New exemptions to the requirement of having an SFOC for commercial operations in Canada

  • News
  • by Marc Dubrule
  • 12-22-2016

Transport Canada has released the new exemptions to the requirements of operating a UAV under an SFOC in Canada.  These exemptions are an update to those previously in effect to December of 2016, and will remain in effect until no later than December 31, 2019

UAV technology is still short of allowing a full integration into the Canadian airspace system. As Transport Canada has a mandate to protect airspace stakeholders, as well as the public, these exemptions were authorised by the Minister of Transport to allow non-recreational UAV users to operate in areas of low-risk to the general public and airspace users.

An operator with a current or recent SFOC, will find the conditions required to exercise the exemptions run parallel to a good deal of conditions required by an SFOC.  Although the exemptions are not a licence to operate a UAV in an unrestricted fashion, a UAV operator that flies repeatedly over the same site, which is located well outside of populated areas, may find their operation can easily fit into the requirements of the exemptions.

The exemptions are divided for 2 categories of UAVs; the first section applies to non-recreational UAV operators, operating UAVs of 1 KG or less,  and the second category applies to UAV operators operating UAVs greater than 1 KG to 25 KG.  While nearly all of the conditions are identical to both weight categories of UAVs, the table below highlights most of the differences;


1 KG and less Greater than 1 KG, up to 25 KG
Maximum distance from operator VLOS to a maximum of 1/4 NM

VLOS to a maximum of 1/2 NM

Minimum distance from built up areas Not over or within 3 NM
Minimum lateral distance from non-participants 100 feet 500 feet
Airspace type Class G uncontrolled Class G uncontrolled
Minimum distance from aerodromes in CFS & WAS 5 NM 5 NM
Minimum distance from unregistered aerodromes and heilports 3 NM 3 NM


The included map (generated from OpenStreetMap data) shows an example of aerodrome and heliport density around Edmonton, Alberta.  The shaded areas show either a 3 NM or 5 NM ring around an aerodrome, as applicable.  It should be noted that this map does not show any of the controlled airspace, of which is a concern to UAV operators, as the exemptions are only authorized for Class G uncontrolled airspace.  The purpose of the map is to show that an operator needs to move a long way out of an urban area, to get far enough away from both built-up areas, and aerodromes, in order to operate under the exemptions.

Highlights of other requirements to operate under the exemption are;

  • Minimum age of 18 (or 16 for academic purposes, under the supervision of an adult).
  • Requirement of subscribing to liability insurance.
  • Pilot to be fit to perform duties.
  • 8 hours (or more) free from drugs or alcohol.
  • Permission required from the property owner for the use of take-off and recovery points.
  • Compliance to all Canadian laws that may apply to the operation.
  • Site survey completed.
  • Operator will produce all relevant documents to a peace office or Transport Canada inspector, upon request.
  • Only operations in Class G uncontrolled airspace.
  • Daylight hours.
  • No higher than 300' AGL.
  • No area of forest fire fighting activities.
  • No flights over or within open air assemblies or sporting events.
  • Notification to the Minister of Transport for operations.
  • Training standards required for the UAV pilot.

This list, combined with the table outlining some differences in the categories of exemptions, is not exhaustive.  For those operators interested in applying the exemptions to their operations, familiarity with all conditions is required.  The document is easy to read, and there is plenty of guidance material included with each condition.