Legal Interpretations
Wheeler-HeliFlite Shares 2017
Summary
The Question
Does the 14 CFR 135.168(b)(1) requirement that occupants wear life preservers beyond autorotational distance from the shoreline apply to single-engine helicopters, multiengine helicopters, or both?
Background
Before the rule took effect on April 24, 2017, HeliFlite Shares LLC asked whether the life preserver requirement was meant for multiengine or single-engine helicopter operations, noting the regulation does not distinguish between them.
The FAA’s Interpretation
Both; it applies to all rotorcraft. 14 CFR 135.168(b)(1) requires each occupant beyond autorotational distance from the shoreline to wear an approved life preserver with an approved survivor locator light, except helicopter air ambulance patients who cannot for medical reasons. Neither the regulation nor the FAA's 2014 helicopter operations final rule distinguishes multiengine from single-engine helicopters, which signifies the FAA intended the requirement to apply to all rotorcraft.
- Requester
- Wheeler
- Organization
- HeliFlite Shares
- Issued
- April 17, 2017
- Subjects
- General Operating & Flight Rules · Air Carrier & Commercial Operations · Rulemaking & Enforcement
Regulations Cited
- 14 CFR Part 13
- 14 CFR Part 91
- 14 CFR 135.168
Unreadable text from the scan (such as a barcode or stamp) is left out of the text below; the original letter shows it exactly.
Page 1
U.S. Departm ent
of Transportation
Federal Aviation
Administration
APR 17 2017
Julian Wheeler
HeliFlite Shares LLC
15 Brewster Road
Newark, New Jersey 07114
Dear Mr. Wheeler:
Office of the Chief Counsel 800 Independence Ave.; S.W.
Washington, D.C . 20591
This is in response to your January 9, 2017 letter asking whether the FAA intended 14 C.F.R. § 135.168(b)(l) to apply to multiengine helicopters or single engine helicopters. In your letter, you acknowledge the regulation does not distinguish specifically between the two types of helicopters.
Section 135.168(b)(1) prohibits operation of a rotorcraft beyond autorotational distance from the shoreline unless the rotorcraft carries an approved life preserver equipped with an approved survivor locator light for each occupant. Further, except for patients transported during a helicopter air ambulance operation who cannot wear the life preserver due to medical reasons, the rule requires each occupant to wear the life preserver while the rotorcra:ft is beyond autorotational distance from the shoreline. When the FAA issued its Helicopter Air Ambulance, Commercial Helicopter, and Part 91 Helicopter Operations final rule in 2014, the agency finalized the requirement that the life preserver be equipped with an approved survivor locator light. The final rule does not distinguish between multiengine and single engine helicopters for purposes of the life preserver requirement. The absence of such a distinction in § 135.168(b) signifies the agency intends the requirement to apply to all rotorcraft. We appreciate your patience and trust that the above responds to your inquiry. If you need further assistance, please contact my staff at (202) 267-3073. This letter has been prepared by Katie Inman, Operations Law Branch, Office of the Chief Counsel and coordinated with the Air Transportation Division of the Flight Standards Service.
Sincerely,
Lorelei Peter
Assistant Chief Counsel for Regulations, AGC-200
Page 2
HELIFLITE '"'
Dear Mr Govan,
HeliFlite Shares LLC
15 Brewster Road
Newark Intl Airport
Newark NJ 07114
1/9/2017
I am writing to you in the hope of clarifying the intent of FAR Part 135.168, which will become effective from April 24th 2017.
My question relates specifically to 135.168(b)(1) which states, ''The life preserver must be worn by each occupant while the rotorcraft is beyond autorotational distance from the shoreline". Although it does not state specifically, is this rule intended for "multi engine helicopters" or was the intent to safeguard "single engine helicopter" operations beyond autorotational distance from the nearest shoreline .
. "
Your clarification of the above rule would be much appreciated.
Sincerely
Julian Wheeler
Director of Operations
HeliFlite Shares LLC
jwheeler@heliflite.com
I ;
15 Brewster Road North. Newark, New Jersey 07114
Regulations Referenced
Snapshot retrieved August 6, 2026.