What you will know
Know the age and certificate each division requires of the person operating, and know exactly what the supervision exception does and does not excuse in each of them.
Before this lesson
- You know which division the flight falls under, because there are three different answers and the division picks one. CAR 901.54
- You know the certificate names: basic operations under 901.55, advanced operations under 901.64, level 1 complex operations under 901.90. CAR 901.63
- You can tell the person operating from the person supervising, because the exception moves the requirement from one to the other. CAR 901.89
How it works
1. Three sections, three age floors
The same prohibition is written three times with a different number in it: CAR 901.54 CAR 901.63 CAR 901.89
| The division | Minimum age | The certificates that satisfy it |
|---|---|---|
| Division IV — basic operations (901.54) | 14 CAR 901.54 | Basic (901.55), advanced (901.64) or level 1 complex (901.90) CAR 901.54 |
| Division V — advanced operations (901.63) | 16 CAR 901.63 | Advanced (901.64) or level 1 complex (901.90) — a basic certificate does not CAR 901.63 |
| Division VI — level 1 complex operations (901.89) | 18 CAR 901.89 | The level 1 complex certificate (901.90) only CAR 901.89 |
Read the middle row's list closely: advanced operations accept the advanced or the level 1 complex certificate, and not the basic one. CAR 901.63
2. Age alone is never enough
Each section joins the age to the certificate with and: at least 14 and holds one of the listed certificates, at least 16 and holds one, at least 18 and holds the level 1 complex certificate. CAR 901.63
So an adult who holds no pilot certificate does not satisfy the section — being old enough is one half of a two-part requirement, and the certificate half is the one that takes work. CAR 901.63
3. The supervision exception, in each section's own words
Each section carries a subsection (2) that disapplies subsection (1). They are not identical: CAR 901.54 CAR 901.63 CAR 901.89
| Section | When subsection (1) does not apply |
|---|---|
| 901.54(2) | The operation is conducted under the direct supervision of a person permitted to operate such a system under this Division, Division V or Division VI CAR 901.54 |
| 901.63(2) | The operation is conducted under the direct supervision of a person permitted to operate such a system under this Division or Division VI CAR 901.63 |
| 901.89(2) | The operation is for the purpose of training and conducted under the direct supervision of a person who is 18 or older and permitted to operate under the Division CAR 901.89 |
The third row is the narrow one, and it narrows in two ways at once: the flight has to be training, and the supervisor has to be 18 or older and qualified to operate under that Division themselves. CAR 901.89
4. What the AIM says about the youngest case
The AIM states the under-14 case in one sentence: a person less than 14 years of age may conduct basic operations if they are under the direct supervision of the holder of a basic or advanced RPA pilot certificate. AIM 3.3.2
That is the practical shape of 901.54(2): the certificate requirement does not vanish, it moves to the person doing the supervising. CAR 901.54
Your checklist
| Question | The answer |
|---|---|
| Minimum age, basic and advanced Division (901.54)? | 14, with a basic, advanced or level 1 complex certificate CAR 901.54 |
| Minimum age, advanced operations (901.63)? | 16, with an advanced or level 1 complex certificate CAR 901.63 |
| Minimum age, level 1 complex operations (901.89)? | 18, with the level 1 complex certificate CAR 901.89 |
| Is an adult without a certificate qualified? | No — the section requires age and certificate CAR 901.63 |
| What excuses the requirement? | Direct supervision, as each subsection (2) defines it CAR 901.63 |
| What is special about 901.89(2)? | It applies to a training operation, and the supervisor must be 18+ CAR 901.89 |
- The three floors are 14, 16 and 18 CAR 901.54 CAR 901.63 CAR 901.89
- A basic certificate does not satisfy the advanced-operations section CAR 901.63
- Supervision must be direct CAR 901.54
- Under Division VI the exception is limited to training CAR 901.89
Where people go wrong
| Symptom | Likely cause | What to do |
|---|---|---|
| One age is applied to every division | There are three | Pick the division first CAR 901.63 |
| A basic certificate is offered for advanced operations | The list excludes it | Use advanced or level 1 complex CAR 901.63 |
| Age alone is treated as qualifying | The requirement is age AND certificate | Check the certificate CAR 901.63 |
| The supervision exception is applied to any flight under Division VI | It is limited to training | Keep it to the training case CAR 901.89 |
| The supervisor's own qualification is not checked | The subsection names it | Confirm they may operate under that Division CAR 901.89 |
| "Supervision" is read loosely | Every subsection says direct | Make it direct CAR 901.54 |
Test yourself
Sources
- CAR 901.54 — Pilot Requirements (basic and advanced Division)
- CAR 901.63 — Pilot Requirements (advanced operations)
- CAR 901.89 — Pilot Requirements (level 1 complex operations)
- TC — Pilot Requirements