What you will know
Know what "operate it in accordance with the applicable operating manuals" requires of you, why the manufacturer's limits are the ones that count, and which kind of automated system the Regulations let you fly.
Before this lesson
- You know your aircraft's operating manual, because that is the document the section names. CAR 901.31
- You know the aircraft's system and environmental limitations — temperature, wind, centre of gravity and the rest — because they are the boundary the rule is about. AIM 3.2.19
- You can tell an automated system from an autonomous one, which is the distinction the second half of this lesson turns on. AIM 3.2.20
How it works
1. The rule: fly it as the manual says
Section 901.31 is one sentence: no pilot shall operate a remotely piloted aircraft system unless it is operated in accordance with the applicable operating manuals. CAR 901.31
The AIM supplies the reasoning behind it. An RPAS is a complex system with system and environmental limitations that are what allow it to operate in a predictable manner, and operating within the manufacturer's operating instructions is what ensures its maximum reliability. AIM 3.2.19
2. Operating outside the limitations
The consequence follows from that reasoning rather than from a separate rule: an aircraft flown outside its system and environmental limitations cannot be relied on to behave predictably, and the operation is no longer in accordance with the manual. AIM 3.2.19
The stated exposure is individual penalties of up to $1,000 and corporate penalties of up to $5,000. AIM 3.2.19
A scenario makes it concrete: launching when the temperature at the site is outside the range given in the manufacturer's operating instructions for that model is not a judgement call about how the conditions look — it is operating outside the manual. CAR 901.31
3. The other rule: the aircraft must let you intervene
Section 901.32 is also one sentence: no pilot shall operate a remotely piloted aircraft system that is not designed to allow pilot intervention in the management of a flight. CAR 901.32
Read what it regulates: not the pilot's attention, but the design of the system. A system designed so that the pilot cannot intervene is one the Regulations do not let you fly at all. CAR 901.32
4. Automation is not autonomy
The AIM draws the line carefully, because the two words are used interchangeably in ordinary speech: AIM 3.2.20
| Automation | Autonomy | |
|---|---|---|
| Nature | A deterministic system behaving predictably by pre-set rules AIM 3.2.20 | A goal-based system, not deterministic AIM 3.2.20 |
| Output | The same output for the same inputs, user error aside AIM 3.2.20 | The path may not be easily predicted; it may model behaviours producing unique outcomes each time AIM 3.2.20 |
| The example | A pilot plotting a route on the control station and the aircraft following it on autopilot while the pilot monitors the flight AIM 3.2.20 | An RPA operating without pilot intervention, possibly with no mechanism for it by design AIM 3.2.20 |
An autonomous RPA may react to changing conditions or system degradations in a manner it determines on its own — which is exactly the case section 901.32 addresses. AIM 3.2.20
5. The prohibition, stated as the AIM states it
RPA pilots are not permitted to operate autonomous RPAs for which they are unable to take immediate control of the aircraft. The phrasing matters: the prohibition bites on the combination — an autonomous system and the absence of immediate control — rather than on autonomy alone. AIM 3.2.20
The stated exposure is the same pair as for the manual: up to $1,000 individually and up to $5,000 for a corporation. AIM 3.2.20
Your checklist
| Question | The answer |
|---|---|
| What does 901.31 require? | Operating the system in accordance with the applicable operating manuals CAR 901.31 |
| Why do the manufacturer's limits matter? | System and environmental limitations are what make operation predictable, and operating inside them is what ensures maximum reliability AIM 3.2.19 |
| What does 901.32 prohibit? | Operating a system not designed to allow pilot intervention in the management of a flight CAR 901.32 |
| What is automation? | A deterministic system behaving by pre-set rules, producing the same output for the same inputs AIM 3.2.20 |
| What is autonomy? | A goal-based, non-deterministic system that may act without pilot intervention AIM 3.2.20 |
| Which autonomous RPA may not be flown? | One for which the pilot is unable to take immediate control AIM 3.2.20 |
- Flying outside the environmental limits is flying outside the manual AIM 3.2.19
- The autopilot case is an example of automation, not autonomy AIM 3.2.20
- 901.32 goes to the design of the system, not to the pilot's skill CAR 901.32
- Both rules state the same exposure: up to $1,000 individual, up to $5,000 corporate AIM 3.2.19 AIM 3.2.20
Where people go wrong
| Symptom | Likely cause | What to do |
|---|---|---|
| "Conditions look fine" is offered as a reason to fly outside the limits | The rule is the manual, not the look of the sky | Stay inside the stated range CAR 901.31 |
| Automation and autonomy are treated as synonyms | The AIM separates them | Use the deterministic test AIM 3.2.20 |
| An aircraft that follows a plotted route is called autonomous | It is the AIM's automation example | It is automation AIM 3.2.20 |
| The penalty figures are reversed | Individual is the smaller | $1,000 individual, $5,000 corporate AIM 3.2.20 |
| 901.32 is answered as a duty to watch the aircraft | The section is about design | Answer with pilot intervention in the management of the flight CAR 901.32 |
Test yourself
Sources
- CAR 901.31 — Operating Manuals
- CAR 901.32 — Control of Remotely Piloted Aircraft Systems
- TC — Manufacturer's Instructions
- TC — Control of RPAS