Advisory Circulars

Commercial & Business Aviation


No. 0199


Chief Pilot Qualifications - Subpart 702 Operations


This Commercial and Business Aviation Advisory Circular (CBAAC) is intended to inform air operators of a recent amendment to the Commercial Air Service Standards (CASS) that has changed the requirements for appointment to the position of Chief Pilot of subpart 702 Operations of the Canadian Aviation Regulations (CARs). This CBAAC also announces an exemption to this recent amendment to the CASS.


Clause 722.07(2)(b)(i)(C) of the CASS - Qualifications and Responsibilities of the chief pilot.


Prior to the latest amendment of the CASS, chief pilot experience requirements were based on calendar time and did not specify a minimum amount of flight time.

The CARs have been amended to redefine the minimum requirements for the position.

The previous minimum experience of:

"at least one (1) year experience within the preceding three (3) years as pilot-in-command of an aircraft operated by the air operator;"

has been changed to the new minimum of:

"at least 500 hours of flight time of which 250 hours were acquired within the preceding three (3) years on the same category of an aircraft operated by the air operator."

All other clauses of this Standard are unchanged and remain in effect.

Due to the language with which these new minimum requirements were drafted, these requirements could be interpreted as on-going requirements to hold the position of chief pilot. This was not the intention of the change. These requirements are intended for initial appointment to the position of chief pilot.


An air operator must designate a person and position whose responsibilities and functional duties encompass those that are set out in CASS, section 722.07. The air operator may use a different title for this position, however it shall be identified for Transport Canada purposes as a chief pilot.

An organization may have more than one chief pilot if desired, as long as all required duties and responsibilities are clearly designated. If more than one chief pilot is identified, there must be a clear delineation of responsibility (i.e. individual chief pilots may be responsible for specific geographic regions, aircraft types, etc.).

When assessing a candidate's experience for initial appointment to the chief pilot position, Transport Canada will expect that the minimum experience required (at least 500 hours of flight time, of which 250 hours were acquired within the preceding three (3) years on the category of an aircraft operated by the air operator), will be considered under the definition for aircraft certification found in CAR section 101.01. Thus "category" means:

when used in reference to the certification of aircraft, a grouping of aircrafts based upon intended use or operating limitations such as normal, utility, aerobatic, commuter and transport;

Therefore a chief pilot candidate for a subpart 702 of the CARs operation would be required to have recency and experience on the category of aircraft operated. Cases where other aeroplane categories are operated under subpart 702 in a fleet mix will be considered on an individual basis.

Note: The requirements for the subpart 703 of the CARs (Helicopter) chief pilot are different than the subpart 702 of the CARs chief pilot requirements.


Air operators conducting business under subpart 702 of the CARs should ensure that candidates nominated for appointment to the chief pilot position meet the new requirements.

M.R. Preuss
Commercial & Business Aviation

Commercial & Business Aviation Advisory Circulars (CBAAC) are intended to provide information and guidance regarding operational matters. A CBAAC may describe an acceptable, but not the only, means of demonstrating compliance with existing regulations. CBAACs in and of themselves do not change, create any additional, authorize changes in, or permit deviations from regulatory requirements.

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