Level 1 Complex BVLOS rules in Canada: populated areas, airspace and declarations
Where Level 1 Complex pilots may fly BVLOS in Canada: population density, uncontrolled airspace, 5 NM from aerodromes, weather, lights and declarations.
Checked against the rules in force on 2026-10-26Since November 4, 2025, Division VI of CARs Part IX lets certified pilots fly some lower-risk BVLOS operations without a special flight operations certificate. Everything depends on how many people live under and near the route.
Population density
The CARs define two terms:
- Populated area: more than 5 people per km².
- Sparsely populated area: more than 5 and not more than 25 people per km².
An area with 5 people per km² or fewer is not a populated area at all. Transport Canada calls it unpopulated.
The two pathways
- 901.87(a): a small or medium RPA, BVLOS, in uncontrolled airspace, at least 1 km from any populated area.
- 901.87(b): a small RPA only, BVLOS, in uncontrolled airspace, over a sparsely populated area or less than 1 km from a populated area.
Overflight of areas with more than 25 people per km², BVLOS in controlled airspace, and medium RPA closer than 1 km to a populated area are outside Level 1 Complex and need an SFOC-RPAS.
Operating limits
- Stay at or below 122 m (400 ft) AGL. On a long route, check the terrain: a barometric altitude measured from the takeoff point does not follow the ground.
- Stay at least 5 NM from the centre of any aerodrome.
- Fly only when ground visibility is at least 3 miles and the RPA can stay clear of cloud.
- Show white anti-collision lights flashing 40 to 100 times per minute, visible from 1 mile.
- One RPA at a time: several RPA beyond visual line of sight need an SFOC.
The site survey must include the distance to populated areas, because that distance decides which pathway applies.
The aircraft: Standard 922 declarations
You may only use an RPA that meets the safety requirements for the exact operation:
- For 901.87(a), the manufacturer declares compliance with the applicable parts of Standard 922. No acceptance letter is needed.
- For 901.87(b), the declaration must be pre-validated: Transport Canada reviews it and issues an acceptance letter.
Detect and avoid
Nobody keeps the RPA in sight, so the operation needs another way to detect and avoid traffic. The options are a declared DAA capability (922.10), visual observers under Standard 923, or flying in atypical airspace as defined in AC 903-001. Low-flying medevac helicopters, agricultural aircraft and float planes are the main threat below 400 ft.
Sources: CARs 900.01 · CARs 901.87 · CARs 901.34 · CARs 901.38.1 · CARs 901.47 · Standard 922
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Under the CARs, what is a 'populated area'?
Under the CARs, what population density defines a 'sparsely populated area'?
Which operation is covered by CARs 901.87(a)?
Without an SFOC, how close to the centre of an aerodrome may you conduct a BVLOS operation?
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