3.2 Aerodrome Stand-offs, Forest Fires & Special Approvals

Aerodrome Stand-offs, Forest Fires & Special Approvals

To ensure peaceful and safe coexistence between uncrewed aerial systems and established Canadian aviation infrastructure, Transport Canada defines precise geographic stand-offs around aerodromes and active wildfire operations. Operating outside these boundaries under a Basic Pilot Certificate requires specialized coordination or formal federal authorization.

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Aerodrome Stand-off Buffers (CAR 901.47)

In aviation law, any location designed for the arrival, departure, or movement of aircraft is an aerodrome. However, CARs Part IX establishes specific, rigid stand-off buffers around certified facilities.

Under CAR 901.47, no person shall operate a remotely piloted aircraft under Basic operations within the following protective zones:

1. Certified Airports and Military Aerodromes: 5.6 km (3 Nautical Miles)

• Buffer Distance: A minimum horizontal distance of 5.6 kilometres (3 nautical miles / NM) measured from the geographic centre of the aerodrome.
• Applicability: All airports certified by Transport Canada under Part III of the CARs (commercial airports such as Toronto Pearson, Vancouver International, Calgary International, and regional municipal airports), as well as military aerodromes operated by the Department of National Defence (CFB Trenton, CFB Moose Jaw, CFB Comox).

2. Certified Heliports: 1.9 km (1 Nautical Mile)

• Buffer Distance: CAR 901.47(2)(b) prohibits a VLOS operation less than one nautical mile (1.9 km) from the centre of a heliport.
• Applicability: A heliport means an aerodrome for which a heliport certificate issued under Subpart 305 of the CARs is in force — certified hospital helipads and certified corporate or municipal heliports. Look for "Cert" in the Operator (OPR) section of the Canada Flight Supplement.
• Water Aerodromes Are Different: There is no 1 NM numeric buffer for water aerodromes. A water aerodrome listed in the Water Aerodrome Supplement is covered by CAR 901.47(1): you must not operate at or near it in a manner that could interfere with an aircraft operating in the established traffic pattern. Floatplane circuits over open water are a real hazard — treat the absence of a fixed number as a reason for more caution, not less.

Basic vs. Advanced Operations at Aerodromes

A pilot holding solely a Basic Certificate cannot legally operate within these 5.6 km or 1.9 km zones under any circumstance without a Special Flight Operations Certificate. To operate within these zones under standard Part IX rules, a pilot must hold an Advanced Certificate, conduct operations in accordance with an established procedure, and coordinate directly with the aerodrome operator or air traffic services (NAV CANADA).

Uncertified Aerodromes and Seaplane Bases

Canada contains hundreds of unregistered or registered rural airstrips, turf runways, and private floatplane docks that are not certified airports. While the rigid 5.6 km rule under CAR 901.47 specifically names certified airports, CAR 901.47(2) mandates that no person shall operate an RPA at or near any aerodrome in a manner that could interfere with or hazard aircraft operating in the traffic pattern. Pilots must review the Canada Flight Supplement (CFS) and conduct thorough site surveys to avoid aerodrome traffic circuits.

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Forest Fire Airspace Restrictions (CAR 601.15)

During wildfire seasons, unauthorized drone flights near active fires represent an extreme threat to life and property.

The forest-fire restriction is not in Part IX at all — it is in Part VI, and it applies to every aircraft, crewed or remotely piloted. Under CAR 601.15, no person shall operate an aircraft:

1. (a) over a forest fire area, or over any area located within five nautical miles (9.3 km) of a forest fire area, at an altitude of less than 3,000 feet AGL; or
2. (b) in any airspace described in a NOTAM issued under CAR 601.16.

CAR 601.14 defines a forest fire area as an area on the surface of the earth on which standing timber, grass or any other vegetation or buildings are burning. Because a Basic RPA may not exceed 400 ft AGL, the 3,000 ft limb can never save you: the 5 NM ring is effectively an absolute no-fly zone. CAR 601.17 lists the only exceptions — flying at the request or with the authorization of a fire control authority, under a written ministerial authorization, or as Transport Canada enforcement personnel.

The Life-Threatening Danger to Wildfire Crews

Aerial firefighting depends on low-level, high-speed maneuvers by specialized aircraft:

• Air Tankers: Heavy water bombers (e.g., Canadair CL-215, CL-415, Conair Q400AT, DC-10) drop water and chemical fire retardant from altitudes as low as 100 to 150 feet AGL into thick smoke, extreme thermal drafts, and high-turbulence terrain.
• Bird-Dog Aircraft: Lead planes that scout targets and coordinate drops directly ahead of tankers.
• Bucketing Helicopters: Heavy rotary aircraft hovering near water sources and tree lines.

Immediate Shutdown Rule: Under federal aviation protocols, if an unauthorized drone is spotted anywhere within wildfire airspace, all firefighting aircraft are immediately grounded. The suspension of aerial drops allows fires to jump containment lines, destroying homes, vital infrastructure, and potentially trapping ground firefighters.

Enforcement

CAR 601.15 is a designated provision, so a contravention can be dealt with by an administrative monetary penalty under the Aeronautics Act. Transport Canada does not publish a special forest-fire penalty scale; the TC AIM quotes individual penalties of up to $1,000 and corporate penalties of up to $5,000 for the RPA contraventions it lists, and a contravention that also endangers aviation safety can be charged under CAR 900.06 and can attract higher amounts. Provincial wildfire legislation and the Criminal Code may apply on top of the federal penalty. Do not rely on any specific dollar figure quoted by a third-party course — check CAR 103, Schedule II.

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Advertised Events & Open-Air Assemblies (CAR 901.41)

Under CAR 901.41(1), no pilot shall operate an RPAS at any advertised event except in accordance with a special flight operations certificate — RPAS issued under CAR 903.01. The prohibition is tied to the event itself; the regulation does not state a 30-metre radius. (Separately, CAR 903.01(b) requires an SFOC even for a sub-250 g RPA flown at an advertised event — one of the very few places where Part IX reaches microdrones.)

CAR 901.41(2) creates a narrow exception: subsection (1) does not apply to an operation conducted to save human life, or to a police, fire-fighting, or other operation in the service of a public authority.

What Is an "Advertised Event"?

CAR 900.01 defines it precisely: an advertised event means an outdoor event that is advertised to the general public, including a concert, festival, market or sporting event. In practice that covers gatherings promoted through flyers, television, radio, social media, posters, newspapers, or websites. Examples include:

• Outdoor music festivals and concerts;
• Sporting events, community marathons, and road races;
• Parades, carnivals, and cultural celebrations;
• Political rallies, protests, and open-air public markets.

Even if you hold an Advanced Certificate and a declared drone, you cannot operate at an advertised event without a specific SFOC from Transport Canada — unless you are flying in the service of a public authority under CAR 901.41(2).

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Special Flight Operations Certificates (SFOC-RPAS) (CAR 903.01)

When a proposed RPAS mission falls outside the operations Part IX permits, the operator must obtain a Special Flight Operations Certificate — RPAS (SFOC — RPAS) under CAR 903.01.

2025 Update — Memorize This: CAR 903.01 was amended by SOR/2025-70 and the weight trigger moved. The SFOC weight threshold is now more than 150 kg, not more than 25 kg. Since 4 November 2025, a medium RPA (more than 25 kg up to and including 150 kg) is flown under Division V (Advanced operations) with an Advanced or Level 1 Complex pilot certificate and a Standard 922 declaration — no SFOC required for the weight alone.

The Three Standing Triggers in CAR 903.01

1. CAR 903.01(a): Operating an RPA with an operating weight of more than 150 kg (331 lb).
2. CAR 903.01(b): Operating an RPA with an operating weight of less than 250 g at an advertised event — the rare case where Part IX reaches a microdrone.
3. CAR 903.01(c): Any other operation of a small or medium RPA for which the Minister determines an SFOC is necessary to ensure aviation safety or the safety of any person.

Operations That Reach an SFOC Through Another Rule

Most SFOC cases arrive through a specific prohibition elsewhere in Part IX that names the certificate as its only way out:

Foreign operators are a practical rather than a textual case: CAR 900.15 lets only Canadian citizens, permanent residents, Canadian corporations and Canadian governments register an RPA, so a visitor who cannot register the aircraft is routed to an SFOC under CAR 903.01(c).

The SFOC Application Process

SFOC applications are submitted through the Drone Management Portal to Transport Canada's Civil Aviation regional offices. Applications require a detailed Concept of Operations (CONOPS), site survey, hazard identification, and risk mitigation plan, and must typically be submitted at least 30 to 60 working days prior to the planned flight.