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Compensation Flights LOA

FAR 91.147 — Compensation Flights LOA

FAR 91.147 covers nonstop passenger-carrying flights for hire within 25 SM of an airport, including LOA requirements, drug testing, and Part 136 safety rules.

In Plain English

FAR 91.147 governs nonstop passenger-carrying flights for compensation or hire that begin and end at the same airport and stay within a 25-statute-mile radius of that airport, conducted in airplanes, powered-lifts, or rotorcraft. These are typically sightseeing-style operations.

Unless every flight is flown under § 91.146 (charitable/community events), the Operator must:

  • Comply with the safety provisions of Part 136, Subpart A
  • Register and implement drug and alcohol testing programs under Part 120
  • Comply with applicable Part 5 (Safety Management System) requirements
  • Apply for and receive a Letter of Authorization (LOA) from the responsible Flight Standards office

The LOA application must list the operator's name and d/b/a, business addresses, person responsible for management, person responsible for maintenance, aircraft details (type, N-number, make/model/series), and antidrug program registration. Once issued, the Operator must comply with the LOA's provisions.

This matters because flying paying passengers — even on short local hops — pulls you out of standard Part 91 and adds commercial-style oversight to protect the public.

Regulation Text
14 CFR § 91.147
§ 91.147 Passenger-carrying flights for compensation or hire. (a)For the purposes of this section,means any person conducting nonstop passenger-carrying flights in an airplane, powered-lift, or rotorcraft for compensation or hire in accordance with §§ 119.1(e)(2), 135.1(a)(5), or 121.1(d) of this chapter that begin and end at the same airport and are conducted within a 25-statute mile radius of that airport. (b)An Operator conducting passenger-carrying flights for compensation or hire must meet the following requirements unless all flights are conducted under § 91.146. The Operator must: (1) Comply with the safety provisions of part 136, subpart A of this chapter. (2) Register and implement its drug and alcohol testing programs in accordance with part 120 of this chapter. (3) Comply with the applicable requirements of part 5 of this chapter. (4) Apply for and receive a Letter of Authorization from the responsible Flight Standards office. (c)Each application for a Letter of Authorization must include the following information: (1) Name of Operator, agent, and any d/b/a (doing-business-as) under which that Operator does business. (2) Principal business address and mailing address. (3) Principal place of business (if different from business address). (4) Name of person responsible for management of the business. (5) Name of person responsible for aircraft maintenance. (6) Type of aircraft, registration number(s), and make/model/series. (7) Antidrug and Alcohol Misuse Prevention Program registration. (d)The Operator must comply with the provisions of the Letter of Authorization received. [Docket FAA-2021-0419, Amdt. 91-374, 89 FR 33108, Apr. 26, 2024]
Oral Exam Questions a DPE Might Ask
Q1What kind of operation does FAR 91.147 cover, and what is the geographic limit?
Per FAR 91.147, it covers nonstop passenger-carrying flights for compensation or hire in airplanes, powered-lifts, or rotorcraft that begin and end at the same airport and stay within a 25-statute-mile radius of that airport.
Q2What four key compliance requirements must an Operator meet under FAR 91.147?
FAR 91.147(b) requires the Operator to comply with Part 136 Subpart A safety provisions, register and implement Part 120 drug and alcohol testing, meet applicable Part 5 SMS requirements, and obtain a Letter of Authorization from the responsible Flight Standards office.
Q3What information must be included in the application for a Letter of Authorization?
FAR 91.147(c) requires the operator's name and any d/b/a, business and mailing addresses, principal place of business, persons responsible for management and maintenance, aircraft type and registration details, and antidrug/alcohol program registration.
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Related Sections in Part 91
§ 91.1
Part 91 Applicability
§ 91.1001
Fractional Ownership Applicability
§ 91.1002
Fractional Ownership Compliance
§ 91.1003
Fractional Ownership Contracts
§ 91.1005
Fractional Ownership Limitations
§ 91.1007
Fractional Program Flights
§ 91.1009
Operational Control
§ 91.101
Flight Rules Applicability
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FAR 91.147 — Passenger Flights for Compensation or Hire