September-October_2021 - 19

AIRPORT GURU
Overall, the vast majority of Part
135 certificates are issued for operations
of business aircraft. According to
data provided by the National Air
Transportation Association, most are
very small businesses with an average
of 37 aviation employees. In addition,
68 percent of Part 135 operators have
three or fewer aircraft, and 80 percent
have five or fewer aircraft.
Part 135 rules are designed to hold
aircraft operators receiving payment
for transportation to a higher standard
than those providing their own
transportation. For example, Part 135
imposes pilot training, flight-dutytime
and rest requirements that are
not mandated under Part 91, as well
as more stringent operational, aircraft
maintenance and aircraft equipment
requirements.
In some cases, this means that an
aircraft operated under Part 91 could
take off under conditions of zero
visibility, while an aircraft under Part
135 could not. Under Part 91, necessary
runway length is determined by the
aircraft's performance limitations,
while Part 135 requires an additional
40 percent of runway length. Also,
while passenger identification is
required under Part 135, this does not
apply to Part 91 flights within the U.S.
This raises the serious question of
how passengers can determine whether
or not an operator has a positive safety
record. For example, many Part 91 and
Part 135 passengers expect the same, or
a similar, level of safety as they would
on a Part 121 scheduled airline flight.
While a person may understand the
risk associated with skydiving, he or
she may not be aware that the aircraft
operates under less stringent safety
standards.
Wh i le the NTSB's fina l
recommendations for Part 91 flights
will soon be available, the FAA has
responded to several of the NTSB's top
recommendations to improve Part 135
operations safety. These action items
include, but are not limited to, the
following:
* Require all newly hired and
transferred pilots flying air tours in
Hawaii to receive cue-based weather
training for the pertinent island/site
prior to initiating flight operations.
ALL PHOTOS COURTESY NATA
Conduct initial and recurrent checks
to verify the pilot's knowledge of
weather-related decision making
pertinent to the assigned area of
operation.
* Conduct a review to determine the
feasibility of requiring all Part 135
certificate holders to install flight
data monitoring systems on their
aircraft, including a review of their
level of participation in voluntary
programs.
* To reduce weather-related accidents
involving the Ketchikan, Alaska air
tour industry, conduct customized
surveillance specifically focused
on operator training programs and
the manner in which the training is
implemented and delivered.
* Evaluate extending the current
guidance, regulations and policy that
address controlled flight into terrainavoidance
training programs for part
135 helicopter operations to all Part
135 operations.
* Evaluate policy and rulemaking
options regarding the implementation
of special operating rules for the
Ketchikan air tour industry that
include en route visual flight rules
weather minimums and are more
conservative than those specified in
part 135.
* Conduct a review and hold meetings
to determine the feasibility of
applying a safety management system
requirement to Part 135 operations
in place of the current voluntary
program.
* Work in coordination with various
working groups/committees
to
produce solutions to enhance terrain
awareness system protections and
determine if further standards are
necessary.
* Focus on improving voluntary
programs
implemented by Part
135 operators/certificate holders to
reduce controlled flight into terrain
accidents, with special emphasis on
Alaska and human factors issues.
* Develop a safety alert for Part 135
certificate holders that operate under
visual flight rules in mountainous
terrain at altitudes below the required
clearance of the aircraft's required
terrain avoidance awareness system
to ensure pilots are aware of the risks
and develop plans to minimize those
risks.
Finally, NTSB data indicates that,
while Part 121 airline operations
maintain the best safety record in
civil aviation, the Part 135 on-demand
air taxi segment has the next lowest
accident rate. These are followed by
Part 91 jet and Part 135 on-demand
turboprop operations, with the Part
91 turboprop category holding the
worst safety record. In light of these
facts, the discussion of whether Part
91 operators should be held to a
higher safety standard merits careful
discussion and consideration. 
SEPTEMBER/OCTOBER 2021 \ AVIATIONPROS.COM / 19
http://www.AVIATIONPROS.COM
September-October_2021

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