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Legal Interpretations

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D.Person 2000

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Summary

The Question

Must the congested area plan required by 14 CFR 133.33(d)(1) be prepared by a particular officer or a full-time employee of the operator?

Background

Helicopter Lift Services, Inc. asked about the qualifications of the person who prepares the congested area plan required by 14 CFR 133.33(d)(1). An earlier FAA opinion had stated that the plan must be developed by the operator.

The FAA’s Interpretation

No. The regulations do not identify a particular employee or officer who must prepare and submit the plan, and do not require that person to be a full-time employee. The operator may hire a part-time employee to prepare and process the congested area plan, but the operator is responsible for that employee's actions.

Requester
D.Person
Issued
June 28, 2000
Subject
General

Regulations Cited

  • 14 CFR 133.33

Page 1

June 28, 2000
Dennis B. Person
President, Helicopter Lift Services, Inc.
4676 Commercial St. SE, #182
Salem, OR 97302
Dear Mr. Person:

This is in response to your recent letter in which you requested our opinion regarding the qualifications of the person who prepares a congested area plan required by section 133.33(d)(1) of the Regulations. In an earlier opinion, we stated that the plan must be developed by the operator.

The regulations do not identify a particular employee or officer who must prepare and submit the plan for the operator. Nor do the Regulations require that the person who prepares the plan be a full-time employee of the operator. In our opinion, the operator may hire a part-time employee to prepare and process the congested area plan. It must be understood that the operator will be responsible for the actions of that employee. Please feel free to contact me if you require any additional information.

Sincerely,

John J. Callahan

Deputy Regional Counsel

Regulations Referenced

14 CFR 133.33

Snapshot retrieved August 6, 2026.

Summary

The Question

Must the congested area plan required by 14 CFR 133.33(d)(1) be prepared by a particular officer or a full-time employee of the operator?

Background

Helicopter Lift Services, Inc. asked about the qualifications of the person who prepares the congested area plan required by 14 CFR 133.33(d)(1). An earlier FAA opinion had stated that the plan must be developed by the operator.

The FAA’s Interpretation

No. The regulations do not identify a particular employee or officer who must prepare and submit the plan, and do not require that person to be a full-time employee. The operator may hire a part-time employee to prepare and process the congested area plan, but the operator is responsible for that employee's actions.

Requester
D.Person
Issued
June 28, 2000
Subject
General

Regulations Cited

  • 14 CFR 133.33