Your Operations Manual Isn't Optional Anymore

Transport Canada's November 2025 amendments to Part IX of the Canadian Aviation Regulations changed things for RPAS operators. Not just for Complex Level 1 certificate holders - for anyone operating commercially who wants to stay compliant as the industry matures.

The regulations now explicitly require RPAS operators holding operator certificates to maintain an operations manual. CAR 901.217 spells it out clearly. And even if you don't hold an RPAS Operator Certificate today, CAR 901.23 has always required pilots to have established normal and emergency procedures before operating. The new framework just makes it harder to pretend "established" means "I'll figure it out when it happens."

We've put together a template that might help. It's available for free on our Training Hub. But before you download it and move on, it's worth talking about why this matters beyond checking a regulatory box—because we spent a long time learning these lessons the hard way.

The Gap Between Certified and Competent

There's a pattern we've seen constantly, including in our own early operations. Someone passes their Advanced exam, maybe even their Complex Level 1. They buy good equipment. They start taking jobs. And then they show up to a site and realize they have no idea how to actually run an operation.

The exams test knowledge of airspace, meteorology, regulations, and basic flight principles. They don't test whether you've thought through what happens when your control link drops at 400 feet. They don't ask whether you've documented who's responsible for what on a two-person crew. They don't verify that you have a process for reporting incidents or tracking maintenance.

This is the competency gap: the distance between passing a test and operating professionally. Most operators fill it through trial and error. Some of those errors are expensive. Some are embarrassing. A few are dangerous. We filled it that way too, which is part of why we eventually wrote things down.

A proper operations manual isn't bureaucratic paperwork. It's the documentation of everything you've learned about how to do this work safely. It's institutional knowledge that keeps you from making the same mistake twice - and keeps new crew members from having to learn everything from scratch.

What the Regulations Actually Require

CAR 901.217 through 901.221 lay out what an operations manual must include. The requirements are more specific than many operators realize.

Crew roles and responsibilities need to be documented for each phase of an operation - before, during, and after flight. This isn't a job description. It's clarity about who conducts the pre-flight inspection, who makes the go/no-go call on weather, who files the incident report if something goes wrong. When these responsibilities are clear in advance, you don't waste time figuring them out under pressure.

Organizational structure matters even for small operations. You need an Accountable Executive—someone ultimately responsible for safety. For a solo operator, that's you. As you grow, having the chain of command documented prevents the confusion that comes when nobody knows who has final authority on a safety question.

Safety management processes are where many operators fall short. The regulation requires documented processes for setting safety goals, identifying hazards, managing risks, and reporting incidents. This isn't optional safety culture - it's compliance. CAR 901.218 is specific about these requirements.

Normal and emergency procedures must be established before every flight. CAR 901.23 lists five specific emergency scenarios you need procedures for: control station failure, equipment failure, RPAS failure, loss of command and control link, and fly-away. If you're flying without documented procedures for each of these, you're not compliant. That's not interpretation - that's what the regulation says.

Training programs require more than informal mentorship. Your manual must describe personnel training and include a detailed syllabus covering indoctrination, initial and annual training on your specific equipment and procedures, and a process for assessing competency.

Maintenance procedures round out the requirements - listing authorized maintenance personnel, maintaining records, and documenting procedures consistent with manufacturer instructions.

Why We Put a Template Together

When we built our own operations manual, we started from scratch. We read the regulations, looked at manned aviation equivalents, talked to other operators, made mistakes, revised things. It took longer than it should have because we didn't have a model to work from.

We've seen other operators go through the same process. They know they need documentation, but they don't know where to start. So they either pay someone thousands of dollars to write a manual for them - which often produces a document that technically exists but doesn't reflect how they actually operate - or they cobble something together that wouldn't satisfy a serious inspector.

The template we're offering isn't meant to be the definitive answer. It's structured to meet regulatory requirements while being genuinely useful as an operational document. Each section includes example content showing what belongs there, with markers for what you need to customize. Regulatory references are included so you understand why each element exists, not just that it's required.

Will using it make you our competitor? Maybe. But it also makes you a safer operator. And there's enough work in this industry for everyone who's doing it right. What hurts all of us is operators who cut corners, cause incidents, and make clients nervous about hiring RPAS services. More professional operators means a healthier industry.

What the Template Covers

The template addresses everything required under CARs Part IX: document control for managing amendments and versions, organizational structure with Accountable Executive and Operations Manager roles defined, crew responsibilities broken down by flight phase, safety management processes including hazard identification and risk assessment, normal operating procedures for mission planning through recovery, emergency procedures for all five required scenarios, training program structure with syllabus framework, and maintenance procedures with record-keeping requirements.

Appendices include equipment lists, checklists, forms, and emergency contacts. The fly-away section includes a call script for reporting to authorities - something you don't want to be composing in the moment.

The Honest Part

Some operators will download this template, spend twenty minutes filling in blanks with minimal information, and call it done. They'll have a document that technically exists.

That's not what makes the exercise worthwhile. The value isn't in having a document—it's in the process of thinking through how you actually operate. What are your emergency procedures? Not what should they be in theory, but what would you actually do if you lost link at 400 feet over a populated area? Have you thought through the sequence? Practiced it? Discussed it with your crew?

The template asks these questions. How you answer them determines whether you end up with useful documentation or paperwork that helps no one.

Some sections will take five minutes. Others will require real thought. That's intentional. If filling in a section feels difficult, that's often a sign you haven't fully worked through that aspect of your operations. The difficulty is the point - it's showing you where you need to do more thinking.

What You Get From the Investment

Filling in the template properly takes a few hours, maybe a day if you're thorough. In exchange, you get documentation that meets Transport Canada requirements - useful when an inspector asks to see your operations manual, which eventually they will. You get operational consistency, because documented procedures get followed while undocumented ones drift. You get easier training for new crew members who can read the manual instead of learning everything through observation. You get some protection if something goes wrong, because having documented procedures shows you were operating professionally.

And you get personal clarity. The process of documenting your operations forces you to think through scenarios you might not have considered. That thinking makes you a better operator, whether or not anyone ever reads the document.

Using the Template

The template is available on the Aeria Training Hub. No email signup, no sales pitch. Download it, open it in Word, and start with the bracketed fill-in fields. The gray italic text shows examples—read it to understand what belongs in each section, then replace it with your own content.

Once you've filled it in, read the whole thing through. Ask yourself: if I handed this to a new crew member, would they understand how we operate? If not, revise it. Then distribute it to everyone involved in your operations - the regulation requires this, but more importantly, a manual that sits in a drawer helps no one.

Review it annually. Update it when things change. Treat it like what it is: the documentation of your professional practice, not a compliance artifact to be filed and forgotten.

We didn't get our own documentation right the first time, or the second time. It's still evolving. But having something written down - something we can review, critique, and improve - has made our operations better. We hope the template helps you get started faster than we did.

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The RPAS Operations Manual template is available at aeriasolutions.ca/training. If you find errors, have suggestions, or want to share how you've approached documentation for your own operation, we'd genuinely like to hear from you.

Regulatory reference: Canadian Aviation Regulations Part IX, as amended November 25, 2025