From the pilot's report to the annual report: the service-difficulty loop

Know the four links that carry a service difficulty from the person who finds it to the Minister who is entitled to see it: who reports it, to whom, what the declarant must run in order to receive it, what is sent to the Minister every year, and what has to be sent as soon as it happens.

• You know whether the model you fly has both a declaration under section 901.194 and an acceptance letter under section 901.196, because every duty on this page is conditioned on that pair. CAR 901.51
• You can tell a reportable service difficulty from ordinary wear or a pilot error, since only the former triggers the reporting duty. CAR 901.51
• You know who made the declaration for the model — the person the report goes to. CAR 901.194

A service difficulty travels in one direction and through three hands. The pilot who discovers it reports it to the person who made the declaration; that person runs a service difficulty reporting system to receive, record, analyse and investigate it; and the results reach the Minister through an annual report, or immediately through a notice when the deficiency is serious enough. CAR 901.51 CAR 901.197 CAR 901.199

Every link is conditioned on the same pair of facts: a declaration made under section 901.194 for the model, and an acceptance letter issued under section 901.196 for it. CAR 901.195

Section 901.51 is short, and each of its parts is load-bearing. The pilot of a system of a model for which a declaration has been made and an acceptance letter has been issued must ensure that any reportable service difficulty discovered with respect to the system is reported to the person who has made the declaration, as soon as feasible after the discovery. CAR 901.51

Three things follow. The recipient is the declarant, not Transport Canada and not the operator the pilot happens to work for. The trigger is discovery, not a decision about how serious it is. And the clock is "as soon as feasible" — which is why holding a report back to gather more detail first is the wrong answer to a question about timing. CAR 901.51

The Minister issues an acceptance letter in respect of a model of RPAS once the applicant demonstrates the ability to: CAR 901.196

The ability	What it covers
Verify	That the model meets the technical requirements set out in Standard 922 for which the applicant proposes to declare CAR 901.196
Run a reporting system	Establish and maintain a service difficulty reporting system meeting section 901.197 CAR 901.196
Ensure consistency	For a manufacturer of an element of the system, ensure production consistency; for a provider of a service that is an element, ensure consistent activation and delivery of the service CAR 901.196

The letter is therefore about a capability, and the reporting system is not an afterthought to it: it is the second of the three abilities, which is why the obligation to keep one running survives for as long as the model is declared. CAR 901.196

Where a declaration has been made for a model for which an acceptance letter has been issued, the declarant shall establish and maintain a service difficulty reporting system for the purpose of receiving, recording, analysing and investigating reports and information about any reportable service difficulty related to that model. CAR 901.197

The system must include two things: a means for receiving those reports and information, and instructions regarding what information must be submitted to the declarant. It is a system, not an inbox — the analyse and investigate half of the purpose is what the annual report later accounts for. CAR 901.197

The declarant of a model for which an acceptance letter has been issued submits an annual report to the Minister in respect of that model. It contains four things: CAR 901.199

• the name of the person submitting it;
• the name of the model;
• the actual, if available, or estimated total number of hours of operation in Canada of systems of that model during the year; and
• the number of reportable service difficulty reports received during the year, a summary of the reports in respect of which mandatory actions were developed, and a description of those actions. CAR 901.199

It is submitted each year by not later than the anniversary of the day the declaration was made — the declaration's date, not the acceptance letter's and not the calendar year end. CAR 901.199

Section 901.195 requires the declarant to notify the Minister of two things, and only two: CAR 901.195

What must be notified	The clock
Any deficiency related to the model that causes it to no longer meet the technical requirements specified under subparagraph 901.194(2)(a)(iv)	As soon as feasible after the deficiency is identified CAR 901.195
The fact that the person is no longer maintaining a service difficulty reporting system, if required to maintain one under section 901.197	On the day the person ceases to maintain it CAR 901.195

Read the first row carefully, because it is narrower than it sounds: the notice is triggered by a deficiency that takes the model out of the technical requirements it was declared against, not by every defect, and not by whether an accident or incident occurred. CAR 901.195

The notice has a consequence that is easy to miss. A notification under section 901.195 makes the declaration invalid — though only in respect of the operations described in paragraphs 901.69(f) and (g) and 901.87(b). CAR 901.194 CAR 901.195

The loop, as four questions:

• Who reports, to whom? The pilot, to the person who made the declaration, as soon as feasible after discovery CAR 901.51
• What must the declarant run? A service difficulty reporting system: a means of receiving reports, and instructions on what information must be submitted CAR 901.197
• What goes to the Minister every year? The submitter's name, the model's name, the hours of operation in Canada, and the service-difficulty numbers with any mandatory actions — by the declaration's anniversary CAR 901.199
• What cannot wait? A deficiency that takes the model out of its declared technical requirements (as soon as feasible), and ceasing to maintain the reporting system (that day) CAR 901.195

Section	Duty	On whom
901.51	Report a reportable service difficulty to the declarant, as soon as feasible CAR 901.51	The pilot
901.197	Establish and maintain the service difficulty reporting system CAR 901.197	The declarant, for a model with an acceptance letter
901.199	Submit the annual report by the declaration's anniversary CAR 901.199	The declarant, for a model with an acceptance letter
901.195	Notify deficiencies and the end of the reporting system CAR 901.195	The declarant

Symptom	Likely cause	What to do
A question asks where a service difficulty is reported	The recipient is the declarant	Report to the person who made the declaration, not to Transport Canada CAR 901.51
A report is held back to gather detail	The clock runs from discovery	Report as soon as feasible CAR 901.51
The annual report date is taken from the acceptance letter	The anniversary is the declaration's	Count from the day the declaration was made CAR 901.199
Only exact hours are given in the report	The section allows an estimate when the actual is unavailable	Give the actual if available, otherwise the estimate CAR 901.199
Every defect is notified to the Minister	Only a deficiency that breaks the declared requirements is	Check it against subparagraph 901.194(2)(a)(iv) first CAR 901.195
A service difficulty is found on a model with no acceptance letter	The pilot's reporting duty is conditioned on both documents	Check for the declaration and the acceptance letter CAR 901.51

Practise: Rpas service difficulty reporting

Practise: Acceptance letters

Practise: Rpas annual report

Practise: Declaration notice to minister

• CAR 901.51 — Service Difficulty Reporting
• CAR 901.194 — Declaration
• CAR 901.195 — Notice to the Minister
• CAR 901.196 — Issuance of Acceptance Letter
• CAR 901.197 — Establishing a Service Difficulty Reporting System
• CAR 901.199 — Annual Report