Beyond Visual Line of Sight (BVLOS): From Certification to Execution in Canada

Part 2 of a 3-Part Series on BVLOS Operations

In Part 1 of this series, we explored what Beyond Visual Line of Sight (BVLOS) means under Transport Canada’s regulatory framework and why it represents a shift from individual flight approval toward structured operational design.

In Part 2, we focus on how BVLOS operations are planned and enabled in Canada—from pilot certification pathways, to organizational responsibilities, to the structured approach Transport Canada uses to assess operational risk. The goal is to show that while BVLOS is more complex than VLOS, the planning process itself is methodical, repeatable, and achievable when approached correctly.

Understanding the Pathway to Level 1 Complex Operations

The Level 1 Complex operations certificate represents a progression beyond baseline RPAS operations. It is designed for pilots conducting operations that involve increased complexity, whether due to environment, mission profile, or operational coordination.

Achieving Level 1 Complex involves:

• Meeting enhanced knowledge and competency requirements

• Demonstrating familiarity with more complex operational scenarios

• Understanding how risk is managed when direct visual separation may not be available

Importantly, Level 1 Complex certification is a pilot qualification, not an operational approval. It supports more advanced operations, but BVLOS authority is always tied to how the operation is designed and authorized, not the certificate alone.

The Role of the Organization: What Transport Canada Looks For

BVLOS operations are evaluated at the organizational level, not just the pilot level. Transport Canada expects the organization responsible for the operation to demonstrate that it can consistently plan, execute, and oversee safe operations.

From an organizational perspective, this includes:

• A clearly defined Concept of Operations (CONOPS)

• Documented operational procedures and limitations

• Defined crew roles and responsibilities

• Maintenance and oversight processes appropriate to the operation

• The ability to identify, assess, and manage risk on an ongoing basis

How BVLOS Planning Works in Practice

BVLOS planning in Canada follows a structured risk-based approach, as outlined in Transport Canada guidance such as AC 903-001. Rather than focusing on aircraft capability alone, the planning process evaluates how the entire operation manages risk.

At a high level, this planning process looks at:

• Where the operation will take place (airspace and ground environment)

• How the aircraft will be contained within a defined operational volume

• What happens if something goes wrong, such as loss of command and control

• How airspace and ground risks are reduced to an acceptable level

By breaking BVLOS planning into these components, Transport Canada creates a process that is systematic rather than subjective.

Operational Volumes and Risk Containment

A central concept in BVLOS planning is the Operational Volume. This includes:

• The intended flight geography

• The contingency areas required to manage foreseeable failures

• Buffers designed to protect people and other airspace users

Defining these volumes helps ensure that even in abnormal situations, the aircraft remains within predictable and controlled boundaries. This approach allows BVLOS operations to be designed around containment and predictability, rather than reliance on constant visual observation.

Airspace Risk and Detect-and-Avoid Considerations

Without direct visual contact, BVLOS operations must demonstrate how airspace risk is managed. This can be achieved through a combination of:

• Operational limitations

• Procedural separation

• Human-based detect-and-avoid strategies

• Declared aircraft systems where applicable

Transport Canada evaluates whether the proposed mitigations are appropriate for the specific airspace and mission profile, rather than requiring a single technical solution in all cases.

Why BVLOS Planning Can Be Simpler Than It Seems

While BVLOS introduces additional requirements, the planning process itself is designed to be transparent and repeatable. By clearly defining:

• The operational intent

• The environment

• The risks

• The mitigations

organizations can demonstrate compliance without relying on excessive complexity. Many BVLOS approvals are successful not because they are technologically advanced, but because the operation is clearly scoped and well-documented.

Setting the Foundation for Execution

Level 1 Complex certification, organizational readiness, and structured BVLOS planning all serve the same purpose: enabling safe, repeatable operations. When these elements are aligned, BVLOS becomes less about exception-based approvals and more about operational maturity.

Coming Up in Part 3

In Part 3 of this series, we’ll focus on training, execution, and operational maturity—including how crews are prepared for BVLOS missions, how procedures are applied in real-world conditions, and how organizations move from initial approval to routine operations.

Because in BVLOS, good planning only matters if it translates into consistent execution.