From "Spotter" to Certified Crew: The Evolution of the Drone Visual Observer in 2026

By: Colonel (ret) Bernie Derbach, KR Droneworks, 31 January 2026

The landscape of Canadian drone operations has shifted dramatically over the last year. With the full implementation of the 2025 RPAS Amendments (which came into force on November 4, 2025), we are operating in a new era of regulatory maturity. One of the most significant yet overlooked changes in this framework is the professionalization of the Visual Observer (VO).

Gone are the days when a VO was simply a "friend" asked to watch the sky.

Today, under the new Transport Canada (TC) regulations, the VO is a certified, integral crew member essential for unlocking complex operations like Extended Visual Line-of-Sight (EVLOS) and Level 1 Complex Operations.

The Evolution: From Informal Assistant to Essential Crew

To understand where we are, we must look at how the role has transitioned through three distinct regulatory eras.

1. The "Legacy" Era (Pre-2019): VOs were informal "spotters." Training was left to the operator's discretion, and there was no formal definition in the CARs.

2. The Part IX Era (2019–2024): The VO became a defined "crew member" under CAR 901.20. However, while the pilot had to ensure they were "trained," there was no mandated certification or government exam.

3. The Modern Era (2025–Present): As of November 4, 2025, the VO role has bifurcated. While standard VLOS (Visual Line-of-Sight) still allows for basic trained assistance, the newly codified EVLOS operations require a professional standard.

The 2026 Requirement: For any EVLOS operation, the VO must now hold, at minimum, a Pilot Certificate — Small RPAS (Basic Operations) (CAR 901.75). They are no longer just observers; they are certified aviators.

The New Regulatory Reality

The updated framework transforms the VO from a passive lookout into an active safety sensor. Under Standard 923, the technical criteria for VOs include a 2 nautical mile (3.7 km) maximum distance between the VO and the RPA, ensuring that the "unaided visual contact" is sufficient to detect conflicting traffic.

• CAR 900.01 (Definitions): Updated to reflect "extended VLOS" as an operation where the drone is not in the pilot's VLOS but is kept safe via a certified VO who maintains unaided visual contact with the airspace.

• CAR 901.20 (VO Duties): Remains the bedrock for communication and scanning responsibilities.

• Standard 923 (Vision-Based Detect and Avoid): Provides the technical criteria for VOs, including the specific weather requirements (ground visibility ≥ 3 miles, ceiling ≥ 1000 feet AGL).

Recommended Training Program: VO Level II

For organizations building a compliant training manual under the new RPOC (RPAS Operator Certificate) requirements, certification is the baseline. Your internal Training Program (TP) must cover:

Module	Topic	Key Learning Objective
1	Regulatory Prep	Obtain TC Basic or Advanced Pilot Certificate.
2	CRM & Human Factors	Mastering the "Sterile Cockpit" and assertive communication.
3	Visual Scanning	Implementing the "10-degree block" scanning technique.
4	Comms Loop	Standardizing "Clock Position" and "Elevation" alerts.
5	Emergency Protocols	Training for C2 Link Loss or VO/PIC Comms Failure.

Reflecting VOs in Your RPOC Requirements

If you are an organization operating under an RPOC, your documentation must now reflect the professionalized VO.

1. Operations Manual (OM): Explicitly list the VO as a "Safety-Critical Crew Member" for EVLOS missions.

2. Training Program (TP): Include the VO Level II syllabus and the Competency Checklist below as an appendix.

3. SOPs: Mandate a 10-degree overlap in visual sectors if using multiple VOs to eliminate "blind spots."

New Standard Operating Procedures (SOPs) for 2026

To comply with the latest TC oversight, your SOPs must include formalized sections for Crew Resource Management (CRM) and Emergency Communications.

1. Sterile Cockpit Procedure

The Sterile Cockpit rule is designed to eliminate non-essential distractions during critical phases of flight (Takeoff, Landing, and any time the RPA is within 500m of a potential hazard).

• Definition: During "Sterile" periods, no crew member shall engage in conversation that is not directly related to the safety of the flight.

• Initiation: The Pilot in Command (PIC) shall announce "Sterile Cockpit" before takeoff or during hazard approach.

• Termination: The PIC will announce "Clear" or "Ops Normal" once the aircraft is in a stable cruise or safe area.

• VO Responsibility: During the Sterile Cockpit phase, the VO must only speak to report traffic, aircraft status, or immediate safety hazards.

2. Emergency Communications Protocol

In the event of a safety hazard or equipment failure, communication must be immediate, clear, and prioritized.

• Priority 1: Traffic Alert (VO to PIC)

  • Format: "[Traffic] — [Clock Position] — [Elevation] — [Trend]"

  • Example: "Traffic, 2 o'clock, high, converging."

• Priority 2: Immediate Danger / Abort (VO to PIC)

  • Command: "ABORT, ABORT, ABORT" or "LAND NOW."

  • Requirement: The PIC must acknowledge and execute the command immediately without questioning until the aircraft is safe.

• Priority 3: Communication Link Loss (Crew Internal)

  • If the VO loses voice contact with the PIC, they must use a pre-arranged visual signal (e.g., orange flag or strobe) or a redundant radio channel.

  • Failure Protocol: If primary and secondary comms fail, the VO must move to a pre-determined "Emergency Meeting Point." The PIC, noticing the comms loss, must initiate a Return to Home (RTH) or landing sequence.

Appendix: VO Competency Checklist (Sample)

To assist RPOC holders in maintaining compliance, this form should be completed for every VO prior to joining a mission.

Visual Observer Competency Check Form

Candidate Name: ____________________ Certificate #: ______________

Competency Area	Requirement	Pass/Fail
Prerequisites	Holds a valid TC Basic or Advanced Pilot Certificate.	[ ]
Regulatory	Can define EVLOS limits (2 NM / 3.7 km max distance).	[ ]
Communication	Demonstrates standard phraseology (Traffic/Direction/Elevation).	[ ]
Scanning	Demonstrates 10-degree block scanning for 30 consecutive mins.	[ ]
Situational Awareness	Correctly identifies "converging" vs. "diverging" traffic.	[ ]
Emergency	Knows the "Abort" command and PIC acknowledgment loop.	[ ]
CRM	Understands the "Sterile Cockpit" rule during critical flight phases.	[ ]

Chief Pilot Signature: ____________________ Date: ______________

Conclusion

The evolution of the Visual Observer is a sign of the Canadian drone industry coming of age. We are moving away from "best efforts" and toward aviation-grade standards. By ensuring your VOs are certified and professionally trained, you aren't just checking a box for Transport Canada—you are significantly reducing the risk of a mid-air collision.

Update your manuals, certify your observers, and fly into 2026 with confidence.

References:

• Canadian Aviation Regulations (CARs) Part IX, Sections 900.01, 901.20, and 901.75.

• Standard 923 – Vision-Based Detect and Avoid (DAA).

• Transport Canada Advisory Circular (AC) 903-001: RPAS Operational Risk Assessment.

• TP 15263: Knowledge Requirements for Pilots of Small RPAS.