2.1 Regulatory Scope & RPA Weight Categories

2.1 Regulatory Scope & RPA Weight Categories

Exam Focus: Transport Canada's Basic RPAS exam heavily tests the exact legislative definitions in the Canadian Aviation Regulations (CARs) Part IX. Memorize the 250 g threshold, the definition of unaided Visual Line-of-Sight (VLOS), and the universal application of CAR 900.06 across all unmanned aircraft.

Statutory Foundation: The Aeronautics Act and CARs Part IX

In Canada, all airspace is federally regulated. The primary statutory authority governing civil aviation is the Aeronautics Act, a federal statute empowering the Minister of Transport to regulate aeronautics and airspace safety.

Under this authority, Transport Canada enacted CARs Part IX (Remotely Piloted Aircraft Systems) on June 1, 2019. Part IX established a unified, risk-based regulatory framework. A fundamental legal principle for exam candidates is that Part IX applies to all civil RPAS operations in Canada, regardless of commercial, recreational, academic, or scientific intent. The law does not distinguish between commercial operators and recreational hobbyists; regulations apply strictly based on aircraft weight, operational environment, and airspace risk.

RPA Weight Categories (CAR 900.01)

Under CAR 101.01, a Remotely Piloted Aircraft (RPA) is a navigable aircraft, other than a balloon, rocket or kite, that is operated by a pilot who is not on board. Part IX classifies RPAs by operating weight, which CAR 900.01 defines as the weight of a remotely piloted aircraft at any point during a flight, including any payload and any safety equipment that is on board or otherwise connected to the aircraft. That is a stricter test than take-off weight: a tethered or line-suspended load counts, and jettisoning something mid-flight does not retroactively change the category you launched in.

Transport Canada establishes four distinct weight categories:

1. Microdrones (Less than 250 g)

RPAs with an operating weight of less than 250 grams (up to 249.9 g) are commonly called microdrones. The exemption does not come from CAR 900.02 — that section says the opposite, namely that "This Part applies in respect of the operation of remotely piloted aircraft systems". The microdrone exemption comes from two places:

• CAR 900.13(1) sets the registration threshold at an operating weight of 250 g or more, so a lighter aircraft need not be registered or marked (CAR 900.14).
• CAR 901.01 limits Subpart 1 — the entire small/medium RPA rule set, including pilot certification, the 400 ft ceiling, the 30 m bystander distance and the aerodrome stand-offs — to systems that include a small or medium remotely piloted aircraft.

The practical result is that a microdrone pilot is exempt from:

• Aircraft registration and marking with Transport Canada
• Pilot certification (no exam required)
• The minimum-age requirement
• Fixed aerodrome and heliport setback distances
• The mandatory 100 ft (30 m) horizontal distance from bystanders

However, microdrone pilots are not exempt from the law. Under CAR 900.06, no person shall operate an RPA in a reckless or negligent manner that endangers aviation safety or the safety of any person. Microdrone pilots also remain subject to municipal bylaws, privacy laws, provincial trespass acts, and Criminal Code offenses.

2. Small RPAs (250 g up to and including 25 kg)

This category covers aircraft weighing from 250 grams (0.55 lbs) up to and including 25 kilograms (55 lbs). This bracket forms the primary domain of CARs Part IX and the entire scope of the Small Basic Exam.

Every RPA in this bracket must be:

• Registered with Transport Canada (CA$10 charge)
• Marked indelibly with its issued registration number
• Piloted by an individual holding at least a valid Basic Pilot Certificate

Operations within this bracket are divided into Basic Operations and Advanced Operations based on airspace classification, distance from bystanders, and proximity to aerodromes.

3. Medium RPAs (> 25 kg up to and including 150 kg)

RPAs weighing more than 25 kg and up to 150 kg cannot be flown under Basic privileges. Since the November 2025 amendments they are flown under Division V (Advanced operations) by the holder of an Advanced or Level 1 Complex pilot certificate, and the model must be covered by a manufacturer declaration made under CAR 901.194 against the applicable technical requirements of Standard 922 — RPAS Safety Assurance (CAR 901.69). TP 15395 is the Flight Reviewer's Guide, not a safety declaration.

4. Large RPAs (> 150 kg)

Any RPA with an MTOW exceeding 150 kg (330 lbs) falls outside standard Part IX rules. Under CAR 903.01, operating a large RPA requires a Special Flight Operations Certificate (SFOC-RPAS) issued directly by Transport Canada.

Weight Classification and Regulatory Matrix

Visual Line-of-Sight (VLOS) Mandate (CAR 900.01 & 901.11)

Under CAR 900.01, Visual Line-of-Sight (VLOS) means unaided visual contact with the RPA at all times during flight, sufficient to maintain operational control, determine its position, and scan the surrounding airspace to detect and avoid other aircraft, obstacles, and persons.

Under CAR 901.11, pilots must maintain continuous VLOS:

• Unaided Visual Contact: The pilot must maintain direct visual contact with the naked eye.
• Permitted Corrective Vision: Standard prescription eyeglasses and contact lenses are legally permitted because they restore normal natural acuity.
• Prohibited Primary Aids: Using binoculars, telescopes, or electronic displays as the primary means of maintaining visual contact is illegal. Binoculars may only be used momentarily to identify a specific distant object.
• First-Person View (FPV): Flying solely via FPV goggles does not satisfy VLOS. Under CAR 901.38, FPV operations are permitted only if a trained Visual Observer (VO) maintains direct, continuous, unaided visual contact with the RPA and communicates hazards to the pilot.

Where Part IX Does — and Does Not — Apply

Two application rules are worth memorizing before the weight bands:

• CAR 900.02 states plainly that "This Part applies in respect of the operation of remotely piloted aircraft systems" — all of them, at any weight.
• CAR 102.01 is the boundary that matters in practice: the Canadian Aviation Regulations do not apply to aircraft operated indoors or underground. Flying a drone inside a warehouse, an arena, a mine shaft or a sewer is outside the CARs entirely. That does not make it unregulated — occupational health and safety law, the property owner's rules and the Criminal Code still apply — but you need no pilot certificate and no registration to fly inside a closed structure.

Division II: The Rules That Apply to Every RPAS

Part 900, Division II applies to all remotely piloted aircraft systems, at any weight, in any category. Four prohibitions sit here:

One Part VI rule belongs in the same mental bucket: CAR 606.01 prohibits carrying weapons, ammunition or other equipment designed for use in war on board an aircraft unless it is a Canadian aircraft and the Minister has authorized the carriage. For RPAS the point is reinforced by CAR 901.43(1)(b), which bars war equipment as a payload outright.

The Wildfire and Crash-Site Trap: Two separate rules can catch the same flight. Flying a drone to film a wildfire breaches CAR 601.15; flying it inside the police cordon around a highway collision breaches CAR 900.08. Neither requires that you interfere with anything — the presence of the aircraft is the offence.

Note the pair of "inadvertent entry" rules and keep them straight: CAR 900.07 covers Class F Special Use Restricted airspace as specified in the Designated Airspace Handbook, while CAR 901.15 covers controlled airspace. Both require the appropriate ATS unit or user agency to be notified immediately.

Reckless or Negligent Operation (CAR 900.06) in Depth

CAR 900.06 is the catch-all, and the one most likely to be charged when no other provision fits.

• Universal Application: Applies to all RPAS regardless of weight, including sub-250 g microdrones, and regardless of whether any specific numeric limit was breached.
• Penalties: Administrative Monetary Penalties (AMPs) reach $1,000 for individuals and $5,000 for corporations per violation, with severe criminal sanctions under the Aeronautics Act for intentional endangerment.
• Enforcement Scenarios: Flying near forest fire operations (CAR 601.16), flying in dense fog, or operating over crowds without safety declarations.

Practical Exam Scenarios

Scenario 1: The Added Payload Trap

A pilot attaches a 20 g prop guard and a 15 g strobe light to a 240 g microdrone. Analysis: At take-off, the MTOW is 275 g (240 + 20 + 15 g). Because it exceeds 249.9 g, the aircraft instantly transitions into the Small RPA category. The pilot must hold a valid Pilot Certificate, register the RPA with Transport Canada, apply the C-number marking, and maintain all standard setback distances.

Scenario 2: Long-Range Binocular Tracking

An operator tracks a 2 kg drone at a distance of 1.5 nautical miles using 10x50 binoculars. Analysis: This violates CAR 901.11 and CAR 900.01. Optical magnification eliminates peripheral airspace awareness required to see and avoid incoming crewed aircraft. Unaided line of sight is legally mandatory.