Legal Interpretations
Jensen-AirCenterHelicopters 2006
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U.S. Department of Transportation Federal Aviation Administration James L. Jensen, Director Flight Operations Air Center Helicopters, Inc.
150 Aviation Way, Hangar 17N Fo1i 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 multi.engine 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. 13 5 .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 multi.engine 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 multi.engine helicopter having the minimum performance chai·acteristics stated in section 135 .183(c) above it fulfills the requirements of the rnle. The multi.engine helicopter does not also have to be equipped with "helicopter flotation devices" as stated in section (d) .
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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)
Retrieved from ecfr.gov on July 18, 2026.