FAA Part 135 (On-Demand Charter)

What's the difference between Part 91 and Part 135?

Part 91 covers non-commercial operations including most corporate flight departments. Part 135 covers commercial operations where the operator is paid to provide transportation. The trigger for Part 135 is generally compensation for the flight unless the operation qualifies for limited Part 91 exceptions. Part 135 imposes substantially more rigorous training, recordkeeping, and operational requirements than Part 91.

What pilot qualifications does Part 135 require?

Varies by operation: VFR-only Part 135 PIC requires 500 hours flight time; IFR Part 135 PIC requires 1,200 hours total time, 500 cross-country hours, and instrument rating; SIC for IFR Part 135 requires 100 hours flight time and instrument rating. All Part 135 pilots must complete recurrent training every 12 calendar months and pass an annual proficiency check (the 'Part 135.293 check').

What is operational control under Part 135?

Operational control is the carrier's responsibility to make safe-conduct decisions about each flight. The carrier (not the customer) decides whether to fly given weather, mechanical, crew, or fuel conditions. Operational control violations are a frequent enforcement issue, especially with wet leases or dry leases that blur control lines. The carrier's Director of Operations is formally responsible for operational control.

Is drug and alcohol testing required for Part 135?

Yes. Part 135 carriers must comply with Part 120 drug and alcohol testing program covering pre-employment, random, post-accident, reasonable suspicion, return-to-duty, and follow-up testing. The program covers pilots, mechanics performing safety-sensitive maintenance, and dispatchers. Records retention: 5 years for positive tests, 1 year for negative tests, 5 years for refusal-to-test records.