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What may I carry, and what may I shine?

Basic OperationsAdvanced OperationsLevel 1 Complex5 citations

Unofficial translation: 中文译本 →

What you will know

Know which payloads are prohibited and what an SFOC does about them, and know the separate regime that governs projecting a laser or any directed bright light source into airspace — including the case where the equipment is exempt from it.

Two different regimes meet on the same aircraft. What the aircraft carries is governed by section 901.43. What it projects into airspace, and who may fly into that beam, is governed by sections 601.20 to 601.22. CAR 901.43 CAR 601.20

Before this lesson

  • You know what your aircraft will be carrying, in the sense the section uses: not its camera bag, but any payload attached to or transported by the aircraft. CAR 901.43
  • You know the class of any laser on board, because the exemption turns on it. AIM 3.2.31
  • You know that an SFOC is a separate instrument from a declaration, and that section 901.43 names it as the exception. CAR 901.43

How it works

1. Three payload prohibitions, and one conditional one

No pilot shall operate a remotely piloted aircraft system if the aircraft is transporting a payload that: includes weapons, ammunition or other equipment designed for use in war; could create a hazard to aviation safety or cause injury to persons; or is attached to the aircraft by means of a line, unless the operation is conducted in accordance with the operating manuals applicable to the system. CAR 901.43

Read the third one carefully, because it is the only one with an ordinary route out: a payload on a line is not prohibited outright — it is prohibited unless the manuals allow that operation, which puts the answer in your own documentation. CAR 901.43

The first two have a different route: a pilot may operate with such a payload if the operation is conducted in accordance with a special flight operations certificate — RPAS issued under section 903.03. CAR 901.43

2. A laser is a payload, and also a light source in airspace

No person shall project, or cause to be projected, a directed bright light source into navigable airspace in such a manner as to create a hazard to aviation safety, or to cause damage to an aircraft or injury to persons on board. CAR 601.20

That prohibition is expressly subject to section 601.21, which is where the authorization regime lives. CAR 601.20

3. You request the authorization before you project, and you need it in writing

A person planning to project a directed bright light source into navigable airspace shall, before the projection, submit a written request to the Minister for authorization, and obtain a written authorization. CAR 601.21

The Minister shall issue the authorization if the projection is not likely to create a hazard to aviation safety or to cause damage to an aircraft or injury to persons on board, and may specify any conditions necessary to ensure that. CAR 601.21

Three features are worth holding on to: the request comes before the projection; the authorization must be written; and the conditions on it are part of the authorization, not advice. CAR 601.21

4. The pilot's side of it: do not fly into the beam

No pilot-in-command shall intentionally operate an aircraft into a beam from a directed bright light source, or into an area where such a source is projected, unless the aircraft is operated in accordance with an authorization issued by the Minister. CAR 601.22

The Minister may issue that authorization if the operation of the aircraft is not likely to create a hazard to aviation safety. CAR 601.22

Note that this is a rule about the pilot of the aircraft flying into the beam — including the pilot of a remotely piloted aircraft — and that its trigger is intentional operation. It is a different duty from the one on the person doing the projecting. CAR 601.22

5. The equipment that needs no authorization at all

Class 1 lasers, as designated by Health Canada, are considered incapable of causing harm and will not create a hazard to traditional aircraft provided they are operated as per the manufacturer's specifications. AIM 3.2.31

The specific exemption from assessment and notification requires all three: the equipment is classified Class 1 or Class 1M; it has an average output power of less than 1 mW; and it uses a non-visible beam. AIM 3.2.31

If it is anything else, the operator must notify Transport Canada of the intention to operate a laser in airspace shared with traditional aircraft, complete a Notice of Proposal to Conduct Outdoor Laser Operation(s) and submit it to the regional office, where an aeronautical assessment is made and the operator's NOHD calculation is validated. Normal processing takes at least 30 days. AIM 3.2.31

The exemption is not a licence to stop caring: the operator remains responsible for safe operation within the manufacturer's specifications. AIM 3.2.31

6. Keep the two regimes apart

Question Governed by
What the aircraft may carry 901.43, with an SFOC as the exception CAR 901.43
What may be projected into navigable airspace 601.20, subject to the authorization in 601.21 CAR 601.20
Who may fly an aircraft into the beam 601.22, on the pilot-in-command CAR 601.22
Equipment exempt from assessment and notification Class 1 or 1M, under 1 mW, non-visible beam AIM 3.2.31

7. The regime that sits outside Part IX: carrying things for others

A payload is not only a 901.43 question. The AIM adds the two regimes that apply because the aircraft is an aircraft, and neither of them is Part IX:

  • before transporting items of any kind from one location to the next, the Canadian Transportation Agency's Air Transportation Regulations must be considered — they are outside the scope of Part IX, they apply whether the operation is under Subpart 1 or under an SFOC-RPAS, and the exceptions inside them are the reason they have to be considered for all operations; and
  • before transporting goods that may be dangerous, the Transportation of Dangerous Goods Act must be consulted, and if they are in fact dangerous it says what is required — with CAR 901.43 deciding when an SFOC-RPAS is needed for a payload that is also dangerous. AIM 3.2.31

The reason both reach a remotely piloted aircraft is stated in the same passage: an RPA is an aircraft under the CARs, and the Act and the Agency do not separate RPAs from other aircraft — they simply say "aircraft". AIM 3.2.31

And the duty that ties it together is placed on one person: it is the responsibility of the RPA pilot to ensure compliance with all regulations before an RPAS operation. Not the manufacturer, not the operator, not the region. AIM 3.2.31

Your checklist

Your flight is compliant only when all of the following hold:

  • No payload is a weapon, ammunition or war equipment, or otherwise hazardous, or carried under an SFOC CAR 901.43
  • Any line-attached payload is permitted by the applicable operating manuals CAR 901.43
  • Any directed bright light source you project into navigable airspace is under a written authorization, requested beforehand CAR 601.21
  • No aircraft is intentionally flown into a beam or projected area without an authorization CAR 601.22
  • Laser equipment that is not Class 1/1M, under 1 mW and non-visible has been the subject of a Notice of Proposal, with at least 30 days allowed AIM 3.2.31
  • Before carrying anything from one place to another, the CTA's Air Transportation Regulations have been considered, and the TDG Act consulted where the goods may be dangerous AIM 3.2.31

Warning "It is only a laser pointer" is not a defence under 601.20. The prohibition is on projecting a directed bright light source into navigable airspace in a manner that creates a hazard — the equipment's size is irrelevant to that test, and the exemption is defined by three specific characteristics, not by the equipment's appearance. CAR 601.20 AIM 3.2.31

Where people go wrong

Symptom Likely cause What to do
Your survey payload includes a LIDAR unit Laser equipment other than the exempt class needs notification Apply under 601.21, allowing at least 30 days AIM 3.2.31
You are carrying a payload on a line 901.43(d) prohibits it unless the operating manuals allow it Check the manuals CAR 901.43
Your payload could cause injury to persons 901.43(c) prohibits it without an SFOC Apply for an SFOC under 903.03, or do not carry it CAR 901.43
You have authorization to project and want to fly into the beam The pilot's authorization is a separate one, under 601.22 Obtain that authorization too CAR 601.22
You planned a laser operation for next week Normal processing is at least 30 days Plan further ahead AIM 3.2.31
Your Class 1 laser has a visible beam The exemption requires all three characteristics Treat it as requiring notification AIM 3.2.31

Test yourself

Sources

  • CAR 601.20 — Projection of Directed Bright Light Source at an Aircraft
  • CAR 601.21 — Requirement for Notification
  • CAR 601.22 — Requirement for Pilot-in-command
  • CAR 901.43 — Payloads
  • — Payloads
  • Consolidation: CARs current to 2026-09-21

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Lesson 36 of 50 in Basic Operations

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