Direct Answer
14 CFR §135.79 requires every Part 135 certificate holder to have established procedures for locating each flight for which an FAA flight plan is not filed — capturing at least VFR-flight-plan-level information, providing for timely notification of an FAA or search and rescue facility if an aircraft is overdue or missing, and pre-arranging communication re-establishment details for flights in areas where communications cannot be maintained.
The flight locating information must be retained at the certificate holder's principal place of business (or other places designated in the procedures) until the completion of the flight. Part 135 has no Part 121-style dispatch-release requirement: there is no regulation requiring a Part 135 flight release document, a dispatcher signature, or release contents. The flight release used in on-demand charter is the operator's own operational-control record under §135.77 and its manual — not a CFR mandate.
The only release-adjacent Part 135 record with a hard retention period is the multiengine load manifest: prepared in duplicate before each takeoff under §135.63(c), carried to destination by the pilot in command, and kept by the certificate holder for at least 30 days under §135.63(d).
The Exact Text of §135.79
Section 135.79 is short, and its precision matters. Paragraph (a) requires each certificate holder to have procedures established for locating each flight for which an FAA flight plan is not filed. Those procedures must, in the regulation's own words:
"Provide the certificate holder with at least the information required to be included in a VFR flight plan"
"Provide for timely notification of an FAA facility or search and rescue facility, if an aircraft is overdue or missing"
"Provide the certificate holder with the location, date, and estimated time for reestablishing communications, if the flight will operate in an area where communications cannot be maintained."
Paragraph (b) is the retention rule, quoted in full: "Flight locating information shall be retained at the certificate holder's principal place of business, or at other places designated by the certificate holder in the flight locating procedures, until the completion of the flight."
Paragraph (c) is the FAA-visibility rule: "Each certificate holder shall furnish the representative of the Administrator assigned to it with a copy of its flight locating procedures and any changes or additions, unless those procedures are included in a manual required under this part." In practice, nearly every operator satisfies (c) the second way — by putting the procedures in the general operations manual, which §135.23(l) expressly requires to include "Flight locating procedures, when applicable." Once the procedures live in the manual, they become revision-controlled manual content — see the Part 135 GOM/MOM manual requirements guide for how manual revisions are managed and distributed.
The trigger is the FAA flight plan — not VFR vs. IFR
Section 135.79 keys on whether an FAA flight plan is filed for the flight, because a flight on an FAA flight plan is already inside the FAA's alerting system. A company flight log or internal trip sheet is not an FAA flight plan. The rule bites hardest on VFR on-demand legs and repositioning flights where crews skip the FAA flight plan — those are exactly the flights the certificate holder's own locating system must cover, with the procedures already established before the flight departs.
For the broader inventory of records a charter operator must keep beyond flight locating, see what records a Part 135 operator must keep, and for the certificate-level authorizations that frame all of it, see operations specifications (OpSpecs) explained.
What a Flight Locating Record Must Actually Contain
Section 135.79(a)(1) sets the information floor by reference: the certificate holder must capture at least the information required to be included in a VFR flight plan. That list lives in 14 CFR §91.153(a), which means a compliant flight locating record covers, for each flight:
The §91.153(a) information items (the §135.79(a)(1) floor)
On top of the information floor, the procedures themselves must work as a system. Paragraph (a)(2) demands a functioning overdue-aircraft process: someone at the certificate holder must actually be watching estimated arrival times and must know which FAA facility or search and rescue facility to notify, and when, if an aircraft goes overdue or missing. Paragraph (a)(3) demands advance planning for communication gaps: if a flight will operate in an area where communications cannot be maintained — common in Alaska operations, offshore legs, and mountainous terrain — the record must show where and when the crew will reestablish contact, before they lose it.
Who holds the record is regulated too. Under §135.79(b), flight locating information stays at the certificate holder's principal place of business — or at other places the certificate holder has designated in its flight locating procedures. That designation language matters for operators running multiple bases: a satellite base can hold the flight locating records for its own flights only if the written procedures say so. An inspector who finds flight-following records scattered across personal phones and text threads, with no designated holding location, has found a §135.79(b) nonconformity even if every flight was actually followed.
"Until the completion of the flight" is a floor, not a strategy
Read literally, §135.79(b) lets an operator discard flight locating information the moment the flight completes. The regulation treats the record as a live search-and-rescue tool, not an archive — once the aircraft is safely on the ground, the locating purpose is spent. That is the entire CFR retention requirement: until the completion of the flight.
Almost no well-run operator actually does that, for three reasons. First, the same record is usually the operator's evidence of who exercised operational control over the flight — the central question in any illegal-charter inquiry. Second, many operators commit in their own manuals to retaining trip records for 30, 90, or 180 days — and once the commitment is in the manual, inspectors hold the operator to it. Third, post-accident and post-incident investigations reconstruct flights from exactly these records. The regulatory floor and the operational need are very different numbers.
Note one specialized corner of Part 135 where the FAA did impose a control-center regime: helicopter air ambulance. Under §135.619, certificate holders with 10 or more helicopter air ambulances assigned to their operations specifications must have an operations control center staffed by operations control specialists, with documented duties in the operations manual and training records retained for each specialist for the duration of employment and 90 days after. The HEMS records guide covers that regime in depth.
Part 135 Flight Locating vs. Part 121 Dispatch: The Side-by-Side
The word "dispatch" gets used loosely across charter aviation, but in the regulations it is a term of art that belongs to Part 121. Part 121 actually contains two different release regimes — the dispatcher-driven system for domestic and flag operations, and the flight-release system for supplemental operations — and Part 135 deliberately adopts neither. Seeing all three side by side makes clear what Part 135 does and does not require.
In Part 121 domestic operations, §121.593 provides that — except when an airplane lands at an intermediate airport specified in the original dispatch release and remains there for not more than one hour — no person may start a flight unless an aircraft dispatcher specifically authorizes that flight. Flag operations are stricter still: §121.595 requires dispatcher authorization for every flight and adds that no person may continue a flight from an intermediate airport without redispatch if the airplane has been on the ground more than six hours. Behind those rules sits an entire dispatcher infrastructure: §121.395 requires enough qualified aircraft dispatchers at each dispatch center to ensure proper operational control of each flight, and under §121.663 the certificate holder prepares a dispatch release for each flight between specified points based on information furnished by an authorized aircraft dispatcher — and, in the regulation's words, "The pilot in command and an authorized aircraft dispatcher shall sign the release only if they both believe that the flight can be made with safety."
| Requirement | Part 121 domestic / flag | Part 121 supplemental | Part 135 commuter & on-demand |
|---|---|---|---|
| Who authorizes the flight | An aircraft dispatcher must specifically authorize each flight (§§121.593, 121.595) | The person authorized by the operator to exercise operational control (§121.597(a)) | A person the certificate holder lists in its manual as authorized to exercise operational control (§135.77) |
| Required release document | Dispatch release, prepared for each flight (§121.663); contents prescribed by §121.687 | Flight release executed before flight by the PIC or the operational-control person (§121.597(b)) | None required by regulation — any flight release is the operator's own procedure |
| Prescribed contents | Aircraft identification number, trip number, departure/intermediate/destination/alternate airports, type of operation (IFR/VFR), minimum fuel supply, ETOPS diversion time where applicable, plus attached weather (§121.687) | Conditions under which the flight will be conducted, set forth in the executed release (§121.597(b)) | No prescribed release contents; flight locating information must meet the §91.153(a) VFR flight plan floor (§135.79(a)(1)) |
| Joint responsibility | PIC and aircraft dispatcher jointly responsible for the "preflight planning, delay, and dispatch release of a flight" (§121.533(b)) | PIC and director of operations "jointly responsible for the initiation, continuation, diversion, and termination of a flight" (§121.537(b)) | Certificate holder is responsible for operational control; authorized persons listed by name and title in the manual (§135.77) |
| Re-release after a ground stop | Domestic: intermediate stop over one hour requires new dispatcher authorization (§121.593). Flag: redispatch required after more than six hours on the ground (§121.595(b)) | New flight release required to continue from an intermediate airport after more than six hours on the ground (§121.597(c)) | No re-release rule; the operator's own operational-control procedures govern |
| Record retention | Load manifest, dispatch release, and flight plan copies kept at least three months (§121.695) | Load manifest, flight release, airworthiness release, pilot route certification, and flight plan kept at the principal base at least three months (§121.697) | Flight locating information until completion of the flight (§135.79(b)); multiengine load manifest at least 30 days (§135.63(d)) |
| Dispatcher certificate required | Yes — enough qualified aircraft dispatchers at each dispatch center (§121.395) | No dispatcher requirement; operational control persons instead | No — Part 135 imposes no aircraft dispatcher certificate requirement on flight followers or coordinators |
Two things stand out from the table. First, Part 135's philosophy is closest to Part 121 supplemental — operational control rests with the certificate holder's own designated people rather than an independent dispatcher corps — which makes sense, since both regimes govern non-scheduled operations. Second, Part 135 stops one full step short of even the supplemental regime: supplemental operators must execute a flight release for every flight and keep it three months under §121.697; Part 135 operators are not required to create the document at all.
That regulatory gap is exactly why so many operators are confused about what their obligations are — and why the people who run charter operations day to day, the director of operations and the chief pilot among the required management personnel, end up designing the flight release system themselves inside the manual. The regulation hands them the responsibility (§135.77) without handing them the form.
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The Part 135 "Flight Release": An Operational-Control Record, Not a CFR Mandate
If no regulation requires a Part 135 flight release, why does virtually every credible charter operator issue one? Because the regulation that does exist — §135.77 — creates a duty that is nearly impossible to demonstrate without one. The section reads, in full: "Each certificate holder is responsible for operational control and shall list, in the manual required by § 135.21, the name and title of each person authorized by it to exercise operational control." And 14 CFR 1.1 defines operational control as "the exercise of authority over initiating, conducting or terminating a flight."
Put those together: someone named in your manual must exercise authority over initiating every flight. The flight release — sometimes called a trip release or trip sheet — is the contemporaneous record that this actually happened: which authorized person initiated the flight, for which aircraft, with which crew, on what itinerary, under what conditions. In practice, FAA inspector guidance treats the certificate holder's operational-control system as a core surveillance item, and the FAA addresses operational control in the operations specifications it issues to each certificate holder — so the absence of any release practice tends to draw exactly the questions an operator least wants. The full analysis of how operational-control documentation wins or loses enforcement cases is in what is operational control in Part 135.
Three documents make up the release-adjacent record set for a Part 135 flight. Only the third is prescribed in detail by regulation:
Flight Locating Record
14 CFR §135.79What the rule requires
Required for each flight for which an FAA flight plan is not filed. Must capture at least the §91.153(a) VFR flight plan information, support timely overdue-aircraft notification to an FAA or search and rescue facility, and pre-arrange communication re-establishment details for flights through communication gaps. Held at the principal place of business or other designated places until the completion of the flight. The procedures themselves must be furnished to the assigned FAA representative unless they are in a required manual — and §135.23(l) puts them in the manual for nearly everyone.
How FileFlo tracks it
FileFlo classifies flight locating records and flight-following logs as a document class, indexes them by aircraft and date, and keeps them retrievable long after the regulatory floor has passed — because the operational-control question outlives the flight.
Flight Release / Trip Release
Operator procedure under §135.77 and the §135.21 manualWhat the rule requires
Not required by any Part 135 regulation — there is no Part 135 counterpart to §121.663 or §121.597. The release exists because the operator's own operational-control procedures call for it: it records that a person listed in the manual under §135.77 authorized the specific flight before departure. Once the manual describes a release procedure, following it is a manual-compliance matter, and inspectors will sample releases against flights flown. The release is also the document the FAA asks for first when it investigates who really controlled a charter flight.
How FileFlo tracks it
FileFlo classifies and stores flight releases with crew and aircraft cross-references, tracks them alongside the §135.63(a)(4) pilot records and training records they depend on, and assembles them into the audit binder for surveillance visits.
Load Manifest
14 CFR §135.63(c) and (d)What the rule requires
Required for multiengine aircraft: a load manifest prepared in duplicate before each takeoff, covering the number of passengers; total weight of the loaded aircraft; maximum allowable takeoff weight for that flight; center of gravity limits; center of gravity of the loaded aircraft (unless loading follows an approved schedule or other approved method); aircraft registration number or flight number; origin and destination; and crew member identification with crew position assignments. The PIC carries a copy to the destination, and the certificate holder keeps completed manifests at least 30 days at its principal operations base or another approved location.
How FileFlo tracks it
FileFlo indexes load manifests by aircraft, date, and flight, tracks the 30-day §135.63(d) retention window and any longer manual commitment, and ties manifests to the weight-and-balance records they draw on.
The load manifest deserves one extra note: it is where flight release practice meets the aircraft's weight-and-balance data. The §135.63(c) items presume current empty weight and CG data for the specific aircraft — which is why manifest findings and weight-and-balance findings so often travel together in surveillance. The aircraft weight and balance records guide covers that record chain, and the Part 135 pilot records guide covers the §135.63(a)(4) crew records that every release implicitly certifies are current.
FileFlo is the proof layer, not the flight-following desk
FileFlo is a compliance document intelligence platform — it classifies, indexes, and tracks the flight locating records, flight releases, and load manifests your operation produces, and proves they exist when an inspector asks. It does not perform flight following, exercise operational control, dispatch aircraft, or replace your operations control center or scheduling system. The system that follows the flight and the system that proves the paperwork should not be the same system — one is operational, the other is evidentiary.
Retention Traps: Where Operators Get Burned
Part 135 trip records carry wildly different retention clocks, and conflating them is one of the most common findings in records audits. Here is the actual retention map for release-adjacent and related records:
| Record | CFR retention floor | Where it must be held |
|---|---|---|
| Flight locating information | Until the completion of the flight (§135.79(b)) | Principal place of business, or other places designated in the flight locating procedures |
| Load manifest (multiengine aircraft) | At least 30 days (§135.63(d)) | Principal operations base, or another location used by the operator and approved by the Administrator; PIC carries a copy to destination |
| Aircraft list (§135.63(a)(3)) | At least 6 months (§135.63(b)) | Principal business office or other approved places |
| Individual pilot and flight attendant records (§135.63(a)(4), (a)(5)) | At least 12 months (§135.63(b)) | Principal business office or other approved places |
| Flight release / trip release | No CFR retention period — governed by the operator's own manual commitment | Wherever the manual says — and inspectors will check that practice matches the manual |
| Part 121 comparison: dispatch release / flight release | At least 3 months (§121.695(b) domestic/flag; §121.697(e) supplemental) | Certificate holder's records; supplemental at the principal base of operations |
The traps follow directly from the table. An operator who treats "until completion of the flight" as permission to keep nothing will be unable to answer the operational-control question for any past flight. An operator whose manual promises 90-day trip-record retention but whose files show gaps has converted a generous voluntary practice into a manual-compliance finding. And an operator who holds load manifests at a satellite base that was never approved by the Administrator has a §135.63(d) location problem even with every manifest intact.
This is also where the next regulatory wave lands. Safety management systems run on exactly these operational records — flight risk assessments, release decisions, and flight-following data are the inputs a functioning SMS analyzes — so operators building toward the Part 5 SMS deadline in 2027 will find that a disciplined trip-record system is a prerequisite, not a nice-to-have. And when the FAA schedules its next records inspection, the trip records are sampled alongside everything else — the Part 135 surveillance audit preparation guide walks through how those visits actually unfold.
What a defensible Part 135 trip-record system looks like
Procedures in the manual
Flight locating procedures live in the GOM per §135.23(l), satisfying §135.79(c) without separate filings — and every revision is distributed under the manual revision-control process
Named operational-control persons
The manual lists the name and title of each person authorized to exercise operational control per §135.77 — and the list is current, not the version from two directors of operations ago
A release record for every flight
Whether or not an FAA flight plan was filed, an authorized person initiates each flight and the release captures aircraft, crew, itinerary, and conditions — the §1.1 operational-control act, in writing
Flight locating data meeting the §91.153(a) floor
Every non-FAA-flight-plan leg has a locating record with at least the VFR flight plan items, an arrival-watch process, and comm-out plans where coverage drops
Load manifests in duplicate, 30-day clock tracked
Multiengine flights generate the §135.63(c) manifest before takeoff; the PIC copy flies, the base copy enters the 30-day retention window at an approved location
Retention beyond the floor, matched to the manual
Whatever retention period the manual promises is the period the files actually show — with the operational-control answer recoverable for any flight an investigator might ask about
Sixty seconds to see where your trip records stand
The free FAA readiness score checks flight locating, release, and manifest record discipline alongside the rest of your Part 135 document set.
Frequently Asked Questions
What does 14 CFR §135.79 actually require for flight locating?
Section 135.79 requires every Part 135 certificate holder to establish procedures for locating each flight for which an FAA flight plan is not filed. The procedures must do three things: (1) provide the certificate holder with at least the information required to be included in a VFR flight plan — the items listed in 14 CFR §91.153(a), such as aircraft identification, route, departure point and time, point of first intended landing, fuel on board, and persons aboard; (2) provide for timely notification of an FAA facility or search and rescue facility if an aircraft is overdue or missing; and (3) where a flight will operate in an area where communications cannot be maintained, provide the certificate holder with the location, date, and estimated time for reestablishing communications. Under §135.79(b), the flight locating information must be retained at the certificate holder's principal place of business — or at other places designated by the certificate holder in the flight locating procedures — until the completion of the flight. Under §135.79(c), the certificate holder must furnish its assigned FAA representative a copy of the procedures and any changes, unless the procedures are included in a manual required under Part 135.
Does Part 135 require a dispatch release like Part 121?
No. Part 121 domestic and flag operations require a certificated aircraft dispatcher to specifically authorize each flight (§§121.593 and 121.595), require a dispatch release prepared for each flight and signed by both the pilot in command and an authorized aircraft dispatcher (§121.663), prescribe the minimum contents of that release (§121.687), and require the certificate holder to keep copies for at least three months (§121.695). Part 135 contains none of those requirements. There is no Part 135 section requiring a dispatch release, a flight release document, a dispatcher signature, or release contents. What Part 135 requires instead is operational control responsibility (§135.77 — the certificate holder must list in its manual the name and title of each person authorized to exercise operational control), flight locating procedures for flights without an FAA flight plan (§135.79), and a load manifest for multiengine aircraft (§135.63(c)). When a Part 135 operator issues a "flight release" or trip release, that document exists because the operator's own operational-control procedures call for it — not because a regulation prescribes it.
How long must Part 135 flight locating records be retained?
Under §135.79(b), flight locating information must be retained at the certificate holder's principal place of business (or at other places designated in the flight locating procedures) until the completion of the flight. That is one of the shortest retention floors anywhere in 14 CFR — the regulation treats the record as a live safety tool for finding an overdue aircraft, not as an archive. By contrast, the Part 135 load manifest must be kept for at least 30 days (§135.63(d)), and the Part 121 dispatch release and flight release must be kept for at least three months (§§121.695(b) and 121.697(e)). In practice, most Part 135 operators retain flight locating and flight release records far longer than the regulatory floor, because those records are the contemporaneous proof of who exercised operational control over each flight — the central question in illegal-charter investigations and FAA surveillance — and because many operators commit to longer retention in their own manuals.
Do I still need flight locating procedures if I file an FAA flight plan for every flight?
The §135.79(a) duty attaches to each flight for which an FAA flight plan is not filed — flights operating on an FAA flight plan are already in the FAA system for search-and-rescue alerting. The manual contents rule reflects this: §135.23(l) requires the manual to include flight locating procedures "when applicable." But very few operators can guarantee that every leg, including VFR repositioning legs, will always be on an FAA flight plan. A single leg flown without one triggers the requirement, and the procedures must already exist at that point — §135.79 requires established procedures, not improvisation after the fact. For that reason, in practice nearly all Part 135 certificate holders maintain flight locating procedures in their general operations manual and apply a single flight-following discipline to all flights, whether or not an FAA flight plan was filed for a particular leg.
Who can release a Part 135 flight, and do flight followers need an FAA dispatcher certificate?
Part 135 leaves this to the certificate holder's operational-control system. Section 135.77 makes the certificate holder responsible for operational control and requires it to list, in the manual required by §135.21, the name and title of each person authorized by it to exercise operational control. Those are the people who can authorize — release — a flight. Unlike Part 121 domestic and flag operations, where §121.395 requires enough qualified aircraft dispatchers at each dispatch center and §121.663 requires an authorized aircraft dispatcher's signature on each dispatch release, Part 135 contains no requirement that flight followers, flight coordinators, or anyone else in the operational-control chain hold an FAA aircraft dispatcher certificate. The one exception in spirit is helicopter air ambulance: under §135.619, certificate holders with 10 or more helicopter air ambulances assigned to their operations specifications must have an operations control center staffed by trained operations control specialists, with documented training records.
What must a Part 135 load manifest contain, and how long is it kept?
Under §135.63(c), for multiengine aircraft the certificate holder is responsible for preparing an accurate load manifest in duplicate before each takeoff. The manifest must cover: the number of passengers; the total weight of the loaded aircraft; the maximum allowable takeoff weight for that flight; the center of gravity limits; the center of gravity of the loaded aircraft (unless the aircraft is loaded according to an approved loading schedule or other approved method that keeps the CG within limits without computation); the registration number of the aircraft or flight number; the origin and destination; and identification of crew members and their crew position assignments. Under §135.63(d), the pilot in command must carry a copy of the completed load manifest in the aircraft to its destination, and the certificate holder must keep copies of completed load manifests for at least 30 days at its principal operations base or at another location it uses and the Administrator approves. The 30-day load manifest rule is the closest thing Part 135 has to the Part 121 release-retention requirement.
How does the Part 121 supplemental flight release compare to Part 135?
Part 121 supplemental operations are the closest regulatory cousin to Part 135 on-demand operations — both are non-scheduled — and the comparison is instructive. Supplemental operations do not use the domestic/flag dispatcher system; instead, §121.597 requires that no flight start under a flight following system without specific authority from the person authorized by the operator to exercise operational control, and requires a flight release executed by the pilot in command or that operational-control person before the flight. Under §121.537(b), the pilot in command and the director of operations are jointly responsible for the initiation, continuation, diversion, and termination of the flight. Under §121.697, the pilot in command carries the original or a signed copy of the load manifest, flight release, airworthiness release, pilot route certification, and flight plan to the destination, and the certificate holder retains the records at its principal base of operations for at least three months. Part 135 adopts the same operational-control philosophy — authority rests with the certificate holder, not an outside dispatcher — but stops short of requiring any release document at all. The flight release in Part 135 is an operator-created control record, not a CFR mandate.
If Part 135 does not require a flight release, why do FAA inspectors ask for flight release records?
Because operational control has to be proven, and the flight release is how operators prove it. 14 CFR 1.1 defines operational control as the exercise of authority over initiating, conducting, or terminating a flight, and §135.77 places that authority squarely on the certificate holder. In an illegal-charter investigation, a post-accident inquiry, or routine surveillance, the FAA's question for any given flight is: who decided this flight would go? A contemporaneous flight release — showing which authorized person initiated the flight, with which aircraft and crew, under what conditions — answers that question in the operator's favor. In practice, FAA inspector guidance treats the certificate holder's operational-control system, including its flight locating procedures and any release practice described in its manual, as a core surveillance item, and the FAA addresses operational control in the operations specifications it issues to each certificate holder. An operator whose manual describes a flight release procedure but who cannot produce the releases has a manual-compliance finding; an operator with no record at all of who authorized a flight has an operational-control problem, which is far worse.
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Reviewed by Chad Griffith, Founder, FileFlo — compliance document intelligence — June 10, 2026. Regulatory citations verified against the Code of Federal Regulations as of publication date.