Legal Interpretations
Trock-PillsburyWinthropShaw 2007
Summary
The Question
May airships conduct sightseeing and other operations for hire under 14 CFR part 91 without a 14 CFR part 119 certificate?
Background
Pillsbury Winthrop Shaw Pittman LLP asked the FAA to confirm that because the 14 CFR part 119 definitions of commuter and on-demand operations cover only airplanes and rotorcraft, airships may operate for hire under 14 CFR part 91.
The FAA’s Interpretation
Yes. The FAA confirmed that 14 CFR part 135 applies only to commuter or on-demand operations of operators required to hold a 14 CFR part 119 certificate, and those definitions apply only to airplanes and rotorcraft as defined in 14 CFR 1.1. Airships therefore may conduct sightseeing and other operations for hire under 14 CFR part 91, provided they comply with its requirements.
- Requester
- Trock
- Organization
- PillsburyWinthropShaw
- Issued
- September 28, 2007
- Subjects
- General Operating & Flight Rules · Air Carrier & Commercial Operations · Definitions
Page 1
U.S. Department
of Transportation
Federal Aviation
Administration
SEP 2 8 2IJ07
Jennifer Trock, Esquire
Pillsbury Winthrop Shaw Pittman LLP
2300 N Street, NW
Washington, DC 20037-1122
RE: Airship Operations
Dear Ms. Trock:
In an email communication dated August 17, 2007, you requested the FAA to confirm your understanding as follows:
"Airships are not subject to the requirements of Part 119, 121, 135, or 136, but instead may operate under the rules of Part 91, including sightseeing and other operations for hire, provided they comply with Part 91 requirements (especially now that the prior exception in 119 was recently eliminated and the new air tour rule excludes airships). Because (1) Part 135 applies only to "commuter or "on-demand operations" of operators required to hold a certificate under Part 119; and (2) the Part 119 definitions of "commuter" and "on-demand operations" apply only to "airplanes" (defined in section 1.1 as "an engine-driven fixedwing aircraft heavier than air ... ") and "rotorcraft" (defined in section 1.1 as "a heavierthan-air aircraft that depends principally for its support in flight on the lift generated by one or more rotors"), Part 91 would govern airship operations."
The FAA confirms your understanding as appropriate for airship operations. This response was prepared by Bruce Glendening, Attorney in the Regulations Division of the Office of the Chief Counsel. If you have additional questions regarding this matter, please contact us at your convenience at (202) 267-3073.
~/~l/a'Rebecca MacPherson
Assistant Chief Counsel for
Regulations Division"AGC-200
Regulations Referenced
Snapshot retrieved August 6, 2026.