Legal Interpretations
Bernstein-AirCargo 2009
Summary
The Question
Does 14 CFR 135.63(d) require a Part 135 operator to do anything specific with the duplicate load manifest, such as leave it at the airport before takeoff?
Background
The Regional Air Cargo Carriers Association asked whether 14 CFR 135.63(d) governs handling of the duplicate copy of the load manifest prepared before takeoff under 14 CFR 135.63(c).
The FAA’s Interpretation
No. 14 CFR 135.63(d) requires the pilot in command to carry a copy of the load manifest to its destination and the certificate holder to keep completed manifests for at least 30 days at its principal operations base or another location approved by the Administrator, but it does not specify what to do with the duplicate. The FAA dropped a proposed requirement to mail the duplicate or retain it at the airport.
- Requester
- Bernstein
- Organization
- AirCargo
- Issued
- November 13, 2009
- Subject
- Air Carrier & Commercial Operations
Regulations Cited
Page 1
U.S. Deportment
of Transportation
Federal Aviation
Administration
NOV 1 3 2009
Stanley L. Bernstein
President
Office of the Chief Counsel
Regional Air Cargo Carriers Association
60 Clifford Road
Plymouth, MA 02360
Dear Mr. Bernstein:
800 Independence Ave .. S.W.
Washington, D.C. 20591
This letter is in response to your July 13, 2009 request for legal interpretation of 14 C.F.R. § 135.63(d). You ask ifthat section places any requirements on what must be done with the duplicate copy of the load manifest that is prepared prior to takeoff pursuant to§ 135.63(c), specifically, if you are required to leave the copy behind at the airport before tak.~-off Section 135.63(d) requires the pilot in command to carry a copy of the load manifest in the aircraft to its destination. It also requires a certificate holder to keep copies of completed load manifests at its principal operations base, or at another location approved by the Administrator for at least 30 days. Section 135.63(d) does not specify what is to be done with the duplicate copy of the load manifest.
When the FAA proposed§ 135.63(d), the proposed rule language would have required the pilot in command to arrange for mailing of the duplicate copy of the load manifest to the certificate holder, or for it to be retained at the airport until the flight was completed. See 42 Fed. Reg. 43490, 43515 (Aug. 29, 1977). However, the FAA removed that requirement after considering comments received on the proposed rule. See 43 Fed. Reg. 46742, 46764 (Oct. IO, 1978); Legal Interpretation to Nettie Dickerson, from Edward P. Faberman, Acting Assistant Chief Counsel (Nov. 5, 1980).
Nevertheless, although§ 135.63(d) does not specify how the duplicate copy of the load manifest should be handled, the FAA advises certificate holders to incorporate procedures in their operations' manuals for the disposition of the duplicate copy. See Legal Interpretation to Nettie Dickerson (Nov. 5, 1980). The certificate holder should work with its principal operations inspector to develop such procedures. In the event of an accident in which the load manifest carried on-board the aircraft is destroyed, the duplicate copy of the load manifest could provide valuable information to investigators regarding passengers, crewmembers, and aircraft weight and balance.
Page 2
This response was prepared by Dean Griffith, Attorney in the Regulations Division of the Office of the Chief Counsel, and was coordinated with the Air Transportation Division of Flight Standards Service. Please contact us at (202) 267-3073 if we can be of further assistance.
Sincerely,
fr.1h:s:!J-Assistant Chief Counsel for Regulations, AGC-200
Regulations Referenced
Snapshot retrieved August 6, 2026.