The “Rise” of Unmanned Aerial Vehicles (UAVs) in Canada:An Analysis of Special Flight Operation Certificates(SFOCs) from 2007 to 2012

Scott Thompson, Alana Saulnier

Canadian Public Policy, Volume 41, Number 3, September / septembre2015, pp. 207-222 (Article)

Published by University of Toronto Press

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The ‘‘Rise’’ of Unmanned Aerial Vehicles(UAVs) in Canada: An Analysis of Special

Flight Operation Certificates (SFOCs)from 2007 to 2012

SCOTT THOMPSON AND ALANA SAULNIERDepartment of Sociology, Queen’s University, Kingston, Ontario

Dans cet article, nous examinons les politiques et la reglementation qui concernent les vehicules aerienssans pilote (UAV) ainsi que les tendances en matiere d’utilisation de ces vehicules. Grace a une analysequantitative de contenu menee a partir de tous les certificats d’operations aeriennes specialisees emis parTransport Canada de 2007 a 2012, nous decrivons, a l’aide de statistiques, la progression de l’utilisationd’UAV et les types d’usages que l’on fait de ces vehicules. Nous avancons que la combinaison de laprogression de l’utilisation d’UAV et le manque de clarte qui entoure la surveillance des UAV constitueune occasion a saisir pour evaluer attentivement les nouveaux defis lies a la securite et au respect de lavie privee qui se posent, afin de mettre en place des lois et des reglements eclaires et judicieux.

Mots cles : vehicules aeriens sans pilote, certificat d’operations aeriennes specialisees, Transport Canada,respect de la vie privee, securite, drones

This article reviews Canadian UAV policy, regulation, and usage trends. Through a quantitative contentanalysis conducted on all UAV Special Flight Operation Certificates (SFOC) issued by Transport Canadabetween 2007 and 2012, this article charts the expansion of UAV use and the nature of this usage throughkey statistics. We argue that in combination, the rise of UAV use and the opaque nature of UAV oversightconstitute the formation of a social moment in Canada in which new challenges regarding safety andprivacy need to be carefully considered in the process of producing informed and, thereby, thoughtfullegislation and regulation.

Keywords: unmanned aerial vehicles, Special Flight Operation Certificates, Transport Canada, privacy,safety, drones

IntroductionThe oversight of unmanned aerial vehicles (UAVs)through the issuance of ‘‘Special Flight Operation Certifi-cates’’ (SFOCs) by Transport Canada is currently recog-nized as the primary process for maintaining safety andprotection of privacy rights of the Canadian public inregards to UAVs1 or other craft more commonly knownas ‘‘drones’’ (CBC News 2012). As Michael Toscano, thepresident and CEO of the Association for UnmannedVehicle Systems International explains,

Transport Canada has to approve any utilization orauthorization of any of these unmanned systems, sothere is a process you go through . . . you can’t just flythese things, you have to have a mission in mind, you

have to have a purpose for doing this . . . someonewent to the authorities and got the right permission.(CBC News 2012)

In this way, the issuance of SFOCs is used to publicallydemonstrate the validity of UAV usage, as well as estab-lish Transport Canada as an overseer of regulated UAVflights.

As was noted by the spokesperson for UnmannedSystems Canada in 2010, ‘‘Canadian companies are al-ready using unmanned systems in many roles and withreal business benefits,’’ with Transport Canada’s SFOCscited as ‘‘be[ing] a great enabler to the unmanned air-craft (UA) community’’ (Canadian Centre for UnmannedVehicle Systems [CCUVS] 2010, 20). When asked to

doi:10.3138/cpp.2014-038 8 Canadian Public Policy / Analyse de politiques, September / septembre 2015

explain what exactly it is that UAVs are currently beingused for in Canada, both government and industry repre-sentatives employ a common mantra of the three ‘‘Ds’’:dull, dirty, and dangerous work (Holman 2013; CBCNews 2012; CCUVS 2010; Finn and Wright 2012;Unmanned Systems Canada 2012, 2014). For example,as the Canadian Centre for Unmanned Vehicle Systems(a public private partnership devoted to the develop-ment of UAV technology centred in Alberta) explains,‘‘the most familiar’’ use of UAVs is as a tool designedto ‘‘tak[e] people out of dull, dirty and dangerousjobs’’ (2010, 20). As an extension of this focus, TransportCanada provides a plethora of examples of potentialUAV applications, from scientific research to fire fight-ing and management (Transport Canada 2014c). How-ever, while clear and detailed regulations have beendeveloped to govern certain forms of UAV usage inCanada, the extent to which oversight is administeredis unclear. For instance, Canada’s flight regulatoryagency (Transport Canada) maintains that it holds noelectronic records regarding the issuance of SFOCs, orany statistics regarding UAV flights in Canada as awhole, limiting fact-based assertions on UAV usagetrends.2 For example, the claim that UAV flights havebeen restricted primarily to tasks related to the three Dsis one that, up until now, has been exceedingly difficultto confirm or refute with anything other than anecdotalevidence.

Drawing on a complete record of SFOCs issued byTransport Canada between 2007 and 2012,3 we establishfour key points. First, we explore the accessibility andtransparency of records kept by Transport Canada re-garding the regulation of UAVs. Second, we chart theexpansion of UAV applications in Canada over thistime period—demonstrating, among other key statistics,the primary technologies, purposes, public and privateinstitutions, and regions in which these systems havebeen put to work as well as shifts in the SFOC issuanceprocess. Third, we demonstrate that the adoption andexpansion of this technology are opening up Canadianairspace to greater UAV usage. Finally, we argue thatthe combination of these three factors has led us to theforefront of a social moment in Canada regarding UAVs.This moment is characterized by new challenges to safetyand privacy that need to be carefully considered in theprocess of producing informed and, thereby, thoughtfulregulation of UAV usage. In short, in this article we pro-vide a quantitative overview of UAV usage in Canada,addressing the vital questions of who, what, when,where, and why. In doing so, we produce a longitudinalempirical understanding of UAV technology in Canadabetween 2007 and 2012, contributing crucial data to aca-demic and public debates. To situate our contributionwe provide an overview of historical developments inCanadian UAV legislation, before presenting an integrated

results and discussion of the content analysis performedon the SFOCs issued by Transport Canada. Followingthis analysis we dedicate the remaining portion of thearticle to considering the immediate future of UAV ap-plications and implications in Canada.

Historical Developments of UAVs in CanadaGlobal regulation and legislation. The very first

UAV regulation to be applied in Canada stemmed froman international agreement—the Convention on Interna-tional Civil Aviation, signed in Chicago on 7 December1944. Specifically, Section 8 limited the flying of UAVsby asserting that ‘‘[n]o aircraft capable of being flownwithout a pilot shall be flown without a pilot over theterritory of a contracting State without special author-ization by that State and in accordance with the termsof such authorization’’ (International Civil AviationOrganization 1944). This legislation set the precedentthat UAVs should be segregated to specified airspaceand required nation-state authorization for each indi-vidual flight.

In 2002, the World Radiocommunication Conference(WRC-12) met to discuss the expansion of UAV flightsbeyond ‘‘segregated airspace where separation fromother air traffic can be assured’’ (Organization of AmericanStates 2012). As a result, Resolution 421 was passed aspart of their 2007 meeting, placing the matter of UAVson their agenda and, in particular, calling for an allo-cated bandwidth spectrum on an international scale. Aswell, an array of safety, operator and craft standardswere discussed. In a related area of concern, the Interna-tional Civil Aviation Organization (a United Nationsspecial agency) met in April 2005 to address the issuethat

current UAVs are unable to integrate safely and seam-lessly with other airspace users, the reasons for whichare twofold—the inability to comply with critical rulesof the air, and the lack of Standards and RecommendedPractices (SARPs) specific to UAVs and their support-ing systems. (International Civil Aviation Organization2011, 3)

The agency was reacting to pressures from industryand member states regarding the adoption of UAVs inseveral civil aircraft applications. The feelings expressedwere that the development of a non-binding ‘‘guidancedocument’’ with shared definitions of technological needsand applications could ‘‘serve as a focal point for globalinter-operability and harmonization’’ (International CivilAviation Organization 2011, 1).

In 2011, Canada and the United States entered into apartnership to develop ‘‘rulemaking for small UAVs,’’dubbed the Regulatory Cooperation Council (RCC). Thisregulatory body was designed to ‘‘alig[n] future regula-tory approaches’’ regarding UAVs. Discussions under

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the RCC’s Joint Action Plan have focused on the areasof: ‘‘airspace integration issues, aircraft certificationstrategies, operator certificates requirements, privacyissues related to UAVs, Arctic UAV activities, firstresponder use of UAV systems, and personal licensingrequirements’’ (Transport Canada 2013). Beyond thisinternational partnership, Transport Canada has alsoplayed an active role in the International Civil AviationOrganization (ICAO). The ICAO has set a mission ofactively working toward the ‘‘full integration of UAVsystems into non-segregated airspace between 2023–2028’’ and has been developing a ‘‘guidance manual’’ re-garding UAV flight regulation, anticipated to be presentedin late 2014. However, as of the writing of this article,there were no international agreements or standardsregarding UAV flights outside of segregated areas moni-tored by individual states.

Canadian regulation. Legislation specific to Canadafirst emerged in 1996 as the Canadian Aviation Regula-tions (CAR) touched on UAV flights; however, 2003 sawthe oversight duties regarding UAVs shift to TransportCanada, with the digital spectrum required to transmitdata to and from UAVs falling under the managementof Industry Canada.4 The Canadian Aeronautics Act,Canadian Aviation Regulations (SOR/96/433) section101.01, set the operational definition of an ‘‘unmannedair vehicle’’ as ‘‘a power-driven aircraft, other than amodel aircraft,5 that is designed to fly without a humanoperator on board.’’ The legislation requires all vehiclesthat fit this definition to obtain a Special Flight Opera-tion Certificate, or for the vehicle to be operated by per-sonnel who hold an Air Operator Certificate (AOC)—both of which are issued by Transport Canada (Section602.41). Prior to November 2014, the regulations requiredan SFOC to be issued for each ‘‘operation,’’ or in the caseof an AOC holder, to have each operation amended tothe original certificate. Initially each UAV flight requiredits own SFOC, though section 5.1 of the Transport CanadaStaff Instructions (Transport Canada 2008) did allow forthe issuance of non-site-specific ‘‘long term authority[ies]’’for a period of up to one year in those cases where ‘‘ahistory demonstrating that the operations have beenconducted in a safe manner’’ exists (Transport Canada2008, 5.1[2]). These regulations, also after 2014, explainthat subsequent SFOC applications by these provenactors ‘‘should be able to be expedited’’ for quicker proc-essing (sec. 623.001, 5.1[2]). This process has been formal-ized under the 2014 second edition of Transport Canada’sStaff Instructions (Transport Canada 2014f). UAV opera-tors are now categorized as either ‘‘Compliant Operators,’’whose applications are expedited and granted ‘‘greatergeographical flexibility’’ and ‘‘longer SFOC validity peri-ods,’’ or ‘‘Restricted Operators,’’ whose applications are‘‘granted fewer privileges,’’ because they are ‘‘unable orunwilling to meet the criteria to become a Compliant

operator’’ ( sec. 7.2[1][a-b]). However, all initial applica-tions require detailed information on the operator, UAV,and flight plan to receive approval.

The Canadian Aviation Regulations (CAR) legisla-tion decrees that all UAV flights necessitating an SFOCrequire the applicant to provide 11 key pieces of infor-mation: (1) the name of the applicant; (2 and 3) thename and contact information of the flight operationmanager; (4) the type and purpose of the operation; (5)date and times of the proposed flight; (6) data regardingthe aircraft; (7, 8, 9, 10) information pertinent to securityand safety plans; and (11) details on how the operationwill be carried out, including the flight path (CanadianAviation Regulations SOR/96/433 sec. 623.65[d][3][a-k]).As well, section 606.02 establishes the need for adequateinsurance to cover any public liability. Furthermore,additional regulations come into place if the UAV flightis planned to take place within an urban or populatedarea (see Lt.-Gen. Semianiw 2012). Changes to policy inNovember 2014 have worked to formalize the definitionof ‘‘built-up areas’’ and call on the Transport Canadastaff to develop additional site-specific SFOC conditionsto mitigate the specific risks related to: (a) airspace con-siderations; (b) risk of radio frequency interference; (c)distances to people and property; (d) security; (e) munic-ipality bylaws; (f ) urban meteorological conditions; and(g) ability to maintain a line-of-sight with the aircraft(Transport Canada 2014f, sec. 6.20[6]).

New regulations adopted 26 November 2014 alsoestablish an exemption from SFOC requirements forUAVs under 25 kg (Transport Canada 2014b, 2014d).Although this exemption works to deformalize the rela-tionship between Transport Canada and UAV operatorssomewhat by eliminating the need for SFOCs for certainUAVs, it does not remove all restrictions and documen-tation requirements of flights. UAV operators of craftbetween 2 and 25 kg, even under this exemption, arerequired to follow 58 conditions,6including: 18-year ageminimum; attaining sufficient liability insurance; opera-tional restrictions (e.g., flying only during daylight hours,operating at or below 300 feet, remaining at least fivenautical miles away from the centre of built-up areas7);and successfully completing a pilot ground school pro-gram8 (Transport Canada 2014b). Like SFOC holders,those flying under this exemption are still required tonotify Transport Canada in writing, before the com-mencement of any operation, of key flight informationof ‘‘their name, address, telephone number and e-mail;the model of UAV(s) being operated including serialnumber(s), where appropriate; the type of work beingconducted; and the geographic boundaries of the opera-tion,’’ in addition to retaining copies of ‘‘proof of liabilityinsurance; name, address and telephone number of theUAV operator; and a copy of the UAV system operatinglimitations’’ (Transport Canada 2014b).

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The requirements placed on regulated UAV users toprovide these pieces of information provide a wealth ofdata that can be used to chart UAV usage trends. Whilewe present most of these statistics in the Results section,we present overall issuance rates here to frame ourintroduction to some core topics of focus. Specifically,between 2007 and 2013, 1,563 SFOCs were issued byTransport Canada, with a rise in the number of certifi-cates granted annually from 44 in 2007 to 229 in 2012,and to 945 in 2013 (see Table 1).9

However, the increased use of UAVs has prompted avariety of interested parties to take greater note of thecapabilities of these craft, leading to not only greaterusage but also inquiries into concerns such as trans-parency and oversight in regulation, as well as infringe-ments on safety and privacy.

Oversight and transparency. Although TransportCanada has specified SFOC conditions that regulate theuse of UAVs, the extent to which these conditions areactively monitored is questionable. Transport Canadacurrently does not maintain digital records of issuedSFOCs, nor does it have a record of all UAV flights inprogress. Instead, the task of record keeping (and, as aresult, to some extent oversight) falls to regional admin-istrators.10 However, there is significant variation inregional applications of policy as well as a general lackof transparency regarding the details of UAV flights inCanada. Specifically, we are aware that there is variationin: flight log reporting; regional administrative interpre-tations of definitions outlined in federal legislation; andprocessing procedures used for applications.

In several regions flight logs are required to be sub-mitted to Transport Canada in the year following theflight(s) as part of the process of renewing SFOCs. Inother regions, however, there are no such requirements,and, as such, no accurate record of the actual numberor exact purpose of UAV flights exists or is turned overto the primary regulating agency, Transport Canada(Transport Canada Access to Information and Privacy

Department 2014). This lack of records amounts to alack of administrational oversight, as even the regulatorsof UAV flights do not know when flights are takingplace and, in the case of ‘‘blanket SFOCs’’11—SFOCsissued in defined locations as large as ‘‘all of Ontario’’and for operational periods of up to three years (Trans-port Canada 2008, sec. 623.001[2] sec. 7.2[1][a], 7.2[2],7.4[1])—even where exactly these flights are takingplace. What is particularly concerning in this regard isthe lack of preemptive knowledge of specific UAV flighttimes and locations, a situation that would not beacceptable for traditionally piloted aircraft and a con-cern that will only become greater as UAV technologybecomes more accessible and applicable to a growingaudience.

A similar lack of consistency can be seen in theregional differences of definitional interpretations. Forinstance, before November 2014, what constituted a‘‘built-up area’’ had been applied differently withinTransport Canada’s five regions. For example, Quebecwas the only region to deny all flights ‘‘within built-upareas’’ based on pre-2014 legislative guidelines (Trans-port Canada 2014e). Likewise, the option to ‘‘fast-track’’applicants has been broached in Transport Canada regu-lations in the form of ‘‘expedited processing’’ for ‘‘provenactors’’; yet, the prerequisites to demonstrate provenactor status as well as the details of an expedited processhad been left undefined. As such, the fast-tracking ofSFOC applications had been left to the discretion of theregional level. Expedited processing has been put intoplace for some institutions—for example, the Royal Cana-dian Mounted Police have received fast-tracked SFOCswithin Transport Canada’s Prairie and Northern region(PNR) (Transport Canada 2014e). In addition, 2014 policynow distinguishes compliant individuals and organiza-tions through the category of ‘‘Compliant Operator Ap-plication’’ SFOCs; how exactly this status is achievedremains somewhat nebulous—it is defined only as anapplication having ‘‘demonstrate[d] that they have a com-pliant organization with qualified personnel operating acompliant small UAV within VLOS in accordance with aset of criteria’’ (emphasis added, Transport Canada 2014f,sec. 7.2[1][a]). Additionally new policy is sometimesunclear, adopting terms such as ‘‘etc.’’ in their specificrequirements for flight record documentation (sec.6.28[3][a]).

Safety and privacy concerns. Safety concerns asso-ciated with UAV usage include their potential to interferewith the airspace of other flying crafts, as well as theircapacity to crash in populated areas. A primary con-sideration in this regard is the distribution and regula-tion of bandwidth for flights. The technological designof UAVs requires the transmission of sensor data totheir operators by drawing on satellite or ground-basedtowers; as such, a specified and unchanging band of

Table 1: SFOCs Issued by Transport Canada by Year 2007–

2013

Year Issued N % of total

2007 44 (�/�%) 2.82

2008 64 (+20/45%) 4.09

2009 66 (+2/3%) 4.22

2010 66 (�/�%) 4.22

2011 149 (+83/126%) 9.53

2012 229 (+80/54%) 14.65

2013* 945 (+716/313%) 60.46

Source: Authors’ compilation from Transport Canada ATIP Requests

files A-2012-00239, A-2012-00240, A-2012-00241, A-2012-00242,

A-2012-00243, A-2012-00244. *Only the total number of UAV

flights isavailable for this year (see Transport Canada 2014e).

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radio spectrum is required for UAV flights. WithinCanada the spectrum is highly regulated, and the fre-quencies of 90 MHz and 2.4 GHz have been allottedto ‘‘unlicensed’’ UAV flights involving small ‘‘off-the-shelf’’ consumer craft which are capable of dealing withfrequency interference.12 For larger UAVs that require‘‘command and control’’ capabilities free of outside inter-ference, a license or Letter of Authority (LOA) needs to begranted from Industry Canada. These licenses and letterslegally assert that an exclusive portion of the spectrumhas been dedicated to a particular UAV or operator tokeep that frequency free from interference. This is neces-sary since ‘‘any emissions in the band can cause harmfulinterference to the [UAV] equipment, resulting in in-accurate data, temporary loss of signal, or even loss ofcontrol of an UAV’’ (RCMP 2009, 4). In addition, In-dustry Canada also provides specific ‘‘developmentallicenses’’ for commercial UAV development in Canada,allowing operators to have exclusive use of a portion ofthe spectrum for a given period.13 In November 2014,SFOC requirements were expanded to require operatorsto obtain a Restricted Operator Certificate–Aeronautical(ROC-A) from Industry Canada as a means of ensuringthat they are sufficiently proficient in operating radio-telephone equipment and possess a general knowledgeof operating procedures and regulations relating to radio-telephones as well as the content of the Canadian Radio-communications Act for the reason that UAV operatorsare now required to be able to contact other aircraft bymeans of radiocommunication technologies (TransportCanada 2014b; Transport Canada 2008, sec. 6.12). AsUAV flights exponentially grow the extent to whichthis bandwidth distribution and regulation strategy willremain feasible will need to be carefully considered.

On a less technical front, legislation governing suc-cessful SFOC applicants typically requires that UAVsnot be flown above 400 feet in an effort to regulate (or,more specifically, avoid) UAVs coming into contact withpiloted aircraft. However, there have been incidents ofUAVs violating the maximum height or airspace restric-tions imposed by Transport Canada (Transport Canada2014a). In many cases these flights are attributed tohobbyists or amateurs, though Transport Canada’s owninvestigations of complaints have identified at least fivenon-hobbyist violators of SFOC regulations since 2004(Transport Canada 2014a). For instance, violations haveincluded unregulated flights over a mining site in 2006,a water-based crash of a UAV being used to film awakeboarding competition in 2011, and a violation ofairspace at the 2012 Grand Prix opening in Montreal(Transport Canada 2014a). Although all reported vio-lations are small in number, some included relativelyserious infractions, such as entering the restricted air-space of a British Columbia airport in 2004, posing signif-icant risks to public safety. For the most part, complaints

received by Transport Canada were resolved with theindividuals and companies involved by informing theassociated parties of legislation restrictions and request-ing that the appropriate certifications be acquired; in noinstances between 2004 and 2013 were fines applied toSFOC-holding UAV operators, while in 2014 all 12 ofthe fines related to UAV use were issued only withinthe province of Quebec (Transport Canada ATIP RequestA-2014-00283; CBC News 2015).

While public safety is a central concern associatedwith inquiries into the changing nature of Canadian air-space through the increased presence of UAVs, attentionto privacy-related concerns is another prominent featurein discussions of domestic UAV usage. In contrast withstatements from industry stakeholders regarding theoversight that SFOCs offer in regards to privacy issues,the standard SFOC application does not inquire intowhat ways privacy concerns might be impacted by therequested UAV flight(s) or require any documentationin this regard, nor did the word ‘‘privacy’’ appear beforeNovember 2014 within the Transport Canada Staff Instruc-tions, which is used to inform evaluations of SFOC ap-plications. The second edition of Transport Canada’sStaff Instructions (Transport Canada 2014f), the SFOCcover letter, and an advisory circular (AC 600-002 2014)directed to operators as of November 2014 do now notea need to comply with The Charter of Rights and Free-doms; Criminal Code of Canada; Privacy Act; PersonalInformation Protection and Electronic Documents Act;Customs Act; Trespass Act; Radiocommunication Act;Environmental Protection Act; National Parks AircraftAccess Regulations; Transportation of Dangerous GoodsAct; and the Canadian Transportation Accident Inves-tigation and Safety Board Act—though there are stillno explanations as to what attention to these variouslegislations would require of UAV operators (TransportCanada 2014f, sec. 623.001[2] 2014 sec. 3.7[1], [2]). Inaddition, Transport Canada’s new ‘‘Knowledge Require-ments for Pilots of Unmanned Air Vehicle Systems(UAV) 25 kg or Less, Operating within Visual Line ofSight’’ provides guidance to ‘‘organizations or indi-viduals intending to provide ground school instructionto pilots seeking compliance with the Best Practices forpilots of small UAV systems,’’ but makes no mention ofprivacy legislation (Transport Canada 2014g).

Privacy has been noted as a central concern in severalrecent media reports on the use of UAVs. Again, userswho are currently unregulated or under regulated posea significant concern in this regard, while these mediareports and posed videos demonstrate the increasingcapabilities of these technologies.14 However, this is ofimportance in the case of SFOC holders as well. Forexample, UAVs have been used in privacy-sensitiveenvironments, such as political protests—as in the caseof the Ontario Provincial Police (OPP) monitoring of

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First Nations protesters (Bowman 2014). In this case aprotest by members of the Tyendinaga First Nation inOntario was monitored by the OPP via a quadcopterUAV on 5 March 2014. During the protest an AboriginalPeoples Television Network reporter posted an image ofthe UAV captured on a cell phone by a protester anduploaded it to Twitter (Bowman 2014; Jackson 2014).Public responses varied in degrees of support and oppo-sition for the OPP’s use of the technology, but consistentacross these posts was evidence of the public’s lack ofawareness of the capabilities of the craft in addition toexpressing significant concern over the ‘‘military’’ natureof the UAV—though the craft in question is far lesssophisticated than those deployed by the CanadianArmed Forces (Jackson 2014). This case serves as anexample of how the failure to specifically incorporateprivacy concerns into UAV legislation has placed theonus of being mindful of privacy concerns on SFOCholders, while this case demonstrates the problems thatarise when the operators are required to develop theirown internal procedures and regulations regarding thesafeguarding of privacy matters.15 It is unreasonable toexpect all SFOC holders, as well as the operators ofUAVs less than 25 kg exempted from SFOC require-ments, to have the financial or legal capacity to properlydesign or execute privacy policy that complies withall aspects of the Personal Information Protection andElectronic Documents Act (PIPEDA) or Privacy Actfederally, and any additional provincial legislation. Thisreality is perhaps best exemplified through the prevalence,or lack thereof, of any Privacy Impact Assessments16 sub-mitted to the Office of the Privacy Commissioner (OPC)regarding the collection of personal information by UAVs.

Having provided an overview of the historical de-velopments and current components of UAV legislationin Canada in addition to presenting core concerns sur-rounding the transparency, oversight, safety, and privacyconcerns, we take up a quantitative content analysis ofall SFOCs issued by Transport Canada between 2007and 2012, empirically demonstrating that the currentmoment demands careful attention be paid to the devel-opment of UAV legislation as UAV usage in Canada hasbeen on the rise. We present several key statistics thatserve as a starting point for other researchers to begin orcontrast their analyses with. In this way, a detailed andaccurate view of SFOC-regulated UAV use in Canada isdeveloped for this, as well as subsequent, research.

MethodContent analysis is a research method that involves thesystematic analysis of information directly (i.e., throughtext and images) or indirectly (e.g., symbolic) to identifypatterns and substantive content (Denzin and Lincoln2008; Krippendorff 2004). As a means of analysis, con-tent analysis17 provides a framework through which to

assess existing information; in this case, data withinTransport Canada’s SFOCs. In this content analysis, sub-jective interpretations associated with the coding of in-formation were extremely minimal. As outlined ahead,the information that comprised the eight variables as-sessed in our analysis is quite standardized and rela-tively objective, leaving little opportunity for critiquesof accidental or deliberate researcher bias. In this case,use of content analysis not only shed light on the regu-lated usage of UAVs in Canada (i.e., those requiring anSFOC) as well as general timelines associated withSFOC obtainment and duration, but also provided afoundation on which future research updating and re-considering these statistics may build.

Specifically, we analyzed the content of 618 SFOCsissued from 2007 to 2012 that were obtained througha series of Access to Information and Privacy (ATIP)requests submitted to Transport Canada; requests fordata regarding 2003–2006 and 2012–2013 were sub-mitted in 2013, and requests for 2014 data in January2015, but these data have not been released, nor isTransport Canada able to provide an estimate of whenthese requests will be completed. In reviewing the infor-mation presented in the SFOCs that were released, werecorded the following data: applicant information,flight information, and application details. In total, in-formation from each SFOC was coded within ten spe-cific areas, resulting in eight variables (the names ofwhich are identified by italics). In particular, applicantinformation included distinguishing between SFOCssubmitted by an individual or an institution (applicanttype), and, when the applicant type was an institution,recording the name of the institution (institution name),as well as distinguishing between public and private in-stitutions (institution type). Flight information includedrecording the region in which the SFOC was submitted(region), the purpose of the flight ( flight purpose), and thetype of UAV (UAV type). Finally, recorded informationregarding application details included the dates onwhich the applicant submitted the SFOC and on whichthe SFOC was approved (calculations produced a singlevariable representing the number of days betweenapplication submission and approval; application time),as well as the dates during which the SFOC was valid(calculations produced a single variable representingthe number of days for which an SFOC was valid;SFOC duration).

Before presenting the results of the content analysis,we would like to note that information received throughATIP requests can be redacted for various reasons.Many of the SFOCs we received from Transport Canadaincluded partially redacted information (largely tied tothe year in which the SFOC was processed).18 There isno missing data at all for Tables 1 and 3, while Table 5’sredactions account for only 3.6 percent of cases and

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Table 4 for 13.3 percent. The remaining redactions dosomewhat limit the extent to which we can fully under-stand these aspects of UAV usage and the SFOC ap-plication process; however, we have clearly indicatedwhen missing cases are the result of redacted informationand we move forward with the available information.Regardless of these points, since Transport Canadakeeps no digital records of UAV flights and compilesno statistics regarding UAV flights, the descriptivestatistics presented in this article represent the mostcomprehensive view of the use of these technologiesin Canada. In this way, these data provide a detailedpicture of how UAV are being used and how this usagerelates to oversight policies and regulations.

Results and Discussion

Descriptive StatisticsThe descriptive statistics presented help to characterizethe basic landscape of UAV usage and the SFOC appli-cation process in Canada.

Applicant information. Applicant type revealed astartling distribution regarding the pattern of use ofUAVs that require SFOCs between individuals and in-

stitutions. Once redacted information was excludedfrom the analysis (n ¼ 364; 58.9 percent), it was clearthat institutions (n ¼ 245; 96.5 percent) are applying forSFOCs in much greater numbers than are individuals(n ¼ 9; 3.5 percent). The explanation for this findingmay lie, in part, in current legislation that does not re-quire ‘‘hobby’’ or ‘‘model aircraft’’ UAV flights to obtainan SFOC. Hobby UAV usage is likely to fall almoststrictly within the realm of UAV users classified as ‘‘in-dividuals’’ as opposed to ‘‘institutions’’; therefore thenumber of individuals flying UAVs likely greatly ex-ceeds the figures reported here, but because they do notcurrently need to obtain an SFOC, usage figures suggestthat individuals are flying UAVs in substantially lessernumbers than institutions. Despite the fact that we areunable to fully understand rates of UAV usage basedon these figures, we can conclude that individuals aremuch less likely than institutions to use UAVs withincontexts that require an SFOC.

Table 2: Issued SFOCs by Institution 2007–2012

Institution Name n %

ING Engineering Inc. 30 4.9

Aeryon Labs Inc. 15 2.4

Memorial University of Newfoundland* 11 1.8

Universal Wings Geophysics Corp. 10 1.6

AeroGeoNautics Inc. 9 1.5

Carleton University* 9 1.5

Draganfly Innovations Inc. 8 1.3

Ontario Provincial Police* 8 1.3

*Public (as opposed to private) institution.

Source: Authors’ compilation from Transport Canada ATIP Requests

files A-2012-00239, A-2012-00240, A-2012-00241, A-2012-00242,

A-2012-00243, A-2012-00244.

Table 3: Issued SFOCs by Transport Canada Region 2007–

2012

Transport Canada Region n %

Prairie and Northern Region (PNR) 238 38.5

Ontario Region 165 26.7

Pacific Region (British Columbia) 132 21.4

Atlantic Region 42 6.8

Quebec Region 41 6.6

Note: For a complete list of SFOCs by province, see Table A.2 in the

Appendix.

Source: Authors’ compilation from Transport Canada ATIP Requests

files A-2012-00239, A-2012-00240, A-2012-00241, A-2012-00242,

A-2012-00243, A-2012-00244.

Table 4: Issued SFOCs by UAV Type 2007–2012

UAV Type n %

Draganflyer 100 16.2

Multiple vehicles 77 12.5

Outlander 28 4.5

Cinestar 25 4

NuvAero 19 3.1

Gatewing 17 2.8

Droidworx AD 13 2.1

CropCam 13 2.1

Note: For a complete list of SFOCs by UAV type, see Table A.3 in

the Appendix.

Source: Authors’ compilation from Transport Canada ATIP Requests

files A-2012-00239, A-2012-00240, A-2012-00241, A-2012-00242,

A-2012-00243, A-2012-00244.

Table 5: Issued SFOCs by Flight Purpose 2007–2012

Flight Purpose n %

Visual mediation 284 46

Research and development 106 17.2

Multiple purposes 102 16.5

Aerial demonstration 44 7.1

Flight training 30 4.9

Not listed 22 3.6

Advertising 10 1.6

Agriculture 9 1.5

UVS student competition 9 1.5

Search flights 2 0.3

Note: For a complete list of SFOCs by purposes before recoding,

see Table A.4 in the Appendix.

Source: Authors’ compilation from Transport Canada ATIP Requests

files A-2012-00239, A-2012-00240, A-2012-00241, A-2012-00242,

A-2012-00243, A-2012-00244.

The ‘‘Rise’’ of Unmanned Aerial Vehicles (UAVs) in Canada: An Analysis of Special Flight Operation Certificates (SFOCs) 213

doi:10.3138/cpp.2014-038 8 Canadian Public Policy / Analyse de politiques, September / septembre 2015

Elaborating on the characteristics of institutions thatapplied for SFOCs revealed a substantial disparity be-tween application rates of private and public institutions.Once redacted information was excluded from the anal-ysis (n ¼ 371; 60 percent), it became apparent that pri-vate institutions (n ¼ 175; 70.9 percent) are applyingfor SFOCs in much greater numbers than publicallyfunded institutions (n ¼ 72; 20.1 percent). In addition,most (though not all) of the institutions that most fre-quently applied for SFOCs were private institutions.Due to the large number of institutions that appliedfor SFOCs (67 in total19) only the eight institutions withthe most frequent SFOC applications are reported (seeTable 2).20

The private institutions that applied most frequentlyfor SFOCs were ING Engineering and Aeryon Labs. Inboth cases, these companies not only produce their ownUAV for the open market but also sell the services oftheir staff to fly specific missions for other companiesor train others in how to use their craft. Furthermore,the relatively high usage of SFOCs is likely partiallyattributable to the reach and diversification of these cor-porations. For instance, in the case of ING Engineering,the company is based out of Ottawa (ON) but also hasoffices in Calgary (AL), Sherbrooke (QC), Fredericton(NB), and McLean (VA) in the United States. In addi-tion, the company sells and operates both fixed-wingand rotor UAVs, and offer ‘‘airborne solutions’’ for usein a variety of areas, including infrastructure inspec-tions, aerial surveying, environmental monitoring, agri-culture surveying, and training (ING Engineering 2014).Recently, ING Engineering has even expanded to pro-viding services for the public sector through a contractwith the Sherbrooke fire department to provide aerialphotography of rising flood waters in the region (Pugliese2014).

Like ING, Aeryon Labs provides both craft and serv-ices to the private and public sectors. Aeryon producesa series of rotocopter, or quadcopters—including theirmost popular model, the Aeryon Scout. In addition toselling UAVs the company has developed an advertis-ing campaign to facilitate the spread of its services, anobjective that could be considered quite successful giventhat the company has already completed a range of mis-sions, including: accident reconstruction and evidencegathering, school roof panoramas for police planning,traffic accident reconstruction, Central American drugcompound recon, marijuana grow-op searches (HaltonRegional Police Services), ship-based wildlife observation(University of Alaska), GIS-3D modelling and volumetricanalysis, hydro tower inspection, flare stack inspection(oil refinery in Eastern Canada), and oil spill response(Alaska) (Aeryon Labs 2014).

The public institutions that have received the mostSFOCs were Memorial University (NL) and Carleton

University (ON). In both cases, flights were largely re-lated to research and development, focusing on design-ing UAV technology ‘‘for command, control, computers,intelligence, surveillance and reconnaissance (C4ISR)missions’’ (Memorial University 2014; also see CarletonUAV Research Group 2014). The next largest number ofSFOCs issued to a public institution was to the OntarioProvincial Police (OPP).

The OPP were the first21 policing body in NorthAmerica to deploy a UAV that provided evidence for acourt proceeding, having done so near Kenora, Ontario,in 2007 (Forberg 2012; Quinn 2013). This first use wasrelated to a homicide investigation and resulted in thefirst court case that relied on images from a UAV asevidence in Canada. Since that time, the use of UAVsby the OPP has expanded significantly to include tacticalunits and has even been applied to the monitoring ofprotesters at Tyendinaga First Nation in 2014 (Bowman2014; Ontario Provincial Police 2013, 2). However, use ofUAVs for policing purposes has not been restricted tothe OPP. The Royal Canadian Mounted Police (RCMP)has also expressed considerable interest in UAV tech-nology, reporting that by 2012 UAVs had been used bytheir officers to perform a variety of tasks, including‘‘operational flights for forensic identification, majorcrimes, search and rescue, and their dive team’’ (Forberg2012). In addition to the RCMP and the OPP, there werefive other identifiable police organizations that wereissued SFOCs: the Prince Albert Police Service (SK), theRegina Police Service (SK), the Halton Regional PoliceService (ON), the Saskatoon Police Force (SK), and theCanadian Police Research Centre (SK). These revelationsdemonstrate the expanding use of UAVs by policinginstitutions across Canada, and support comments madeby the officer in charge of developing UAV policy forthe RCMP in 2012, who asserted that ‘‘within a year,this will explode across the country, every police forcewill want one and be working towards getting one’’(Jewers, cited in Forberg 2012).

Flight information. Some regions have seen muchmore activity in SFOC applications than others. Theregion in which SFOCs were submitted provides inter-esting insight into the distribution of UAV usage acrossCanada. Foremost, in no case was this information re-dacted; as such, we are not limited to a partial view ofthe situation. Of all the SFOCs reviewed (N ¼ 618), thegreatest number of SFOC submissions came from Trans-port Canada’s Prairie and Northern region (n ¼ 238; 38.5percent), followed by Ontario (n ¼ 165; 26.7 percent),Pacific (n ¼ 132; 21.4 percent), Atlantic (n ¼ 42; 6.8 per-cent), and Quebec regions (n ¼ 41; 6.6 percent) (seeTable 3).

While this breakdown reveals interesting informationabout the ways in which UAV usage has been spreadacross Canada since legislation has required these re-

214 Thompson and Saulnier

8 Canadian Public Policy / Analyse de politiques, September / septembre 2015 doi:10.3138/cpp.2014-038

cords be kept, it was the vast amount of UAV typesused across the nation that provides an indication ofthe general proliferation of UAVs. Due to a substantialoverall count of UAV types (78 general models in total)only the eight most frequently occurring responses arereported (see Table 4).

In Table 4 we have distinguished those applicantswho requested permission to fly more than one UAVthrough the classification of ‘‘multiple vehicles.’’ Forclarification purposes we wish to note that the applicantwas still required to specifically list all of the UAVs heor she was requesting permission to fly; but, given ourinterest in providing a general overview of the charac-teristics of UAV usage in Canada, we elected to classifythese cases as a distinct category of UAV type. We wereinterested in the access SFOC applicants had to multipleUAVs and found it notable that the request to fly multi-ple vehicles was the second most popular categoriza-tion. The request to fly multiple vehicles came in secondonly to requests to fly the Draganflyer UAV model (it isalso notable that the Draganfly Innovations Inc. is one ofthe institutions that most frequently requested SFOCs).

The two most common craft types were the Dragan-flyer and the Outlander, each representing the two mostprominent UAV design types—respectively, rotocopterand fixed-wing designs. In the rotocopter (or quad-copter) design, helicopter-style rotors are attached to aseries of arms which protrude from the centre of theunit. The craft’s payload, often a camera system, thenrests below the rotor arms, allowing for the craft to bebalanced and the view of the camera to be unobstructed.In the particular case of the Draganflyer, the craft mea-sures 91cm wide, has a length of 85cm, a top diameterof 99cm, and a complete height of 29cm, and is capableof carrying up to a 500-gram payload (Draganfly Inno-vations 2014).

The second most common craft was the Outlander.Unlike the rotocopter design of the Draganflyer, theOutlander is a fixed-wing UAV that resembles a classicairplane design very closely. The craft itself ‘‘weighsaround 2.7 kg (six pounds), with a 2.5-m (eight-foot)wingspan,’’ making the craft ‘‘capable of flying forabout 45 minutes on a fully charged set of batteries.’’The maximum payload of the craft is 400 grams, ‘‘whichnecessitates using a compact camera for imaging’’ (White-head 2011). Of the top UAV types, three are fixed-wingcrafts (Outlander, Gatewing, CropCam), while fourare rotocopter designs (Draganflyer, Cinestar, NuvAero,Droidworx AD). Of course, these variations in designare associated with different capabilities, making partic-ular crafts more suited to particular purposes.

The flight purposes cited in the SFOCs span a varietyof reasons (see Table 5). Recoding was preformed tocreate the purpose of ‘‘visual mediation’’ (which isthe most frequently cited flight purpose in the SFOCs).

‘‘Visual mediation’’ comprises six purposes that all re-volve around collecting visual information and mediatingit through the UAV for non-emergency purposes (wedistinguished search flights as a unique category becauseof the more pressing sense of urgency involved).22 Aswell, similar to our coding of UAV type, SFOCs thatcited multiple purposes were coded as ‘‘multiple pur-poses’’ to better represent the overall number of SFOCrequests.

Application details. Finally, two scale variables wereproduced through computations that allowed the spe-cific number of days between two set dates to be deter-mined. First, application time (n ¼ 614)23 indicated thatthe average number of days it took an SFOC applicantto have an application approved from the time it wassubmitted was 42.18 (SD ¼ 128.87). Second, SFOC dura-tion (n ¼ 603)24 indicated that the average number of daysan SFOC was approved for was 112.11 (SD ¼ 137.81).From these scales we were able to gain an understand-ing of the changing nature of the SFOC applicationprocess. First, issued SFOCs have consistently increasedeach year. As well, while SFOCs submitted between2007 and 2011 took between approximately 45 to 85days to be issued (2008 being the lowest, with an averagewait time of 45.33 days, and 2010 being the longest, withan average wait time of 85.46 days), the most recent yearfor which we have SFOC data had the shortest waittime (in 2012 applicants waited on average 22.90 days).Finally, the duration for which SFOCs were issued hasincreased every year (lasting an average of 70.60 daysin 2007 and jumping to an average of 109.95 days in2012). These fluctuations are very likely attributable toimprovements and adjustments in Transport Canada’sinternal procedures over time.

Descriptive relationships. In addition to these basicdescriptive statistics, cross-tabulations were performedto gain a better understanding of interactive distribu-tions between variables. In both of the distributions pre-sented, the purpose of flight listed in the SFOC is in-cluded as a variable (with the respective other variablesin the tests being region and UAV type) and, due to thenumber of purpose response attributes, only cells withparticularly high, low, or unique values are discussed.Results indicated that purpose of flight varied based onregion of application and UAV type.

Assessing whether purpose of use varied based onTransport Canada region (n ¼ 618) revealed a weak,positive significant relationship between the variables(p < .05; see Table 6). Research and development aswell as visual mediation tasks were among the mosthighly cited purposes across most regions.

Assessing whether purpose of use varied based onUAV type (due to the high number of UAV types onlythe most popular vehicles [Table 4] were included inthis analysis, with data from SFOCs citing other UAV

The ‘‘Rise’’ of Unmanned Aerial Vehicles (UAVs) in Canada: An Analysis of Special Flight Operation Certificates (SFOCs) 215

doi:10.3138/cpp.2014-038 8 Canadian Public Policy / Analyse de politiques, September / septembre 2015

types removed; n ¼ 215) revealed a weak, positive sig-nificant relationship between the variables (p < .05). Inaddition, due to the large number of cells in this cross-tabulation, only the most frequently cited purposes foreach UAV are reported. Visual mediation tasks werepopular, forming the most often cited purpose forthe Draganflyer (n ¼ 35; 35 percent of all Draganflyerpurposes), the Outlander (n ¼ 25; 89.3 percent), theCinestar (n ¼ 24; 96 percent), the NuvAero (n ¼ 17; 89.5percent), the Droidworx AD (n ¼ 13; 100 percent), andthe CropCam (n ¼ 11; 84.6 percent). Alternatively, theGatewing was most frequently used by SFOC applicantswho cited multiple purposes in their application (n ¼ 16;94.1 percent of all Gatewing purposes).

The Canadian UAV Industry Moving ForwardThis article has charted UAV usage in Canada from 2003to the present, noting a fairly consistent increase in thenumber of issued SFOCs. Key statistics presented inthis article that help track usage trends demonstratethat: more privately funded institutions hold SFOCsthan publically funded institutions; the PNR regionissued the most flight certificates, followed by Ontarioand Pacific regions; the most commonly used craft areDraganflyer models which have a quadcopter design;and, finally, UAVs are used most frequently for visualmediation tasks, though there were also a large numberof certificates related to research and development. Inregards to industry and government claims of UAVsbeing used primarily for the three Ds (dull, dangerous,and dirty work), the foregoing data suggests that theanswer is far more complicated than that. SFOC datashow a wide range of applications unassociated withthe three Ds, such as research and development andadvertising. The range and scope of activities that UAVsare being deployed to take up in Canada also stress theneed for active public debate on UAV policy and use,and lead us to stress again the troubling lack of accessible

records within Transport Canada. A policy of openness,as is the case for commercial manned flights in Canada,would certainly enable a wider debate on UAV usein Canada. The complete lack of electronic records ofUAV flights or issued SFOCs not only is a violation ofexpectations of modern regulatory agencies but alsocarries the potential to result in dangerous situationsthrough the inability to share data regarding UAV flightoperations with other government and non-governmentagencies.

Building on these transparency- and oversight-relatedconcerns, the administration of federal legislation mustbe consistent among various regional departments tobe considered as a legitimate source of regulation. Theparceling out of oversight responsibilities to regionaldepartments without clearly defined expectations hascontributed to Transport Canada’s partial knowledgebank on the details of specific UAV flights and operators.This creates an environment in which it is difficult foranyone to make informed decisions regarding the currentappropriateness of UAV legislation or future directionswhich that legislation should take. As evidence of this,in our own data gathering experience we encountereddifficulties in terms of both being provided with therequested documentation (due to either its purportedlack of existence or means of data storage) and receiving(in some cases) heavily redacted documents. These ex-periences have contributed to our contention that theregulatory practices in place are not particularly accessibleor transparent, and, as such, we are forced to questionwhat this technology means for issues of safety andprivacy with only a partial understanding of UAV usagecharacteristics in Canada.

The present usage of UAV technology poses chal-lenges to safety and privacy concerns, and the nature ofthese challenges will continue to change as UAV tech-nology becomes increasingly prevalent and sophisticated.Furthermore, due to the relatively lax state of current

Table 6: Flight Purpose x Region 2007–2012

Region

Purpose Ontario Atlantic Quebec PNR Pacific

Research/development 52 19 10 13 12

Flight training 9 8 7 3 3

Agriculture 2 0 5 2 0

Visual mediation 48 2 10 128 96

UVS student competition 2 1 2 2 2

Aerial demonstration 22 2 1 10 9

Advertising 0 0 0 10 0

Search flights 0 0 0 0 2

Multiple purposes 25 3 5 63 6

Not listed 5 7 1 7 2

Source: Authors’ compilation from Transport Canada ATIP Requests files A-2012–00239, A-2012–00240, A-2012-00241, A-2012-00242,

A-2012-00243, A-2012-00244.

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8 Canadian Public Policy / Analyse de politiques, September / septembre 2015 doi:10.3138/cpp.2014-038

requirements regarding the tracking and recording ofUAV flights, without the express cooperation of SFOCholders Transport Canada is faced with extreme diffi-culty when attempting to identify SFOC violators, atask compounded by the fact that many ‘‘violators’’have not been aware of the fact that they needed toacquire an SFOC to legally fly their UAV. While theknown violations have not resulted in serious repercus-sions for public safety thus far, these concerns need tobe carefully integrated into a working system of report-ing, recording, monitoring, and evaluating UAV flights,particularly as they become more commonplace inCanadian airspace.

Turning back to our earlier critique of the incorpora-tion of privacy into UAV policy, we believe that thefailure to directly incorporate the requirements of legis-lation into the SFOC application serves to place an un-due burden on applicants to research the implicationsof their flight(s) for privacy concerns and ensure theirown compliance. As such, while particularly thought-ful applicants may bear privacy concerns in mind, thecurrent application process does not require sufficientattention to privacy concerns from those overseeing theissuance of SFOC. It is not our contention that privacy isa non-issue in this context, but rather that it is a rela-tively overlooked issue and, given the capacities ofUAV technology, we believe that policy and legislationmust explicitly address privacy as a concern to ensurethat the privacy rights of Canadians are respected, par-ticularly as UAV technology continues to become increas-ingly sophisticated. Furthermore, with regard to 2014policy regarding SFOC exemption and operator trainingrequirements, we are concerned that policy changeswork to externalize the responsibility for UAV flightoversight and governance, placing a much greater onuson operators for safety and reporting, and placing onindustry the requirement to develop curriculum andconduct training, testing, and certification processes foroperators.

As UAVs are integrated further and with greaterregularity into Canadian airspace, the foregoing data,coupled with the movement of Transport Canada awayfrom tracking and regulation,25 raises valid concernswith regards to safety (relating to airspace and band-width use) as well as privacy law (tied to PIPEDA andthe Privacy Act), which require thoughtfully crafted UAVlegislation with careful oversight. We assert this aspersons who recognize the tremendous value of UAVtechnology for a variety of purposes in Canada but alsoits potential to be used in ways that are unsafe orinfringe on privacy rights, and, as such, we promote thecarefully bounded use of UAVs.

ConclusionThe statistics presented herein are drawn from theSFOCs issued between 2007 and 2012, supplied byTransport Canada through a series of ATIP requests.Our work empirically demonstrates that UAV usage hasbecome increasingly popular and prevalent in Canada,and we believe that there is no reason to suspect thatthis trend will abruptly change. In particular, the resultsdemonstrate the increasing opening of Canadian air-space to UAV technology and the need to be aware ofthe implications of this reality. This is well demonstratednot only by the increase from 44 to 913 SFOCs issuedbetween the years 2007 and 2013 but also by attitudesof industry and government organizations regardingthe ability of UAV technology to allow for expandedcommercial applications and their pursuance of thecomplete opening up of all airspace to UAV operationby 2028 (BBC News 2013; Chappell 2014; TransportCanada 2013). We argue that this reality necessitatesthoughtful legislation and regulation of UAV usage inCanada, with specific attention focused on developingtransparency in UAV usage data regarding the numberof flights, operators, and uses which would match com-mercial travel flight data currently released within Trans-port Canada’s annual reports, as well as consistency inthe application of policy across regions, a concern thathas been expressed by other scholars in the literature(e.g., see Block G 2013; Bracken-Roche et al. 2014; Officeof the Privacy Commissioner of Canada Research Group2013).

In light of these concerns, the information we havepresented helps to develop an accurate understandingof UAV flights in Canada; this information is invaluableto the formation of policy that will shape how aerialvehicles will be designed and flown in Canada in theyears to come. By highlighting usage trends, oversightand transparency concerns and safety and privacy con-cerns and considering how these factors, in combination,contribute to a unique social moment in Canada, wehope to have provided material that others will finduseful in the thoughtful and critical assessment andregulation that integrate UAVs into Canadian airspaceand society.

Notes1. This article adopts the term unmanned air vehicles (UAVs)

to refer to an array of craft, including unmanned vehiclesystems (UVSs), unmanned air systems (UASs), remotelypiloted vehicles (RPVs), and remotely piloted aircraft sys-tems (RPASs). While we acknowledge that there are impor-tant differences between these government and industrycategories, due to our focus on Transport Canada SFOCs

The ‘‘Rise’’ of Unmanned Aerial Vehicles (UAVs) in Canada: An Analysis of Special Flight Operation Certificates (SFOCs) 217

doi:10.3138/cpp.2014-038 8 Canadian Public Policy / Analyse de politiques, September / septembre 2015

the classification of UAV within Section 101.01 of the Cana-dian Aviation Regulations (CAR) under the AeronauticsAct (Government of Canada 1996) is adopted.

2. Statistics of issued SFOCs (including flight log data, flightlocation, and time) are calculated only in the Pacific andthe Prairie and Northern region (PNR) and not collectedfrom all regions (Transport Canada Access to Informationand Privacy Department 2014;also see Transport Canada2014e).

3. The SFOCs were obtained through Access to Informationand Privacy (ATIP) requests responded to by TransportCanada (File Numbers A-2012-00239, A-2012-00240, A-2012-00241, A-2012-00242, A-2012-00243, A-2012-00244).

4. The Canadian Air Force has maintained that its actions falloutside of the purview of CAR legislation and, as such,remain exempt from Transport Canada UAV regulations(Pugliese 2013a, 2013b), instead requiring flight permits(FP) issued internally by the Canadian Armed Forces.

5. Model aircraft are not regulated and are defined as ‘‘anaircraft, the total weight of which does not exceed 35 kg(77.2 pounds), that is mechanically driven or launched intoflight for recreational purposes and that is not designed tocarry persons or other living creatures’’ (Section 101.01).The absence of legislation developed to regulate UAV useby ‘‘hobbyists’’ is a significant issue in need of analysis butbeyond the scope of this research. An inquiry of particularinterest is the extent to which the actions of these un-regulated users come to affect responsible regulated usersthrough amendments to Transport Canada’s SFOC admin-istration or oversight.

6. The use of non-recreational UAV under 2kg is subject to asimilar set of 37 conditions (Transport Canada 2014d).

7. Transport Canada (2014b) notes, however, that this can bedone if ‘‘the building, structure, vehicle, vessel or animal isthe subject of the aerial work; and only persons inherent tothe operation are present.’’

8. Currently no legislation or policy regulates or overseesUAV pilot ground schools, and Transport Canada doesnot test the competencies of pilots or educators (TransportCanada 2014g). A working document was published in2014 to guide ‘‘organizations or individuals intending toprovide ground school instruction to pilots seeking com-pliance with the Best Practices for pilots of small UAV sys-tems,’’ though this document makes no mention of privacylegislation or how operators need to incorporate privacylaw into their collection of data (Transport Canada 2014g).

9. Through an ATIP we requested that Transport Canadaprovide us with information on the total number of SFOCsapplied for, in the interest of comparing SFOCs soughtagainst SFOCs issued, but no data regarding the totalnumber of SFOCs sought was released. An additionalATIP was submitted on 10 December 2013 requesting dataregarding all SOFC issued between 2003 and 2013, but atthe time of publication Transport Canada had not releasedthe 2003–2006 and 2012–2013 data, and could provide notimeline for the completion of our request. SubsequentATIP requests have been made for the 2014 data as well,with again no timeline for the release of these data.

10. Transport Canada divides governance responsibilities acrossthe country into five regions: Pacific region (British Colum-

bia), Prairie and Northern region (Alberta, Saskatchewan,Manitoba, Yukon, Northwest Territories, Nunavut), Atlanticregion (Newfoundland /Labrador, Nova Scotia, NewBrunswick, Prince Edward Island), Ontario region, andQuebec region.

11. Our reference to ‘‘blanket SFOC’’ refers to an SFOC issuedfor an extended period of time, up to one year, and not to aspecified area but to an entire city, province, or region.

12. These crafts fall under the ‘‘model aircraft’’ label and donot currently require SFOCs (Canadian Aviation Regula-tions Section 101.01).

13. In 2009 a portion of bandwidth was allocated for the estab-lishment of a Tactical Common Data Link (TDDL), whichallows military and government UAV to operate without aspecific Industry Canada license, as well as brings Canadain line with all other NATO countries in the allocation ofthe 14.5–15.53 GHz frequency for this exclusive purpose(Department of National Defence 2009, 2–3).

14. For example, cases regarding the use of UAVs to photo-graph private spaces and homes (CBC News 2014a, 2014b;Bowman 2014; CTV News 2014) highlight the importanceof both regulating the hobbyist community through legisla-tion and generally incorporating explicit privacy considera-tions into all UAV legislation. They additionally assert theneed for SFOC regulations to specifically address how pri-vacy regulation fits this new industry and question theblanket SFOC exemption of UAVs under 2 kg.

15. We do not wish to convey that the use of UAVs by policeservices is devoid of attention to privacy concerns. In aninterview conducted with the Halton Regional Police Ser-vice participants emphasized the importance of carefullyincorporating privacy concerns into internal policies andexpectations.

16. PIAs must be completed by any Canadian governmentinstitution wishing to collect, amend, or alter the use ofpersonal information for bureaucratic or administrativepurposes.

17. The approach is not without limitations. A commonly citedconcern is that conclusions are subject to interpretation, aninsinuation that the method is plagued by problems asso-ciated with construct development. However, proponentsmaintain that clear and consistent operational definitions area means of controlling for these concerns (Bryman, Teevan,and Bell 2009; Krippendorff 2004).

18. Redaction rates in the documents received through ATIPrequests varied considerably by year and region. There isno missing data at all for Tables 1 and 3, while Table 5’sredactions account for only 3.6 percent of cases and Table4 for 13.3 percent. Using ‘‘institution name’’ (a heavilyredacted variable) as an example, redaction rates variedfrom 4 percent in 2011 to 99.5 percent in 2012. All of theredactions were primarily concentrated in the years 2007and 2012 in the Pacific and Prairie and Northern regions;within these two years these two regions constituted 70percent of all redacted cases.

19. For a complete list of institutions that applied for SFOCs,see Table A.1 in the Appendix.

20. The categorization of ‘‘redacted’’ constituted the largestpercentage of this distribution (n ¼ 373; 60.4 percent).

218 Thompson and Saulnier

8 Canadian Public Policy / Analyse de politiques, September / septembre 2015 doi:10.3138/cpp.2014-038

21. In 2002, the RCMP were part of a joint security organiza-tion under the Canadian Armed Forces to protect venuesand participants at the G8 Summit in Kananaskis, dubbedOperation Grizzly, which included the use of an I-Gnatfixed-wing UAV craft (Canadian Forces ExperimentationCentre 2003, 113).

22. The collapsed response attributes were: aerial photography,remote aerial inspection, aerial survey, geophysical research,wildlife management, and aerial surveillance and recogni-zance.

23. Four cases are missing from the analysis because no sub-mission date was listed in the application.

24. Fifteen cases are missing from the analysis because the dateon which the SFOC was recorded as valid until precededthe data on which it was valid from—a clerical error in theSFOCs.

25. See statements made by a Transport Canada representativeat the 2013 Unmanned Systems Canada Conference on13 November 2013 in Vancouver, BC (Transport Canada2013), as well as the exemption of UAVs under 25 kg fromSFOC oversight requirements, and the formalization of theexpansion of geographical space and time periods relatedto ‘‘compliant’’ SFOC holders (Transport Canada Staff Instruc-tions 623-001[2] 2014).

ReferencesAeryon Labs. 2014. ‘‘Case Studies.’’ Accessed 23 June 2015 at

http://www.aeryon.com/casestudies/growopsearch.BBC News. 2013. ‘‘Amazon Testing Drones for Deliveries.’’

Accessed 10 December 2013 at http://www.bbc.co.uk/news/technology-25180906.

Block, G. 2013. ‘‘Watching You: Some Implications ofSurveillance-by-UAVs.’’ Accessed 2 June 2014 atwww.blockg.ca.

Bowman, J. 2014. ‘‘Ontario Police Defend Use of DroneCameras over Protests.’’ CBC News. Accessed 5 March2014 at http://www.cbc.ca/newsblogs/yourcommunity/2014/03/ontario-police-defend-use-of-drone-cameras-over-protests.html.

Bracken-Roche, C., D. Lyon, M. Mansour, A. Molnar, A.Saulnier, and S. Thompson. 2014. ‘‘Privacy Implications ofthe Spread of Unmanned Aerial Vehicles (UAVs) inCanada.’’ Report for the Office of the PrivacyCommissioner of Canada.

Bryman, A., J. Teevan, and E. Bell. 2009. Social ResearchMethods, 2nd Canadian edition. Don Mills, ON: OxfordUniversity Press.

Canadian Centre for Unmanned Vehicle Systems. 2010.‘‘Advancing Unmanned Systems in Canada: CanadianCentre for Unmanned Vehicle Systems 2007–2010.’’Accessed 2 June 2014 at http://www.albertacanada.com/aero-ais_ccuvs-overview.pdf.

Canadian Forces Experimentation Centre. 2003. CanadianForces Experimentation Centre, Experiment Report IICE—001/2002: Uninhabited Aerial Vehicle Concept Development andExperimentation. Ottawa: Department of National DefenceCanada.

Carleton UAV Research Group. 2014. ‘‘Aircraft Fleet.’’Accessed 2 June 2014 at http://2014uav.mae.carleton.ca/fleet/.

CBC News. 2012. ‘‘Drones Work the Skies for Police, Scientists,Media.’’ The Current. Accessed 2 June 2014 at http://www.cbc.ca/news/technology/drones-work-the-skies-for-police-scientists-media-1.1237009.

CBC News. 2014a. ‘‘Peeping Drone ‘an Invasion of Privacy,’B.C. Homeowner Says.’’ Accessed 5 March 2014 at http://www.cbc.ca/news/canada/british-columbia/peeping-drone-an-invasion-of-privacy-b-c-homeowner-says-1.2749365.

CBC News. 2014b. ‘‘YouTube Video Shows Drone BuzzingVancouver Apartment.’’ Accessed 5 March 2014 at http://www.cbc.ca/news/canada/british-columbia/youtube-video-shows-drone-buzzing-vancouver-apartment-1.2740004.

CBC News. 2015. ‘‘Transport Canada’s Illegal Drone Fines PileUp in Quebec.’’ Accessed 3 April 2015 at http://www.cbc.ca/news/canada/montreal/transport-canada-s-illegal-drone-fines-pile-up-in-quebec-1.3020586.

Chappell, B. 2014. ‘‘Beer Drone Can Buzz the Skies No More,FAA Says.’’ NPR. Accessed 2 June 2014 at http://www.npr.org/sections/thetwo-way/2014/01/30/269039542/beer-drone-can-buzz-the-skies-no-more-faa-says.

CTV News. 2014. ‘‘Drone Caught Buzzing around VancouverHigh-Rises.’’ Accessed 5 March 2014 at http://www.24news.ca/the-news/canada-news/20752-drone-caught-buzzing-around-vancouver-high-rises.

Denzin, N., and Y. Lincoln. 2008. Handbook of QualitativeMethods. Los Angeles: SAGE.

Department of National Defence. 2009. ‘‘Response to CanadaGazette Notice DGTP-004-08, Consultation Paper on Usinga Portion of the Band 14.5–15.35 GHz for Tactical CommonData Link (TCDL) System.’’ Accessed 2 June 2014 athttps://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/comments_commentaires-DGTP-004-08-RABC.pdf/$FILE/comments_commentaires-DGTP-004-08-RABC.pdf.

Draganfly Innovations. 2014. ‘‘X6 Technical Overview.’’Accessed 2 June 2014 at http://www.draganfly.com/uav-helicopter/draganflyer-x6a/specifications/.

Finn, R.L., and D. Wright. 2012. ‘‘Unmanned Aircraft Systems:Surveillance, Ethics and Privacy in Civil Application.’’Computer Law & Security Report 28(2):184–94. http://dx.doi.org/10.1016/j.clsr.2012.01.005.

Forberg, S. 2012. ‘‘Emerging Trends: Taking to the Skies, aNew Tool Facilitates Investigations.’’ Gazette 74(1).Accessed 2 June 2014 at http://www.rcmp-grc.gc.ca/gazette/vol74n1/trends-dernierestendances-eng.htm.

Government of Canada. 1996. ‘‘Canadian AviationRegulations: The Aeronautics Act.’’ Accessed 2 June 2014 athttp://laws-lois.justice.gc.ca/eng/regulations/SOR-96-433/page-1.html.

Holman, F. 2013. ‘‘The Future of Drones in Canada:Perspectives from a Former RCAF Fighter Pilot.’’ CanadianInternational Council. Accessed 27 August 2013 at http://opencanada.org/features/the-think-tank/essays/the-future-of-drones-in-canada/.

ING Engineering. 2014. ‘‘Services.’’ Accessed 23 June 2015 athttp://ingrobotic.com/services/.

International Civil Aviation Organization. 1944. Convention onInternational Civil Aviation Article 8, ICAO Assembly Doc7300. Chicago: International Civil Aviation Organization.

The ‘‘Rise’’ of Unmanned Aerial Vehicles (UAVs) in Canada: An Analysis of Special Flight Operation Certificates (SFOCs) 219

doi:10.3138/cpp.2014-038 8 Canadian Public Policy / Analyse de politiques, September / septembre 2015

International Civil Aviation Organization. 2011. UnmannedAircraft Systems (UAS), ICAO Circular 328 AN/190.Montreal: United Nations Secretary General.

Jackson, K. 2014. ‘‘@afixedaddress: Here Is a Picture of theDrone OPP Say They Used to Take Pics of ProtestersBlocking Road near Tyendinaga, March 4th.’’ Accessed 5March 2014 at https://twitter.com/afixedaddress/media.

Krippendorff, K. 2004. Content Analysis: An Introduction to ItsMethodology. Thousand Oaks, CA: SAGE.

Memorial University. 2014. ‘‘Remote Aerial Vehicles forEnvironment-Monitoring II.’’ Accessed 2 June 2014 athttp://www.mun.ca/research/about/rgcs/mrp/projects/raven-2.php.

Office of the Privacy Commissioner of Canada ResearchGroup. 2013. ‘‘Drones in Canada: Will the Proliferation ofDomestic Drone Use in Canada Raise New Concerns forPrivacy.’’ Accessed 2 June 2014 at https://www.priv.gc.ca/information/research-recherche/2013/drones_201303_e.asp.

Ontario Provincial Police. 2013. Key Messages: OPPUnmanned Aerial Vehicles (UAV). 12 February. OPP ATIPRequest CSCS-A-2013-03976.

Organization of American States. 2012. Agenda Item 1.5:Preliminary Views for WRC-15. Geneva: Organization ofAmerican States. Accessed 2 June 2014 at http://www.google.ca/url?sa=t&rct=j&q=&esrc=s&source=web&cd=3&ved=0CDQQFjAC&url=http%3A%2F%2Fwww.oas.org%2Fes%2Fcitel%2FTerminado%2FP2!R-3122-1-5-r1_i.doc&ei=o0OyUoGAJoTs2wWVpoD4DQ&usg=AFQjCNGg3r9z-HYGbA-LAhXYYDqi_yiemQ&bvm=bv.58187178,d.b2I&cad=rja.

Pugliese, D. 2013a. ‘‘DND Concludes It Does Not NeedPermission to Fly Drones in Domestic Airspace, despite‘Greater Challenges.’’ National Post 17 August. Accessed 12September 2013 at http://news.nationalpost.com/news/canada/dnd-concludes-it-does-not-need-permission-to-fly-drones-in-domestic-airspace-despite-greater-challenges.

Pugliese, D. 2013b. ‘‘RCAF Says It Sets the Rules for DroneFlights over Canada.’’ Ottawa Citizen 16 August. Accessed30 March 2014 at http://www.ottawacitizen.com/technology/RCAF+says+sets+rules+drone+flights+over+Canada/8798974/story.html.

Pugliese, D. 2014. ‘‘Sherbrooke Fire Department Selects INGRobotic Aviation UAV to Gather Information aboutFlooding.’’ Ottawa Citizen 15 April. Accessed 15 April 2014at http://ottawacitizen.com/news/national/defence-watch/sherbrooke-fire-department-selects-ing-robotic-aviation-uav-to-gather-information-about-flooding.

Quinn, J. 2013. ‘‘Police Drones Sparks Debate over PersonalPrivacy.’’ Toronto Star 5 February. Accessed 5 February2014 at http://www.thestar.com/news/world/2013/02/05/privacy_vs_security_when_does_the_use_of_drones_cross_the_line.html.

RCMP. 2009. ‘‘Comments on Canada Gazette Part I, NoticeNo. DGTP-004-08 (December 2008) Consultation Paper onUsing a Portion of the Band 14.5–15.35 GHz for TCDLSystems.’’ Accessed 2 June 2014 at http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf09396.html.

Semianiw, W. 2012. ‘‘Proceedings of the Standing SenateCommittee on National Security and Defence Issue 5—Evidence—Meeting of April 23, 2012.’’ Parliament ofCanada. Accessed 2 June 2014 at http://www.parl.gc.ca/content/sen/committee/411/SECD/05EVB-49470-E.HTM.

Transport Canada. 2008. The Review and Processing of anApplication for a Special Flight Operations Certificate for theOperation of an Unmanned Air Vehicle (UAV) System. IssueNo. 01. Document No. SI 623-001. File 5812-11 U. 2008 1127. Ottawa: Transport Canada. Accessed 2 June 2014https://www.tc.gc.ca/eng/civilaviation/opssvs/managementservices-referencecentre-documents-si-600-1255.htm.

Transport Canada. 2013. ‘‘Scenario Note for Regional Director,Civil Aviation—Pacific: Presentation at the 2013 UnmannedSystems Canada Conference Transport Canada Update.’’13 November, Vancouver, BC. Transport Canada Access toInformation and Privacy File number: A-2014-00247.

Transport Canada. 2014a. EMS Query Tool—Detailed Report.ATIP File Number A-2014-00283.

Transport Canada. 2014b. Exemptions from Sections 602.41and 603.66 of the Canadian Aviation Regulations. Accessed15 April 2014 at http://www.tc.gc.ca/civilaviation/regserv/affairs/exemptions/docs/en/2879.htm.

Transport Canada. 2014c. ‘‘Flying an Unmanned AircraftRecreationally.’’ Accessed 23 July 2015 at http://www.tc.gc.ca/eng/civilaviation/standards/general-recavi-uav-2265.htm.

Transport Canada. 2014d. Guidance Material for OperatingUnmanned Air Vehicle Systems under an Exemption.Advisory Circular (AC) No. 600-004. 2014–11–27. Accessed15 April 2014 at http://www.tc.gc.ca/eng/civilaviation/opssvs/ac-600-004-2136.html.

Transport Canada. 2014e. Information for the Honorable LisaRaitt, 28 February. Transport Canada ATIP File NumberA-2014-00247 NW.

Transport Canada. 2014f. Staff Instruction: Review andProcessing of an Application for a Special Flight OperationsCertificate for the Operation of an Unmanned Air Vehicle(UAV) System. Issue No. 02. Document No. SI 623-001. FileZ 5000-32. 2014 11 19. Ottawa: Transport Canada.

Transport Canada. 2014g. TP 15263: Knowledge Requirementsfor Pilots of Unmanned Air Vehicle Systems (UAV) 25 kgor Less, Operating within Visual Line of Sight. August.Accessed 15 April 2014 at http://www.tc.gc.ca/eng/civilaviation/publications/page-6557.html.

Transport Canada Access to Information and PrivacyDepartment. 2014. Personal Email Re: A-2013-00247, 19June.

Unmanned Systems Canada. 2012. Unmanned Systems Canada:Canada’s National UVS Sector Association, A Not-For ProfitOrganization. Ottawa: Unmanned Systems Canada.

Unmanned Systems Canada. 2014. ‘‘What Is UnmannedSystems Canada?’’ Accessed 2 June 2014 at http://www.unmannedsystems.ca/content.php?doc=2.

Whitehead, K. 2011. ‘‘New Kid in the Sky.’’ ProfessionalSurveyor Magazine. Aerial Mapping. Accessed 15 April 2014at http://archives.profsurv.com/magazine/article.aspx?i=70889.

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Appendix

Table A.1: Institutions Listed in Transport Canada Issued SFOCs 2007–2012

Institution Name N %

ING Engineering Inc. 30 4.9

Aeyron Labs Inc. 15 2.4

Memorial University of Newfoundland 11 1.8

Universal Wings Geophysics Corp. 10 1.6

Carleton University 9 1.5

AeroGeoNautics Inc. 9 1.5

Provincial Airlines Lmt. 8 1.3

Ontario Provincial Police 8 1.3

Draganfly Innovations Inc. 8 1.3

Visionair UAV—Quebec Inc. 7 1.1

Digital Aerials Limited 6 1.0

NuvAero Flight Systems 6 1.0

Saskatoon Police Force 5 .8

Canadian Centre for Unmanned Vehicle Systems 4 .6

Accuas Inc. 4 .6

Ag Business and Crop Inc. 4 .6

Simon Fraser University 4 .6

Services De Drones Canadiens Inc.—Drone Solutions 4 .6

Sherbrooke University 4 .6

Micropilot 3 .5

Zinger Photographics 3 .5

Fugro Airborne Surveys Corp. 3 .5

University of Waterloo 3 .5

Talon Positioning Solutions 3 .5

Prince Albert Police Service 3 .5

Brican Automated Systems 3 .5

University of Victoria 3 .5

Royal Canadian Mounted Police 3 .5

New Heights Aerial Photography 3 .5

Matrix Solutions 3 .5

Remote Sensing Solutions Inc. 3 .5

Canada’s Mastermind Development Corporation 3 .5

Fourth Dimension Aerial Cinematography 3 .5

University of New Brunswick 3 .5

University of Calgary 2 .3

Air Quest Heli Cam 2 .3

Fugro Aviation Canada Limited 2 .3

Remote Aerial Tripod Specialists Inc. 2 .3

MacDonald, Dettwiler and Associates Ltd. 2 .3

Regina Police Service 2 .3

WineHawk 2 .3

JZAerial 2 .3

University of Alberta 2 .3

Skyline Media 2 .3

McGill University 2 .3

Helinutz Remote Sensing Inc. 1 .2

Quanser Consulting Inc. 1 .2

Advanced Subsonices Inc. 1 .2

Directed Flight Inc. 1 .2

Defence Research and Development Canada 1 .2

Meggitt Training Systems Canada 1 .2

Air Quest Heli Cam 1 .2

Halton Regional Police Service 1 .2

Institution Name N %

UofT Institute for Aerospace Studies 1 .2

Aeronautics Ltd. 1 .2

EnergyOr Technology Inc. 1 .2

Air View Concept 1 .2

Unmanned Systems Canada 1 .2

Canadian Police Research Centre 1 .2

Skyreel Aerial Imaging 1 .2

Chaos Choppers 1 .2

Vangaurd Defense Industries 1 .2

Telik Developments Inc. 1 .2

Helios Global Tracking Ltd. 1 .2

Centre de Geomatique du Quebec 1 .2

Ecole de Technologie Superieure (Drono Lab) 1 .2

Surete du Quebec 1 .2

Redacted 373 60.4

Table A.2: Province Listed in Transport Canada Issued

SFOCs 2007–2012

SFOC Issued by Province n %

Manitoba 189 30.6

Ontario 165 26.7

British Columbia 132 21.4

Quebec 41 6.6

Alberta 26 4.2

Newfoundland 24 3.9

Saskatchewan 23 3.7

New Brunswick 17 2.8

Nova Scotia 1 .2

Total 618 100.0

The ‘‘Rise’’ of Unmanned Aerial Vehicles (UAVs) in Canada: An Analysis of Special Flight Operation Certificates (SFOCs) 221

doi:10.3138/cpp.2014-038 8 Canadian Public Policy / Analyse de politiques, September / septembre 2015

Table A.3: Type of UAV Issued Transport Canada SFOCs 2006–2012

Type of UAV n %

Draganflyer 100 .8

Multiple Vehicles 77 .3

Outlander 28 1.6

Cinestar 25 1.3

NuvAero 19 .3

T-rex 17 .2

Gatewing 17 2.8

CropCam 13 1.6

Droidworx AD 13 1.8

Sensefly Swinglet 12 1.6

Swinglet 12 .2

Bergen Observer EB 11 .2

Aerosonder MK4.2 10 .3

Regulus 3.5 Airship 10 .5

Hirobo Shuttle 10 .3

Aeryon 10 4.5

ROTOMOTION SR200 8 .2

Heroin 7 16.2

Quadcopter 7 .3

Microkopter Haxacopter 7 .5

Multirotor GAUI 7 .2

Senior Telemaster 6 .2

Serenity 6 .2

VAMUdes 5 2.1

AI Multi 5 1.1

Maveric 5 .2

Geosurv II 4 .3

ING SUAS 4 .2

QR1.0 3 1.6

Procerus Flying Wing 3 .6

Vario Helicopter 3 1.0

Logo 600 3 .5

BriCan TD 100 3 .3

Bergen Hexacopter 3 .8

ATB 2 .3

Century Helicopter 2 .2

Electra Pro 2 .5

Seascan Georanger 2 .2

FIU-301 2 .3

MP Vision 2 1.9

Maxi Joker 2 2 .2

Protos MSH 500 2 1.1

JR Voyager 2 .3

Winehawk Curtiss 2 .5

Nextor Condor RC 2 .8

MISKAM 2 1.0

Parrot AR 2 .2

Sub-scale powered parafoil 2 .2

Microkopter Oktocopter 2 .2

Electric Flight Hawkeye 2 3.1

Jdrone 2 2.8

Vindicator 2 1.9

RC Multirotor 2 2.1

Peregrine 1 1 .2

Giles 200 1 .2

Type of UAV n %

Helicoppter 1 .6

Hobbico Nexstar RC 1 .3

Hyperion 1 .2

Kadet Senior 1 .3

Waterstrider 1 .3

Custom Designed Mobb Helicopter 1 .2

Autocopter Express 1 1.1

Flying Cam 1 4.0

Align 1 .3

Zephyr 1 .2

Dominator XP 1 .3

Robostar 1 .3

ShadowHawk 1 .3

Cyberquad Maxi 1 1.1

Multiplex Mentor 1 .2

COBRA quad 1 .3

Responder 1 .2

Skywalker V6 1 .3

Venturer 1 12.5

Hobby King 1 .5

AFS Skate 1 .2

PIXY Paraplane 1 .2

Helicopter avec 4 rotors 1 .2

Redacted 82 13.3

Table A.4: Flight Purpose Listed in Transport Canada

Issued SFOCs 2006–2012

Flight Purpose N %

Aerial photography 258 41.7

Research and development 106 17.2

Multiple purposes 102 16.5

Aerial demonstration 44 7.2

Flight training 30 4.9

Aerial surveying 12 1.9

Advertising 10 1.6

Agriculture 9 1.5

UVS Canada student competition 9 1.5

Remote aerial inspection 7 1.1

Wildlife management 4 .6

Geophysical research 2 .3

Search flights 2 .3

Aerial surveillance and reconnaissance 1 .2

Redacted 22 3.6

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