Part 91 and Part 135 Background
The Federal Aviation Regulations (FAR) outline different requirements for general aviation (Part 91) and commercial charter operations (Part 135). One of the key distinctions between Part 91 and 135 is the documentation required for flight operations. Below is a breakdown of the primary document categories and the specific requirements under each Part.
Pilot Documentation
FAR Part 91:
- Pilot Certificate (Private, Commercial, or ATP depending on operation).
- Medical Certificate (varies by pilot privileges).
- Government-issued photo ID.
- Logbook (if required for flight currency or endorsements).
FAR Part 135:
- ATP or Commercial Pilot Certificate (with appropriate type ratings, if necessary).
- Second Class Medical Certificate (at minimum, First Class for PIC of scheduled flights).
- Government-issued photo ID.
- Logbook (for training and currency records, as required by company and FAA).
- Company Operations Manual and Company ID.
- Emergency and Abnormal Procedures Checklist.
- Flight Duty and Rest Records.
Aircraft Maintenance Documentation
FAR Part 91:
- Airworthiness Certificate.
- Registration Certificate.
- Weight and Balance Data.
- Operating Limitations (POH/AFM, placards, etc.).
- Maintenance Logbooks (Airframe, Engine, Propeller).
- Compliance with Annual Inspection or Progressive Inspection.
- ELT Inspection and Battery Replacement Records.
- AD Compliance Records.
FAR Part 135:
- All Part 91 maintenance documentation, plus:
- Approved Aircraft Inspection Program (AAIP) or Continuous Airworthiness Maintenance Program (CAMP).
- 100-hour Inspections (for aircraft used for hire).
- Pre-flight maintenance status report available to pilots.
- MEL (Minimum Equipment List) authorization and compliance.
- Weight & Balance calculations recorded and retained.
- Operational Control documentation (showing aircraft dispatch and release information).
- Maintenance Status Board or equivalent system tracking aircraft discrepancies and maintenance due items.
Flight Planning & Weather Documentation
FAR Part 91:
- Weather briefing (self-conducted or obtained from an official source such as Flight Service, ForeFlight, etc.).
- Flight Plan (VFR optional, IFR required).
- NOTAMs (recommended but not required to be documented).
- Fuel requirements (considered but not recorded formally).
- Performance calculations (optional but strongly recommended).
FAR Part 135:
- FAA-approved Weather Briefing (from an FAA-approved source, such as an FAA-certified dispatcher or official weather service).
- Dispatch or Flight Release (required for most operations, particularly for multi-pilot operations).
- Filed and approved Flight Plan (required for IFR and most VFR operations).
- Alternate Airport Requirements (strict fuel and weather criteria must be documented).
- Load Manifest (including weight and balance, fuel load, and passenger count, signed by PIC).
- Performance data (must be calculated and recorded for each leg of the flight).
- MEL review and confirmation of deferrals.
Operational Control & Dispatch Records
FAR Part 91:
- No formal dispatch system required.
- Pilot-in-command (PIC) has sole authority over operational control.
- Flight itinerary is at the pilot’s discretion.
- Passenger manifest not required.
- No regulatory duty/rest tracking.
FAR Part 135:
- Dispatch or Flight Release (for some operations, an official dispatcher is required).
- Flight Following System (required for some 135 operators to track aircraft en route).
- Company-issued Operational Control Procedures (outlining who has authority over flight planning, maintenance releases, and go/no-go decisions).
- Passenger Manifest (required to be onboard and available to company personnel).
- Duty and Rest Time Records (must be documented and available for FAA inspection).
- Aircraft Utilization Reports (tracking aircraft hours, cycles, and maintenance due items).
Passenger & Cargo Documentation
FAR Part 91:
- No specific documentation required for passengers.
- Hazardous materials (HAZMAT) transport largely unregulated for private operations.
FAR Part 135:
- Passenger ID verification and manifest.
- Briefing Card and Safety Instructions provided.
- Cargo documentation (if applicable, including Dangerous Goods/Hazardous Materials declaration and proper securing of cargo).
- TSA security compliance (for certain Part 135 operators under 12,500 lbs.).
Record Retention Requirements
FAR Part 91:
- Aircraft logbooks retained indefinitely by owner/operator.
- No formal record retention requirements for flight logs, manifests, or performance data.
FAR Part 135:
- Flight and duty records retained for at least 12 months.
- Load manifests retained for at least 30 days.
- Maintenance records retained as required by Part 135 regulations.
- Training records for pilots and crew retained for specific periods (varies by operation).
Conclusion
The documentation requirements under FAR Part 91 are minimal, as it is designed for private and non-commercial operations. Pilots operating under Part 91 have full discretion over their record-keeping, except for maintenance and aircraft certification documents. On the other hand, FAR Part 135 has much stricter documentation and record retention rules, requiring comprehensive tracking of flights, pilot duty time, weather planning, dispatch releases, and passenger/cargo handling.
Understanding the differences between Part 91 and 135 documentation is crucial for pilots and operators to ensure regulatory compliance and safe flight operations under the appropriate Part of the FARs.
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