Legal Interpretations
Jensen-AirCenterHelicopters 2006
Summary
The Question
Does a multiengine helicopter that meets 14 CFR 135.183(c) also need helicopter flotation devices under 14 CFR 135.183(d) to carry passengers over water?
Background
Air Center Helicopters, Inc. asked about 14 CFR 135.183, which bars operating a land aircraft carrying passengers over water unless one of four listed conditions is met, including multiengine climb performance or helicopter flotation devices.
The FAA’s Interpretation
No. A multiengine helicopter that meets the minimum performance in 14 CFR 135.183(c), climbing at least 50 feet a minute at 1,000 feet above the surface with the critical engine inoperative, fulfills the rule. It does not also have to be equipped with helicopter flotation devices under 14 CFR 135.183(d).
- Requester
- Jensen
- Organization
- AirCenterHelicopters
- Issued
- October 19, 2006
- Subject
- Air Carrier & Commercial Operations
Regulations Cited
Page 1
U.S. Department
of Transportation
Federal Aviation
Administration
James L. Jensen, Director Flight Operations
Air Center Helicopters, Inc.
150 Aviation Way, Hangar 17N
Fort Worth, Texas 76106-2757
RE: Interpretation of 14 CFR 135.183(c) and (d)
Dear Mr. Jensen:
This responds to your October 19, 2006, letter in which you ask " ... does a multiengine helicopter that complies with paragraph (c) not then have to comply with paragraph (d)?" The rnle at issue is:
PART 135--0PERATING REQUIREMENTS: COMMUTER AND ON DEMAND
OPERATIONS AND RULES GOVERNING PERSONS ON BOARD SUCH AIRCRAFT
Subpaii C--Aircraft and Equipment
Sec. 135.183 Perfonnance requirements: Land aircraft operated over water. No person may operate a land aircraft cany ing passengers over water unless-- (a) It is operated at an altitude that allows it to reach land in the case of engine failure;
(b) It is necessaiy for takeoff or landing;
(c) It is a multiengine aircraft operated at a weight that will allow it to climb, with the critical engine inoperative, at least 50 feet a minute, at an altitude of 1,000 feet above the surface; or (d) It is a helicopter equipped with helicopter flotation devices. CmTently, if an operator uses a multiengine helicopter having the minimum performance chai·acteristics stated in section 135.183(c) above it fulfills the requirements of the rnle. The multiengine helicopter does not also have to be equipped with "helicopter flotation devices" as stated in section (d) .
Page 2
This response was prepared by Bruce Glendening, Attorney in the Regulations Division of the Office of the Chief Counsel and has been coordinated with the Air Transportation Division of Flight Standards Service. If you have additional questions regarding this matter, please contact us at your convenience at (202) 267-3073.
Sincerely,
Rebecca MacPherson
Asst. Chief Counsel, Regulations Division (AGC-200)
Regulations Referenced
Snapshot retrieved August 6, 2026.