What you will know
Know the extra condition that applies when you fly by a first-person view device, and the two conditions that stop a flight because of ice.
These are grouped because they share a shape: each is an absolute prohibition with a narrow escape, and each catches pilots who checked everything else.
Before this lesson
- You know whether you are flying by a first-person view device rather than by looking at the aircraft. CAR 901.38
- You know the forecast and the aircraft's state before you launch — icing is assessed before flight and checked on the airframe.
- You know that using an FPV device outside Division VI needs a . CAR 901.38
How it works
1. If you fly by FPV, confirm a visual observer is watching beyond the screen
Unless the operation is conducted under Division VI, no pilot may operate using a first-person view device unless a visual observer maintains unaided visual contact with the airspace beyond the field of view displayed on the device, in order to detect conflicting air traffic and other hazards and take action to avoid them. CAR 901.38
Three things are doing work here. The observer's contact must be unaided — no binoculars. Their attention must be on the airspace beyond what your screen shows, because the screen is exactly what you cannot see past. And their duty includes taking action to avoid, not only reporting.
A first-person view device is defined in the section as a device that generates and transmits a streaming video image to a control station display or monitor, giving the pilot the illusion of flying from an onboard pilot's perspective. CAR 901.38
2. Check the forecast and the airframe for icing before you launch
No pilot may operate when icing conditions are observed, are reported to exist, or are likely to be encountered along the route of flight — unless the aircraft is equipped with de-icing or anti-icing equipment, or the pilot has a means to detect icing. CAR 901.35
Note the three triggers. "Observed" is what you can see; "reported to exist" is what someone else has seen; "likely to be encountered" is a forecast. So a forecast of icing conditions engages the rule before you have seen any ice.
3. Check the critical surfaces physically
No pilot may operate with frost, ice or snow adhering to any of the critical surfaces of the aircraft. CAR 901.35
There is no equipment exemption for this one. The de-icing allowance in step 2 applies to the first prohibition only; a contaminated airframe is prohibited outright.
The AIM supplies the vocabulary and the standard of care behind both rules. Icing is atmospheric water droplets that are often supercooled — below 0 °C — which freeze on contact with a surface. Its intensity is classified from trace to severe, and its types are rime, clear and mixed ice. It is common on all types of aircraft, and remotely piloted aircraft are no exception. AIM 3.2.23
Two things follow that the section alone does not say. First, icing can occur before and during flight, so a clean pre-flight check is a starting condition rather than a clearance. Second, the damage is not only aerodynamic: ice on the propeller and frame increases take-off weight, changes the aircraft's aerodynamic properties, and prevents components from operating properly. AIM 3.2.23
Critical surfaces — the AIM lists wings, control surfaces, rotors, propellers, and horizontal and vertical stabilizers — should be confirmed clear of contamination prior to takeoff and must remain so, or the flight be terminated. That second clause is the one to carry away: it makes contamination an in-flight abort condition, not only a launch check. AIM 3.2.23
And where the risk is known, the AIM states the default. Refer to the manufacturer's operating or flight manual to verify the aircraft's tolerance of icing — and in the absence of an RPAS Safety Assurance, it recommends that you avoid flying in icing conditions unless a method exists to de-ice and to provide anti-ice capability. The declaration is what changes that default; without one, the answer to "can I fly into this" is no. AIM 3.2.23
Critical surfaces are defined in the section as the wings, control surfaces, rotors, propellers, horizontal stabilizers, vertical stabilizers or any other stabilizing surfaces, as well as any other surfaces identified as critical in the operating manuals for the system. CAR 901.35
That last clause matters: your manual can add surfaces to the list, so it is part of the check.
Your checklist
You launch only when all of the following hold:
- If flying FPV outside Division VI, a visual observer has unaided contact with the airspace beyond the screen and can act CAR 901.38
- No icing conditions are observed, reported, or likely along the route — or you have de-icing/anti-icing equipment or a means to detect icing CAR 901.35
- No frost, ice or snow adheres to any critical surface, including any the manual names CAR 901.35
| Situation | What applies |
|---|---|
| FPV outside Division VI, no observer | Prohibited CAR 901.38 |
| FPV, observer watching the aircraft rather than the sky beyond the screen | Does not meet the requirement — the duty is airspace beyond the field of view CAR 901.38 |
| Icing forecast along the route, no anti-icing equipment | Prohibited — "likely to be encountered" is enough CAR 901.35 |
| Ice on the rotors | Prohibited outright — no equipment exemption applies to a contaminated airframe CAR 901.35 |
| Frost on a surface your manual calls critical | Prohibited — the manual extends the definition CAR 901.35 |
Where people go wrong
| Symptom | Likely cause | What to do |
|---|---|---|
| Your observer was watching the drone while you flew FPV | The duty is the airspace beyond the device's field of view | Re-brief, or fly without the device CAR 901.38 |
| The forecast mentioned icing but you saw none | "Likely to be encountered" is a separate trigger from observing it | Do not launch without equipment or a detection means CAR 901.35 |
| You have anti-icing equipment and frost on a rotor | The equipment allowance covers icing conditions, not a contaminated surface | Remove the frost before launch CAR 901.35 |
| You checked the surfaces your manual lists and ignored others | The definition names wings, control surfaces, rotors, propellers and stabilizers regardless | Check the named surfaces and the manual's additions CAR 901.35 |
Test yourself
Sources
— Icing
CAR 901.35 — Icing
CAR 901.38 — Use of First-person View Devices
Consolidation: CARs current to 2026-09-21