Trajectory

    • The applicant must demonstrate that it has implemented a risk mitigation of loss of control of the RPA trajectory (e.g. route, course or path, geo-fencing, etc.).
    • For flight operations at SAIL 3 and higher, the risk mitigation system needs to be 100% independent with the activation of the Flight Termination System at the worst possible time.
    • The risk mitigation system/procedure must be described in detail.

    RPAS Equipment/Capability

    RPAS Manufacturer Performance Declaration

    • The RPAS manufacturer must submit a performance declaration accepted by TC of the RPA above 25 kg operations to the applicable technical requirements in reference to the SORA SAIL level. 
    • The manufacturer declaration must include information about the model of the RPAS, including three-view drawings or photographs and a complete description of the aircraft, including performance, operating limitations and equipment.  
    • It must also provide any applicable certification of any parts from any manufacturer and any document supporting the airworthiness, reliability and safety of the RPAS.
    • Depending on the CONOPS and SORA, a declaration from the manufacturer might be required.
    • Supporting documents such as design characteristics, test plans, test cards, supporting data, maintenance program, etc. might also be required.

    Confirmation of Non-Modification of RPAS

    • The Applicant must provide a declaration confirming that the RPAS has not been modified from the manufacturer’s design and safety assurance declaration.

    RPAS Design Documentation

    • For a new RPAS design or in development, the Applicant must provide all supporting design development documents, tests cards, test plans, certifications, manufacturer’s declaration or flight authority as applicable, how the aircraft is kept airworthy, etc. Refer to CAR 901.76 to 901.79

    RPA Identification

    • The Applicant must identify in detail how the RPA’s colour, paint scheme or illumination make the aircraft highly visible to other people on the ground and other airspace users (from above and from below) when in flight.
    • Describe the Painting and/or Strobe/Anti-Collision Lighting in detail.

    Description of Command & Control (C2) System

    • The Application must provide a complete description of the Command & Control (C2) system, including frequencies and radio licences as required.

    Transfer of Pilot Control

    • If the RPA is to be handed over from one control station to another, the Application must describe the system/procedure in detail required for the handover.

    Description of Payload Systems

    • The Application must provide a complete description of the type and capabilities of all applicable payload systems for the RPAS operations.

    Confirmation of Fuel/Energy Reserves

    • The Applicant must submit a detailed procedure which confirms that the RPA pilot will ensure, before commencing a flight, if there is an amount of fuel/energy sufficient to allow the RPA to safely complete the planned flight with a reserve of 25% of the total planned flight time or 30 minutes whichever is lesser.

    RPA System Maintenance Instructions

    • The Applicant must provide details of the instructions regarding the maintenance of the system and a description of how that maintenance and serviceability will be performed before flight
    • For example, the Application must provide the following as applicable:
      • Maintenance manual/instructions that will be used (e.g., name, revision or date)
      • Maintenance schedule
      • Primary parts description (parts list/catalogue/limited life parts), and
      • Technical / Maintenance Logs (at time of SFOC application).
    • The Applicant must also provide details of the person responsible for maintenance and/or organization designated to perform the maintenance:
      • Identify person who will maintain or supervise the maintenance program, and
      • Provide detail/training.

    RPAS Maintenance Manual

    • The SFOC-RPAS Applicant must submit an RPAS Maintenance Manual (RMM) from the manufacturer OR produce an in-depth proprietary maintenance manual one if it is not available.

    The Applicant/Operator/Pilot

    Detailed Operational Plan

    • The Application must describe in detail how the RPAS operation is to be carried out.
    • It must detail the maximum altitude, maximum expected speeds, maximum operational weight, and maximum possible linear distances in the event of a flight interruption.
    • Must include a site survey of the proposed mission.

    RPAS Operating Manual (ROM)

    • The SFOC-RPAS Applicant must submit and have an RPAS Operating Manual (ROM) immediately available to crew members during operations.

    Training Manual for the RPA Crew (TMR)

    • The SFOC-RPAS Applicant must also submit a Training Manual for the RPA crew (TMR) (for Pilots, VOs, POs, Maintainers, etc.).

    Accountable Executive for Compliance

    • Does the operation have an accountable executive appointed by the RPAS operator who is responsible to ensure compliance and to ensure the Internal Process Bulletin (IPB) 2021-03 requirements for above 25 kg RPA operations compliance.
    • The Applicant must provide the names, certificates, licences, permits and qualifications of the crew members, including the pilots and visual observers, and the RPAS maintenance personnel, as applicable.
    • Additional pilot qualifications may be required, as determined the RPA operational weight and area of operation.

    Pilot-in-Command Credentials

    • The Applicant must provide confirmation the pilot(s) is qualified as RPA pilot for advanced operations and meet recency requirements, and as per the SORA-required SAIL Level.
    • The pilot must be trained and qualified prior to commencing operations under the Requested SFOC.

    Fitness of Crewmembers

    • The Applicant must document and implement a procedure which will ensure that Crew Members are fit to act as a crewmember of a remotely piloted aircraft system.

    Weather Minima

    • The operator must designate weather minima for the VLOS operation and how minimum weather conditions can be ensured during operations onsite as in the applicant’s Standard Operating Procedures (SOP).

    Separation and Collision Avoidance

    • The Applicant must provide a detailed description of separation and collision avoidance capability and procedures for the RPA Pilot and Visual Observer (SOP).
    • The separation and collision avoidance procedures must detail how the RPA pilot will not operate in such proximity to another aircraft as to create a risk of a collision, and detail how the RPA pilot will give the right of way to aircraft, airships, gliders and balloons while operating.

    Normal and Emergency Procedures

    • The Applicant must provide detailed normal and emergency procedures (SOP).

    Air Traffic Control Services Coordination/Communication Process

    • The Application must provide a robust description of air traffic control services coordination/communication process and collision avoidance procedures.

    Radio Communication Technology

    • The operator must provide the radio communication technology, as required by the class of airspace, ATC or CARs regulations, and sufficient radio communication equipment to permit the pilot to conduct two-way communications on the appropriate frequency with other airspace users and ATC appropriate for the class of airspace or regulation, with redundancy.

    Proof of Insurance

    • The operator must submit proof of valid and adequate liability insurance for the operation covering risks of public liability at the appropriate level.

    RPAS Accident and Incident Reporting Procedures

    • The Applicant must declare its RPAS Accident and Incident Reporting procedures (SOP).

    Summary

    Navigating the regulatory landscape for operating RPAS over 25 kg necessitates a thorough understanding and meticulous application of the requirements set forth by CAR 903.01(a).  From the initial risk assessment stages outlined in the SORA methodology to the detailed operational plans and safety procedures, every aspect of the operation must be diligently planned and documented.  Compliance with these requirements not only ensures the safety and integrity of RPAS operations but also fosters public trust and regulatory approval.  By fulfilling these comprehensive guidelines, operators can achieve safe, efficient, and legally compliant RPAS operations, contributing positively to the advancement of unmanned aerial technology.

    How We Can Help You

    Having been designated by Transport Canada as the first and only RPAS operator in Canada to legally operate DJI FlyCart 30 flight operations Canada-wide, DCS has the necessary expertise to prepare successful Transport Canada SFOC applications for third-parties.  We are able to leverage our experience and ensure your new application reflects both compliance with regulatory requirements and lessons learned from our previous application process and regulatory compliance.

    Leveraging Successful SFOC Experience for Third-Party Applications

    Having successfully navigated the SFOC application process for your own RPAS operations, we are well-positioned to assist a third-party in securing their certification. This section outlines how to leverage your experience and insights to ensure a robust and compliant application for a third-party operator.

    Translating Experience into Best Practices

    Drawing on our successful SFOC application, we can implement best practices that have proven effective. These include comprehensive documentation, meticulous risk assessments, and robust safety protocols. We ensure that our third-party applications reflect these best practices to meet and exceed regulatory expectations.

    Customized Operational and Risk Assessments

    Each RPAS operation is unique, requiring tailored operational plans and risk assessments.  We utilize our extensive operational experience to customize the CONOPS document and SORA for our clients’ specific operational environments. We highlight any unique aspects of your operations and ensure that all potential risks are thoroughly assessed and mitigated.

    Detailed Documentation and Supporting Evidence

    We provide detailed and thorough documentation, similar to what was successful in our own application. This includes:

    • Concept of Operations (CONOPS).  We clearly define the purpose, scope, and operational details of the third-party’s RPAS operations.
    • Specific Operational Risk Assessment (SORA).  We conduct a comprehensive risk assessment, detailing operational parameters, ground and air risk classes, mitigation measures, and residual risk evaluations.
    • Company Operations Manual (COM) and Safety Plans.  We develop and ensure our client’s COM and safety plans are detailed, reflecting proactive safety measures and public safety considerations.
    • Emergency Contingency and Response Plans.  We provide clear, actionable plans for various emergency scenarios, ensuring readiness and coordination with first responders and ATC.

    Technical and Maintenance Documentation

    We ensure that third-party applications include all necessary technical and maintenance documentation:

    • RPAS Manufacturer Performance Declaration.  We include comprehensive details about the RPAS model, performance, and safety certifications.
    • Maintenance Manuals and Logs.  We provide detailed maintenance instructions, schedules, and logs to demonstrate ongoing airworthiness and reliability of the RPAS.

    Operational and Training Manuals

    We incorporate detailed operational and training manuals to ensure our client’s air crew is fully prepared and qualified. 

    • RPAS Operating Manual (ROM).  We ensure the ROM is comprehensive and immediately accessible to the crew during operations.
    • Training Manual for RPA Crew (TMR).    We include a detailed training manual covering all aspects of RPAS operation for pilots, visual observers, and maintenance personnel.

    Accountability and Compliance

    DCS ensures that third-parties have a designated accountable executive responsible for compliance with all regulatory requirements.  We provide detailed credentials of the pilot-in-command and other crew members, demonstrating their qualifications and readiness for the operation.  As a Transport Canada TP15263-compliant RPAS training provider, we are able to provide cutting-edge RPAS pilot training for your employees to bring them up to rigourous Transport Canada standards and requirements.

    Separation, Collision Avoidance, and Communication

    We detail the procedures for separation, collision avoidance, and communication with ATC:

    • Separation and Collision Avoidance Procedures.  We ensure these procedures are robust and clearly defined.
    • Air Traffic Control Coordination.  We provide a detailed communication process with ATC and other airspace users.
    • Radio Communication Technology.  We ensure the third-party has the necessary communication technology and redundancy for safe operations.  DCS is an accredited examiner for Innovation, Science and Economic Development Canada (ISED) and the Restricted Operator Aeronautical Qualification (ROC-A) airband radio license. 

    Insurance and Reporting Procedures

    We ensure that our clients have appropriate levels of insurance coverage for their operations, including proof of adequate liability insurance and a clear RPAS accident and incident reporting procedure:

    • Proof of Insurance.  We ensure the third-party has valid and sufficient liability insurance.
    • Accident and Incident Reporting.  We provide a detailed SOP for reporting any incidents or accidents, ensuring timely and accurate communication with regulatory authorities.

    Conclusion

    By leveraging our company’s successful SFOC experience, we are able to guide our clients through a streamlined and effective application process, ensuring their operations are compliant, safe, and well-documented.  This collaborative approach not only helps the third-party achieve certification but also contributes to the overall safety and integrity of RPAS operations in the shared airspace.  The practical application of our cumulative experience ensures that third-party applications for our clients are thorough, compliant, and reflect the highest standards of safety and operational integrity.

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