A visual observer for extended VLOS: which certificate, which eyes, how far away

Know the three conditions section 901.75 places on a visual observer performing extended VLOS duties, which certificate an observer must hold, and why an observer who watches through binoculars is not performing the duty the section describes.

• You know what an extended VLOS operation is, because the section applies to that operation and not to visual observing in general. CAR 901.75
• You know who is flying: the pilot and the observer are two different people with two different sets of duties. CAR 901.20
• You know the observer and the pilot must be able to talk to each other, because the observer's report is only useful if it arrives. CAR 901.20

Section 901.75 opens with a prohibition: no visual observer shall perform visual observer duties with respect to an extended VLOS operation under this Division unless the three conditions that follow are met. CAR 901.75

That scope matters, because the general rule is wider and looser. The AIM states that visual observers are not required to possess an RPA pilot certificate when they are crew members of a small RPA flown VLOS on basic or advanced operations — the exception being extended VLOS, which requires basic pilot certification as a minimum. So the certificate requirement is the extended-VLOS rule, not a general rule about observers. AIM 3.2.8 CAR 901.75

The observer must hold one of: CAR 901.75

Certificate	Issued under
Pilot certificate — small remotely piloted aircraft (VLOS) — basic operations	Section 901.55 CAR 901.75
Pilot certificate — remotely piloted aircraft — advanced operations	Section 901.64 CAR 901.75
Pilot certificate — remotely piloted aircraft — level 1 complex operations	Section 901.90 CAR 901.75

Any one of the three satisfies the paragraph — an observer holding only the level 1 complex certificate is qualified. The progression of certificates is not a minimum grade; it is a list of routes. CAR 901.75

One detail about that third route, because it is a separate question: the level 1 complex pilot certificate is issued only to an applicant who is at least 18 years of age, alongside the 20 hours of ground school, the two examinations and the flight review. CAR 901.90

The observer must maintain unaided visual contact with the airspace in which the remotely piloted aircraft is operating, in a manner sufficient to detect conflicting air traffic and other hazards and take action to avoid them. CAR 901.75

Two words do the work. Unaided rules out watching the aircraft through binoculars for the flight, however good the intent. And the contact is with the airspace — the observer is not merely keeping the aircraft in sight, but watching the volume around it for what is about to conflict with it. CAR 901.75

The observer must remain at a distance of not more than two nautical miles (3.7 km) from the remotely piloted aircraft at all times during the flight. It is a maximum separation, not a minimum, and the measurement runs from the aircraft rather than from the control station. CAR 901.75

The AIM describes the observer's working role rather than repeating the section: visual observers shall be trained to perform the duties assigned to them by the pilot — visual scanning techniques, aircraft identification, communications, and whatever else the role needs — and the pilot and observer shall remain in constant and immediate communication throughout the operation, as CAR 901.20 requires. Before the flight, the crew should agree on the language they will use. AIM 3.2.8 CAR 901.20

What the pilot needs from the observer is specific: the RPA's relative distance, altitude and flight path in relation to other aircraft, and the other hazards — terrain, weather, structures — reported well enough to prevent a collision hazard. The observer also helps keep the operational environment sterile, free of irrelevant conversation, so the pilot is not distracted. AIM 3.2.8

Condition in 901.75	What it requires
(a) Certificate	One of: basic operations (901.55), advanced operations (901.64), or level 1 complex operations (901.90) CAR 901.75
(b) Contact	Unaided visual contact with the airspace the RPA is in, sufficient to detect and avoid conflicting traffic and hazards CAR 901.75
(c) Distance	Not more than two nautical miles (3.7 km) from the aircraft, at all times CAR 901.75

• The duty is engaged by an extended VLOS operation under Division V CAR 901.75
• The observer holds one of the three certificates, not necessarily the highest CAR 901.75
• The contact is unaided, and it is with the airspace rather than only the aircraft CAR 901.75
• The separation is a maximum of two nautical miles CAR 901.75
• Pilot and observer stay in constant and immediate communication CAR 901.20

Symptom	Likely cause	What to do
A question says an observer needs no certificate at all	That is the basic/advanced crew rule	For extended VLOS, 901.75 requires one AIM 3.2.8
An observer holding only the L1C certificate is treated as unqualified	The list is alternatives	Any one of the three qualifies CAR 901.75
Binoculars are used for the whole flight	The contact must be unaided	Watch with the naked eye CAR 901.75
The two nautical miles are read as a minimum distance	It is a maximum separation	Keep the observer within two nautical miles CAR 901.75
The observer reports only where the aircraft is	The duty covers the airspace around it	Report conflicting traffic and other hazards too CAR 901.75
A 16-year-old applies for a level 1 complex pilot certificate	The minimum age is 18	Check the age before the rest of the application CAR 901.90

Practise: Rpac visual observer certification

Practise: Rpac visual observer duties

Practise: Rpac visual observer distance

Practise: Rpac visual observer scope

• CAR 901.20 — Communication between crew members
• CAR 901.75 — Visual Observers
• CAR 901.90 — Issuance of Pilot Certificate — Level 1 Complex Operations
• TC AIM RPA 3.2.8 — Visual Observers