Legal Interpretations
Lavenson 2011
Summary
The Question
May a Part 135 operator use the IFR takeoff minimums in operations specifications C057 or H106 when a more restrictive takeoff minimum is published for the airport?
Background
A requester asked about operations specification paragraphs C057 (airplanes) and H106 (helicopters), citing Ukiah Airport, where the published takeoff minimum is more restrictive than the operations specification minimums.
The FAA’s Interpretation
No. C057 and H106 authorize takeoff minimums equal to the lowest straight-in landing minimums only when no takeoff minimum is prescribed under 14 CFR part 97 for the airport (14 CFR 97.20, 14 CFR 135.225(h)). Only when none is published may an operator use the standard minimums in 14 CFR 91.175 or the operations specification minimums, so Ukiah's published 300-foot ceiling and 1-statute-mile visibility applies.
- Requester
- Lavenson
- Issued
- January 20, 2011
- Subjects
- General Operating & Flight Rules · Air Carrier & Commercial Operations
Regulations Cited
Page 1
U.S. Department
of Transportation
Federal Aviation
Administration
JAN 2 0 2011
Markus Lavenson
Dear Mr. Lavenson,
Office of the Chief Counsel 800 Independence Ave., S.W.
Washington, D.C. 20591
This is in response to your October 4, 20 l 0, request for legal interpretation regarding the applicability of operation specification paragraphs C057, !FR Takeoff Minimums for part 135 Airplane Operations, and Hl06, !FR Standard Takeoff Minimums for Helicopter Operations, when there is a published takeoff minimum. Specifically, you question when there is a published takeoff minimum that is greater, or otherwise more restrictive, than the takeoff minimums authorized via operation specification C057 or HI 06, yvhether an operator may use the minimums authorized via the operation specification. Based on the discussion below, the operator must comply with the published takeoff minimums. Operation Specification paragraphs C057 and Hl06 are issued to all part 135 operators that conduct operations under instrument flight rules to authorize the operator to use takeoff minimums equal to the lowest straight-in landing minimums, provided there is no prescribed, or published, takeoff minimum under 14 CFR part 97 for the airport. See 14 C.F.R. §§ 97.20, 135.225(h); see also FAA Order 8900.1, Chg. 118, Vol. 3, Ch. I 8, para. 3- 87 l (Nov. 12, 20 I 0) (discussing applicabi lity of operation specification paragraph C057). Only when a takeoff minimum is not published for an airport may a certificate holder use the applicable standard takeoff minimums set forth in 14 C.F.R. § 91.175 or the takeoff minimums authorized by these operation specification paragraphs. Therefore, in the Ukiah Airport example you referenced, the published takeoff minimum for Ukiah Airport, which requires a ceiling of 300 feet and visibility of 1 statute mile, would be the applicable takeoff minimum.
We appreciate your patience and trust that the above responds to your concerns. If you need further assistance, please contact my staff at (202) 267-3073. This response was prepared by Anne Bechdolt and coordinated with the Flight Technologies and Procedures Division and Air Transportation Division of Flight Standards Service.
Sincerely,
R~~=~Assistant Chief Counsel for Regulations, AGC-200
Regulations Referenced
Snapshot retrieved August 6, 2026.