Level 1 Complex: the two gates an operator passes, and the training behind the certificate

Know which operations Division VI governs, what the two requirements in section 901.88 actually say, where the age minimum lives, and what a ground school training provider has to have in place before it may deliver the instruction the certificate depends on.

• You know that Division VI is the Level 1 Complex regime, and that it sits above Basic and Advanced rather than beside them. CAR 901.87
• You know the small and medium classes by operating weight, because the two paragraphs of section 901.87 are split along that line. CAR 901.87
• You know what an RPAS operator certificate is: the operator-side document, not the pilot's. CAR 901.88

Section 901.87 states the application of the Division in two paragraphs: CAR 901.87

Paragraph	The operation
(a)	A small or medium RPA conducting a BVLOS operation in uncontrolled airspace and not less than 1 km from a populated area CAR 901.87
(b)	A small RPA conducting a BVLOS operation in uncontrolled airspace over a sparsely populated area, or less than 1 km from a populated area CAR 901.87

The AIM restates the same two cases and attaches the declaration each one leans on: the 901.87(a) operation with a safety assurance declaration, and the 901.87(b) operation — the small aircraft case — with a pre-validated declaration. AIM 3.4.2 AIM 3.4.2

Note which class is missing from paragraph (b): a medium RPA has no sparsely-populated-area operation under Division VI. CAR 901.87

Section 901.88 is short and has two limbs: no person shall operate a remotely piloted aircraft system under this Division unless the person CAR 901.88

• is an RPAS operator, or an employee, agent, mandatary or representative of one; and
• complies with the conditions in the RPAS operator certificate issued to that operator. CAR 901.88

Both limbs must hold, and the second is where the certificate does its work: the operator holds the certificate, and the person flying complies with its conditions. CAR 901.88

Two things section 901.88 does not say, because they are the answers to two questions built on its silence. It states no minimum age — that requirement is in section 901.89, not here — and its prohibition is confined to operations under this Division, so it is not a prohibition on every RPAS operation everywhere. CAR 901.88 CAR 901.89

Section 901.89 requires the person operating under the Division to be at least 18 years of age and to hold a pilot certificate — remotely piloted aircraft — level 1 complex operations issued under section 901.90. CAR 901.89

There is one exception, and it is narrow: the subsection does not apply where the operation is for the purpose of training and is conducted under the direct supervision of a person who is 18 or older and who is permitted to operate under the Division. Training flights are the one place the certificate requirement steps aside, and only while that supervision is in place. CAR 901.89

The level 1 complex certificate requires 20 hours of ground school instruction delivered by a training provider referred to in section 901.182, so the provider's own obligations are part of the chain. No training provider may deliver that instruction unless it has CAR 901.182 CAR 901.90

• made a declaration to the Minister in accordance with section 921.08 of Standard 921; and
• appointed a chief ground instructor responsible for the delivery of the instruction. CAR 901.182

And the appointment is not a one-time filing: the provider must inform the Minister within 30 days after any change in the appointment of a chief ground instructor. A question that offers the 30-day rule as applying only to the first appointment is describing something narrower than the section. CAR 901.182

Section 901.88 and 901.89 say who may fly. The AIM's 3.4.2.3 says what must be true of the flight, and its list is worth reading as a list because the exam draws from it item by item: AIM 3.4.2

• uncontrolled airspace only, per section 901.87;
• at 400 ft (122 m) AGL or below, per section 901.25;
• more than 5 NM (9.3 km) from the centre of aerodromes listed in the CFS or the CWAS, per section 901.47;
• familiarity with the information relevant to the flight — including the site survey's distance from any populated area or sparsely populated area, the safety assurance declaration for the model being used, and the qualifications of all crew members;
• the RPAS operator's operations manual immediately available to crew members, per section 901.30;
• ground visibility not less than 3 NM (5.6 km) with the aircraft clear of cloud, per section 901.34; and
• anti-collision lights fitted and turned on, per subsection 901.38.1. AIM 3.4.2

The aerodrome item is the one to read twice. The ring is 5 NM (9.3 km), and it is measured from the centre of aerodromes listed in the Canada Flight Supplement or the Canada Water Aerodrome Supplement — not from every aerodrome in Canada, which is the version of the rule a question offers as a true-or-false. The distance itself is set by section 901.47, which is why the AIM's item reads "as per CARs section 901.47". Transport Canada's own page states the same three limits together — uncontrolled airspace, 400 ft (122 m) AGL or below, more than 9.3 km (5 NM) from the centre of CFS or Water Aerodrome Supplement aerodromes — which is the reader-facing version of the same list. AIM 3.4.2 CAR 901.47 TC Level 1 Complex Operations

Gate one is a list of relationships, and ownership is not on it. A pilot who personally owns a registered and marked RPA with a valid Standard 922 declaration still may not conduct a level 1 complex operation unless the pilot is an RPAS operator or is the employee, agent, mandatary or representative of one, complying with that operator's certificate conditions. CAR 901.88

The same requirement decides who may come from abroad. Foreign individuals and foreign commercial operators are not eligible to hold an RPOC, but they can conduct level 1 complex operations by flying with a Canadian organization that holds one. TC Apply RPAS Operator Certificate RPOC

The step	What it requires	Section
The operation is Level 1 Complex	BVLOS in uncontrolled airspace, ≥ 1 km from a populated area (small or medium); or over a sparsely populated area / < 1 km (small only) CAR 901.87	901.87
The person is attached to an operator	An RPAS operator, or its employee, agent, mandatary or representative, complying with the certificate's conditions CAR 901.88	901.88
The pilot is qualified	At least 18, holding the level 1 complex pilot certificate — with the supervised training exception CAR 901.89	901.89
The instruction is legitimate	A provider with a Standard 921.08 declaration and an appointed chief ground instructor CAR 901.182	901.182
The flight itself	Uncontrolled airspace, at or below 400 ft (122 m) AGL, more than 5 NM (9.3 km) from CFS/CWAS aerodromes, 3 NM (5.6 km) ground visibility and clear of cloud, anti-collision lights on AIM 3.4.2	AIM 3.4.2.3
Who may fly under the certificate	An RPAS operator, or its employee, agent, mandatary or representative — owning the aircraft is not enough CAR 901.88	901.88
A foreign pilot or operator	Not eligible to hold an RPOC, but may fly with a Canadian organization that holds one TC Apply RPAS Operator Certificate RPOC	TC guidance

• Section 901.88 says nothing about age; the age is in 901.89 CAR 901.88
• Section 901.88 binds Division VI operations, not every operation CAR 901.88
• The operator holds the certificate; the person flying complies with its conditions CAR 901.88
• The training exception needs direct supervision by an 18+ person permitted to operate CAR 901.89
• A chief ground instructor change is notified within 30 days, not only the first appointment CAR 901.182
• The aerodrome ring is 5 NM (9.3 km) and runs from CFS or CWAS aerodromes, not every aerodrome in Canada AIM 3.4.2
• Owning the aircraft is not one of the relationships in 901.88 CAR 901.88

Symptom	Likely cause	What to do
A question asks where the age minimum is	Not 901.88	Section 901.89 sets 18 CAR 901.89
The 901.88 prohibition is read as applying to all operations	It is confined to the Division	Check whether the operation is under Division VI CAR 901.88
The certificate is assumed to be the pilot's	It is the operator's	The pilot complies with its conditions CAR 901.88
A medium RPA is offered a sparsely-populated-area operation	Paragraph 901.87(b) is small-aircraft only	Check the class before the location CAR 901.87
The 30-day notification is read as first-appointment-only	The section says any change	Notify on every change CAR 901.182
The training carve-out is read as removing the pilot requirement generally	It is limited to training flights under direct supervision	Keep the supervision in place CAR 901.89
The 5 NM ring is applied to every aerodrome in the country	The AIM names the aerodromes listed in the CFS or the CWAS	Check the listing before applying the ring AIM 3.4.2
You own the aircraft, so you assume you may fly the operation	Ownership is not one of the 901.88 relationships	Fly as an operator, or as its employee, agent, mandatary or representative CAR 901.88
A foreign operator asks whether it needs its own RPOC	Foreign individuals and operators cannot hold one	Fly with a Canadian organization that holds an RPOC TC Apply RPAS Operator Certificate RPOC

Practise: Division VI – Level 1 Complex Operations

Practise: Aerodromes l1c separation

Practise: Area, RPAS operator, RPAS operator certificate

Practise: Division XII – RPAS Operator Certificate

• CAR 901.87 — Application (Division VI)
• CAR 901.88 — Requirement for RPAS Operator Certificate
• CAR 901.89 — Pilot Requirements
• CAR 901.90 — Issuance of Pilot Certificate — Level 1 Complex Operations
• CAR 901.182 — Training Provider Requirements — RPAS Ground School Instruction
• TC AIM RPA 3.4.2 — General — Level 1 Complex Operations (3.4.2.1 application, 3.4.2.3 operating list)
• Transport Canada — Apply for an RPAS Operator Certificate (RPOC)