10.1 Pilot-in-Command Duties, SOPs & Checklists

Key Takeaways

  • Under CAR 900.06 and CAR 901.16, the Pilot-in-Command (PIC) holds ultimate legal accountability for flight safety, bystander protection, and CARs Part IX compliance, a responsibility that cannot be delegated to visual observers, clients, or employers.
  • CAR 901.31 strictly prohibits operating an RPA outside manufacturer limitations, including maximum wind resistance, operating temperature envelopes (-10°C to 40°C), maximum gross takeoff weight, and IP moisture ingress ratings.
  • Standard Operating Procedures (SOPs) mandate structured checklists across normal, abnormal, and emergency flight regimes, prominently featuring a 15–30 second hover check at 3–5 metres AGL to evaluate stability, battery voltage under load, and control responsiveness.
  • Under CAR 901.48, pilots and operators must maintain flight logs (pilot/crew names, flight times, locations, aircraft registration) and maintenance records (inspections, battery cycles, firmware updates) for a minimum of 24 months.
  • CAR 901.48(2) requires records to be made available to the Minister on request; CAR 901.57 and CAR 900.20 separately require the pilot certificate, proof of recency and the certificate of registration to be easily accessible at the site.
Last updated: September 2026

Pilot-in-Command Duties, SOPs & Checklists

Quick Summary: In Canadian aviation, the Pilot-in-Command (PIC) is the ultimate legal authority for every flight under Canadian Aviation Regulations (CARs) Part IX. The PIC cannot delegate liability to visual observers, employers, or clients. Operating an RPA requires strict adherence to manufacturer limitations (CAR 901.31), disciplined execution of Standard Operating Procedures (SOPs) through four flight phases—including a mandatory 15–30 second hover check at 3–5 metres—and rigorous maintenance of flight and technical logs for at least 24 months (CAR 901.48).

A professional RPAS operation is distinguished from casual drone flight by structure, discipline, and procedural compliance. Under Transport Canada standard TP 15263, candidates for the Small Basic Pilot Certificate must demonstrate a thorough understanding of pilot responsibilities, flight phase checklists, and mandatory statutory record keeping.


Pilot-in-Command (PIC) Authority & Legal Accountability

Under CAR 900.06 and CAR 901.16, every remotely piloted aircraft operation must have a designated Pilot-in-Command (PIC). The PIC is the individual who manipulates the flight controls or oversees the flight profile of the system.

The Legal Scope of PIC Responsibility (CAR 901.16)

The Canadian Aviation Regulations place absolute accountability on the PIC before, during, and after flight:

  1. Safety of Flight: The PIC is responsible for the overall operation, navigation, and trajectory of the remotely piloted aircraft.
  2. Protection of Persons & Property: The PIC must ensure that the flight does not present a hazard to persons on the ground, maritime vessels, vehicles, or terrestrial infrastructure.
  3. Compliance with CARs Part IX: The PIC must guarantee that all aspects of the flight—including airspace permissions, altitude ceilings, weather minimums, and bystander separation—strictly adhere to federal law.
  4. Crew Management: The PIC directs all other crew members, including visual observers (VOs) and payload sensor operators.

The Non-Transferability of Command Authority

A central tenet of Canadian aviation law is that command authority cannot be delegated or surrendered:

  • Client Pressure: If a commercial client or property owner demands an aerial photograph that requires flying within 15 metres of non-participating bystanders or exceeding 400 feet AGL, the PIC has a statutory duty to refuse. A signed waiver from a client holds zero legal weight against federal CARs violations.
  • Employer Directives: An employer cannot order a drone pilot to operate in weather exceeding aircraft limitations. If an accident occurs, Transport Canada and the Transportation Safety Board (TSB) hold the PIC personally liable, resulting in individual administrative monetary penalties or certificate suspension.
  • Visual Observers: While a VO assists with situational awareness and visual scanning, the VO does not hold operational command. If the VO fails to spot an encroaching helicopter, the legal accountability remains entirely with the PIC.

Operating Within Manufacturer Limitations (CAR 901.31)

Under CAR 901.31, no pilot shall operate a remotely piloted aircraft system unless it is operated in accordance with the manufacturer operating instructions.

Manufacturer manuals are not advisory guidelines; under federal regulations, they establish legal operational boundaries:

ParameterCommon Manufacturer EnvelopeOperational Consequence of Exceedance
Maximum Wind ResistanceTypically 28 to 38 km/h (15 to 21 knots)Motor saturation, loss of attitude control, rapid battery drain, drift downwind into obstacles.
Operating Temperature-10°C to +40°C (14°F to 104°F)Sudden electrochemical voltage collapse in LiPo batteries below freezing; processor overheating above 40°C.
Moisture / Ingress ProtectionIPX0 (unrated) to IP43/IP55Short-circuiting of electronic speed controllers (ESCs), sensor corruption, motor failure in rain/snow/fog.
Maximum Takeoff Weight (MTOW)Fixed gram/kilogram limitExcessive wing/rotor loading, degraded climb performance, structural fatigue, inability to arrest descents.
Maximum AirspeedTypically 50 to 75 km/hControl surface flutter, aerodynamic stall on retreating rotor blades, exceeding VLOS reaction boundaries.

Exam Tip: If your drone's manual specifies a maximum wind limit of 30 km/h, operating in 35 km/h gusts is a direct violation of CAR 901.31, regardless of pilot skill level or mission urgency.


Pre-Arranged, Restricted and Prohibited Operations

Several in-VLOS rules in CARs Part IX apply to a Basic pilot but are easy to miss because they never come up on a routine job. Each is a one-line rule and each is examinable.

RuleRequirement
CAR 901.33 — Take-offs, launches, approaches, landings and recoveryBefore each of these, the pilot shall ensure there is no likelihood of collision with another aircraft, person or obstacle, and that the site set aside for the manoeuvre is suitable for the intended operation
CAR 901.36 — Formation flightFormation with other aircraft is permitted only by pre-arrangement between the pilots in respect of the intended flight. Impromptu formations are prohibited
CAR 901.42 — HandoversA pilot may not hand over responsibility to another pilot in flight unless, before take-off, (a) the handover was pre-arranged between the pilots and (b) a procedure was developed to mitigate the risk of loss of control
CAR 901.40 — Multiple RPAsOne pilot may operate more than one RPA at a time only if the operation is VLOS, is conducted per the operating manuals, the system is designed for multi-aircraft control from one station, and no more than five aircraft are flown at once. Beyond five, or for a non-VLOS multi-aircraft operation, an SFOC is required
CAR 901.37 — Moving vehiclesNo pilot shall operate an RPA while operating a moving vehicle, vessel or manned aircraft. Under CAR 901.20(4) a visual observer is under the same bar
CAR 901.45 — ELTNo pilot shall operate a remotely piloted aircraft equipped with an ELT. This is an outright prohibition, not a requirement — an emergency locator transmitter on an RPA would trigger false search-and-rescue activations on 406 MHz
CAR 901.46 — TransponderAn RPA must not be flown in the transponder airspace referred to in CAR 601.03 unless it carries a transponder and automatic pressure-altitude reporting equipment — or the responsible ATC unit authorizes the flight in advance
CAR 901.50 — Dropping of objectsNo pilot shall create a hazard to persons or property on the surface by dropping an object from an RPA in flight

The ELT Trap: Candidates routinely reverse CAR 901.45 because crewed aircraft are generally required to carry an ELT. For remotely piloted aircraft the regulation reads the opposite way — an ELT is prohibited.

Standard Operating Procedures across Flight Phases

Standard Operating Procedures (SOPs) provide structured workflows that eliminate cognitive errors and catch mechanical faults before they cause accidents. Professional RPAS operations divide checklists into four distinct flight phases:

1. Pre-Flight Inspection Checklist

Before powering on the system, the PIC must conduct a physical walkaround inspection of the airframe and ground equipment:

  • Airframe Structure: Check the fuselage, motor arms, landing gear, and fasteners for stress fractures, delamination, cracks, or loose hardware.
  • Propulsion System: Inspect all propellers for leading-edge nicks, hairline cracks, deformation, and balance. Verify that clockwise (CW) and counter-clockwise (CCW) props are installed on matching motor shafts with locking mechanisms fully seated.
  • Sensors and Payload: Remove gimbal locks, inspect optical camera lenses for clarity, and verify that payloads are securely mounted within approved Centre of Gravity (CG) envelopes.
  • Battery Inspection: Verify that Lithium Polymer (LiPo) or Lithium High Voltage (LiHV) battery packs are physically undamaged, with zero swelling ("puffing"), intact connector pins, and individual cell voltage deltas under 0.05 V. Ensure battery latches click securely into place.
  • Avionics & Fail-Safe Verification: Power on the Ground Control Station (GCS) first, then the RPA. Verify satellite acquisition (minimum 8–12 satellites for stable GNSS lock), compass status, Command and Control (C2) link margin, and ensure the Return-to-Home (RTH) altitude is configured above the highest local obstacle.

2. Takeoff Checklist & The Mandatory Hover Check

Once pre-flight checks are complete and the takeoff zone is verified clear of non-participating bystanders:

  • Takeoff Clearance: Announce "Taking off!" to all crew members and visual observers.
  • Smooth Liftoff: Apply vertical throttle to lift smoothly off the ground to an altitude of 3 to 5 metres (10 to 16 feet) Above Ground Level (AGL).
  • The Mandatory Hover Check (15–30 Seconds): The PIC must hold a stationary hover for 15 to 30 seconds to evaluate system health before proceeding with the mission:
    • Position Hold & Sensor Fusion: Confirm the RPA maintains solid horizontal and vertical station-keeping without drifting or toilet-bowling oscillations.
    • Flight Dynamics & Response: Make subtle pitch, roll, and yaw inputs to confirm immediate, proportional stick response.
    • Battery Under Load: Monitor real-time telemetry on the GCS to verify that battery voltage does not experience abnormal voltage sag under active motor draw.
    • Acoustic & Vibration Check: Listen for unusual motor bearing whines, rotor flutter, or excessive airframe resonance.

3. In-Flight Monitoring & Situational Awareness

During flight, the PIC must continuously balance instrument monitoring with external visual scanning:

  • Visual Line-of-Sight (VLOS): Maintain direct, unaided eye contact with the RPA at all times (CAR 901.11). Corrective glasses are permitted; sunglasses, binoculars, or GCS screens cannot replace direct line-of-sight.
  • Telemetry Scanning: Periodically cross-check battery percentage, remaining flight time calculations, altitude (< 400 ft AGL), groundspeed, and C2 signal strength.
  • Airspace Scanning: Continuously scan the horizon for low-flying crewed aircraft (helicopters, floatplanes, agricultural sprayers) and birds.
  • Ground Perimeter Monitoring: Confirm that pedestrians or vehicles do not enter the mandatory 30-metre bystander buffer.

4. Landing & Post-Flight Checklist

  • Approach & Touchdown: Confirm the landing zone is clear, align the aircraft into the wind, and execute a controlled vertical touchdown.
  • Motor Disarm: Immediately disarm and stop motor rotation upon ground contact to prevent flyaways, tipping, or blade strikes.
  • Power-Down Sequence: Power down the RPA first, then disconnect and remove the flight battery. Power off the GCS last (powering off the GCS while the RPA is energized may trigger an uncommanded lost-link RTH routine).
  • Physical Post-Flight Walkaround: Touch motor bells to check for excessive bearing heat; inspect propellers for insect impacts; examine battery casing for abnormal heat or swelling.

Mandatory Record Keeping & Logbooks (CAR 901.48)

Under CAR 901.48, every owner and operator of a remotely piloted aircraft system is legally required to keep and maintain detailed operational records.

The Two Retention Periods: 12 and 24 Months

CAR 901.48(2) sets two different clocks, and conflating them is a standard exam trap:

  • The crew-and-flight-time record required by CAR 901.48(1)(a) — the names of the pilots and other crew members involved in each flight and the time of each flight or series of flights — is retained for 12 months after the day it is created.
  • The maintenance record required by CAR 901.48(1)(b) — the particulars of any mandatory action and any other maintenance action, modification or repair — is retained for 24 months after the day it is created.

A separate 12-month clock runs under CAR 901.49(2) for the record of any occurrence analysis, and CAR 901.56(2) requires a record of recency activities to be kept for at least 24 months.

Required Contents of Operational Logs

Record CategoryData Elements Required or Recommended (CAR 901.48)
Crew and Flight-Time Record (CAR 901.48(1)(a), retain 12 months)• Date and geographic location of each flight.<br/>• Time of takeoff, time of landing, and total flight duration.<br/>• Names and duty assignments of all crew members (PIC, Visual Observers, payload operators).<br/>• Aircraft make, model, and Transport Canada registration number (C-XXXXXXXXXX).<br/>• Record of any incidents, unusual flight behaviors, or equipment anomalies.
Maintenance Record (CAR 901.48(1)(b), retain 24 months)• Comprehensive record of all pre-flight and scheduled maintenance inspections.<br/>• Dates and descriptions of all repairs, parts replacements, and structural overhauls.<br/>• Component tracking: motor replacements, ESC swaps, propeller changes.<br/>• Battery management logs: individual battery serial numbers, total charge cycles, internal resistance, and retirement dates.<br/>• Mandatory records of firmware updates, software patches, and compliance with manufacturer service bulletins.

Production of Records upon Statutory Demand

CAR 901.48(2) requires the records to be made available to the Minister on request — in practice, to a Transport Canada Civil Aviation Inspector. The regulation names the Minister, not police services generally, although CAR 103.02 separately governs who may demand to inspect Canadian aviation documents and permits computer-stored records to stand in for paper if they are protected.

Separately, at the flying site itself, CAR 901.57 requires your pilot certificate and proof of recency to be easily accessible, and CAR 900.20 requires the aircraft's certificate of registration to be easily accessible. Records may be kept in paper logbooks or in a digital logging application, provided they can actually be produced.


Practical Exam Scenarios & Common Traps

  • The "Boss Said So" Trap: An employer instructs a newly minted Basic pilot to fly an aerial mapping mission during a steady 42 km/h wind. The drone's operating handbook specifies a 35 km/h limit. If the pilot flies and loses control, the PIC bears sole legal responsibility under CAR 901.16 and CAR 901.31.
  • The Immediate Fly-Off Error: A pilot takes off and immediately climbs to 350 feet AGL to capture a sunset shot, bypassing the 15–30 second hover check. A defective battery cell suffers rapid voltage drop under high throttle, triggering an unrecoverable mid-air power loss. The hover check is designed specifically to detect these faults at safe altitudes.
  • The 12-Month Logbook Misconception: While certain medical declarations or certifications in crewed aviation have annual timelines, RPAS logbook retention under CAR 901.48 is strictly 24 months.
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Standard Operating Procedures (SOPs) & Four Flight Phase Workflow
Test Your Knowledge

Under Canadian Aviation Regulations Part IX (CAR 900.06 and 901.16), what are the legal authority and accountability of the Pilot-in-Command (PIC) during an RPAS operation?

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Test Your Knowledge

During the takeoff phase of a multirotor flight, what is the required standard operating procedure for the initial hover check?

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B
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D
Test Your Knowledge

Under CAR 901.48, for how long must an RPAS owner retain the crew-and-flight-time record and the maintenance record, and to whom must they be made available?

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D
Test Your Knowledge

A commercial client requests an aerial mapping flight during sustained winds of 45 km/h with gusts to 55 km/h. The RPA manufacturer operating manual specifies a maximum wind resistance limit of 38 km/h. Under CAR 901.31, what is the PIC's legal obligation?

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