Legal Interpretations
Harris-Harris & Collins 2014
Summary
The Question
May a parachute jump operator fly jumpers more than 25 miles away for demonstration or exhibition jumps under 14 CFR part 91?
Background
A law firm's client operates a parachute jump facility and occasionally receives requests to fly jumpers more than 25 miles away for demonstration or exhibition jumps.
The FAA’s Interpretation
No. Because the flights go beyond the 25-mile limitation of 14 CFR 119.1(e)(6), the operator must hold an air carrier or commercial operator certificate and conduct them under 14 CFR part 121 or 14 CFR part 135. The FAA has also denied an exemption to an operator seeking to conduct nonstop parachute operations beyond 25 miles of the takeoff airport.
- Requester
- Harris
- Organization
- Harris & Collins
- Issued
- February 7, 2014
- Subjects
- General Operating & Flight Rules · Air Carrier & Commercial Operations
Regulations Cited
- 14 CFR 91.14
- 14 CFR 91.147
- 14 CFR 119.1
- 14 CFR 119.2
- 14 CFR Part 121
- 14 CFR Part 135
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U.S. Department
of Transportotion
Federal Aviation
Administration
FEB - 7 2014
Charles Harris
Harris & Collins
Office of the Chief Counsel
Attorney and Counselors at Law
7777 Alvarado Road, Suite 720
La Mesa, California 91942
Dear Mr. Harris:
800 Independence Ave., S.W.
Washington, D.C. 20591
This letter is in response to your legal interpretation request regarding parachute operations. Your client operates a parachute jump facility and occasionally gets requests to fly the jumpers "some distance away (more than 25 miles)" for demonstration or exhibition jumps and questions whether these operations would fall under 14 CFR part 91 or part 135. Since the flights you describe above go beyond the 25 mile limitation of§ 119.1(e)(6), your client must hold an air carrier or commercial operator certificate and must operate such flights in accordance with either 14 CFR part 121or135.
The FAA has responded to several interpretation requests regarding the exceptions provided in 14 CFR 119. l(e). Specifically, the FAA has reiterated that several of these exceptions restrict operations to a 25 mile radius limitation. See Legal Interpretation to Ray Bonilla from Rebecca B. MacPherson, Assistant Chief Counsel for Regulations (Sept. 7, 2011) (cautioning that "commercial air tours operated under § 91.147 are limited to operations within a 25 mile radius of the take-offlocation ... "). 1
Additionally, the FAA has denied an application for an exemption from § 119(e)(6) from an operator that wished to conduct nonstop intentional parachute operations outside the 25 mile radius of the airport of takeoff. The FAA detennined that the petitioner did not demonstrate an equivalent level of safety that the exemption would not be in the public interest. A copy of the legal interpretations and exemption are attached. 2
1 See also Legal lnterpretation to Victor Anderson from Donald Byrne, Assistant Chief Counsel for Regulations (June 26, 1997) (stating that "non-stop sightseeing flights which began and ended at the same airport and were conducted within a 25 mile radius of the airport... would qualify for the exception under Section 119.2(eX2)").
2 FAA legal interpretations may be found at
http://www.faa.gov/about/office org/headguarters offices/age/pol adjudication/agc20-0/Jnterpretations/.
Additionally, you may search the FAA exemption database at
rgl. faa.gov/Regulatory_and_ Guidance_ Library/rgEX.nsf/MainFrame?OpenFrameSet.
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If your potential operations differ substantially from the ones described in the following interpretations and exemption, you may submit another request for a legal interpretation.
International Law, Legislation, and Regulations
enclosures
Regulations Referenced
Snapshot retrieved August 6, 2026.