The 450-Foot Favour: Advanced Certificate, Lapsed Review, and a Client in a Hurry
You are an RPAS contractor holding an Advanced Pilot Certificate issued 26 months ago; your last flight review with a reviewer was completed 27 months ago. You fly a 4.6 kg quadcopter for a roof inspection on a commercial building 2.6 km (1.4 NM) from the threshold of a certified aerodrome, inside a Class C control zone from the surface to 3,000 ft ASL. The aircraft is registered and the number is affixed. You confirmed the model appears in Transport Canada's RPAS database only with a declaration covering operations that are not over bystanders. The client wants 450 ft AGL for a better angle and says six workers in the parking lot will "stay in the truck" so the flight is not over people. Crews are waiting and rain is forecast by 1800Z.
1. Before launch, list each regulatory element this advanced operation requires and state whether it is satisfied. What must happen before any flight?
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Work through the four pillars in order; a fail on any one is a stop.
- Pilot certificate and recency. Advanced certificate held - yes. But advanced operations require the flight review with a reviewer to have been completed within the preceding 24 months. At 27 months the recency has lapsed, so you cannot act as pilot of an advanced operation. Fix: book and complete a flight review - not achievable this afternoon.
- Registration. Registered and the mark is affixed to the aircraft - satisfied.
- Safety assurance declaration. The model's declaration does not cover operations over bystanders, so any flight directly over or in close proximity to the workers in the lot is outside the declared envelope. Fix: a different RPA with an appropriate declaration, or a site plan that genuinely keeps people out of the operating area.
- Airspace. Inside a Class C control zone means controlled airspace, which requires an ATC authorization for the specific block of altitude, area, and time. Not yet obtained.
Three independent blockers. The flight does not go today, and no amount of client urgency changes that.
2. Assess the client's two requests: 450 ft AGL, and "the workers will stay in the truck."
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450 ft AGL. The default ceiling for RPAS operations in Canada is 400 ft AGL. Going above it is not a judgement call you can make on site - it requires a special authorization (SFOC) for that operation. Declining this is not caution, it is the regulation.
People in a truck. A person in a vehicle you are flying over is still a person below the flight path, and the declaration on your model excludes operations over bystanders regardless of whether they are sheltering. Beyond the paper trail, the practical point: if a motor or battery fails, the wreckage lands on whatever is underneath, and a steel truck roof is not a mitigation you control. Six people plus a client standing in an open lot is the risk exposure, not the seating arrangement.
Both requests are refused on the merits, not on mood. Offer the alternative that preserves the client relationship: a 300–350 ft pass from a standoff distance that keeps the lot outside the operating area, once the legal blockers are cleared.
3. You want to keep the client. What is a defensible course of action for today?
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Separate what can be salvaged from what cannot.
Cannot be fixed today: the lapsed flight review (needs a scheduled review) and the missing ATC authorization for a Class C control zone. Also the declaration gap - unless you can reposition so that no one is under the flight path and the model's declared envelope is respected.
Can be done today: a proper site visit. Walk the property with the client, mark the launch and recovery area, identify the standoff geometry that keeps the parking lot and the truck clear, capture ground reference photos and measured distances, note obstacles and wires, confirm the aerodrome proximity and the frequency to call, and write a flight plan and a weather go/no-go for the rescheduled date.
Say it in one clear sentence: "I can't fly legally today; here is what I can deliver today and the earliest date I can fly." Then put the refusal and the reasons in writing (email to the client, entry in your log). If a crew is standing around, that is the client's scheduling risk, not a reason to launch an uninsured, unauthorized flight - the exposure is enforcement action, void insurance, and personal liability if something falls on someone.