Rethinking Charter: The Case for a “Part 135 Lite”
A System Drifting from Its Mission
The Federal Aviation Administration was created with a clear dual mandate: to “provide the safest, most efficient aerospace system in the world” and to “regulate civil aviation to promote safety and encourage and foster the growth of air commerce.”
Safety and growth were meant to be inseparable. Yet, over time, the agency has become more a bureaucratic gatekeeper than a facilitator. Nowhere is this drift more evident than in the rules governing on-demand charter under Part 135.
Designed in the 1970s to regulate air taxis and small commuter airlines, Part 135 once offered flexibility for operators who didn’t fit neatly into the airline model. But decades of regulatory layering have hardened it into something that actively prevents innovation at the smallest end of aviation—the very segment best suited to reconnect rural America, expand cargo access, and give young pilots meaningful real-world experience.
Part 91 vs. Part 135: The Line Between Private and Commercial
To understand why reform is needed, it’s important to see how the FAA divides the world.
Part 91 governs private flying. Here, the pilot in command has full authority over the flight. A commercial pilot with 250 hours can carry friends, family, or business associates, and passengers can even share direct expenses like fuel and airport fees. What they cannot do is profit or hold themselves out as a charter service.
Part 135, by contrast, governs on-demand commercial operations. The moment passengers pay for transportation, the flight shifts into a regime designed for air carriers. That shift triggers higher pilot experience requirements, formal FAA-approved training and checking programs, duty and rest limits, and far stricter maintenance oversight. Even if the aircraft is a Cessna 182 or Piper Cherokee, the standards applied mirror those designed for turbine aircraft and commuter airlines.
The result is a sharp and sometimes illogical divide: the same pilot, flying the same aircraft, can be legal under Part 91 one day and disqualified the next simply because passengers exchanged money for the service.
Pilot Requirements: A Barrier for the Next Generation
Under Part 91, a 250-hour commercial pilot can carry passengers legally. Under Part 135, however, that same pilot suddenly needs substantially more time, recurrent training, and check airman sign-offs—requirements written with jets and turboprops in mind.
This creates a bottleneck. Most new pilots end up instructing to build time, often in highly repetitive environments. What they don’t gain is real-world commercial experience: flying cargo on tight deadlines, making weather decisions, or managing customer expectations. A streamlined charter model would give them that experience while still holding them accountable to professional standards.
Maintenance: Scaled for Airlines, Applied to Cessnas
Maintenance under Part 91 is straightforward: comply with the manufacturer’s instructions, complete annual and 100-hour inspections, and keep the logbooks current. It’s the same system that keeps tens of thousands of safe piston aircraft flying every day.
Part 135, however, imposes airline-style standards across the board. Continuous airworthiness programs, additional sign-off requirements, and heavy recordkeeping often drive compliance costs beyond the value of the aircraft itself. These rules make sense for a Gulfstream flying coast-to-coast, but they strangle the economics of a Cessna running a short rural hop.
Operational Control: Simplicity vs. Bureaucracy
In Part 91, the pilot in command is fully responsible. They decide if the flight goes, and they bear the consequences of that decision.
In Part 135, operational control is distributed across a formal management structure. Chief pilots, directors of operations, and FAA-approved manuals all come into play. Dispatch or flight-locating procedures are required even for single-aircraft operators. Again, these requirements work for larger fleets—but for a one-airplane charter company in rural America, they amount to bureaucracy for bureaucracy’s sake.
Oversight and Delay
Part 91 oversight is minimal—occasional ramp checks, annual inspections, or inquiries after incidents.
Part 135 oversight begins with certification, a process that can take years. Each operator is assigned inspectors—operations, maintenance, avionics—who must approve every revision of a manual, every training change, every procedural update. Intended to ensure safety, the system often functions as an administrative chokehold. Many operators simply give up before ever flying a paying passenger.
What We Lose Under the Current System
The consequences of this regulatory mismatch are real.
A Path Forward: 135 Lite
A tailored charter framework could unlock these opportunities while preserving safety. It might include:
This is not deregulation. It is right-sizing regulation—restoring balance between safety and commerce, as Congress intended when it created the FAA.
Returning to the FAA’s Charter
The FAA’s statutory role is clear: ensure safety while fostering the development of civil aeronautics. In practice, however, the agency has become a roadblock to the very innovation that could expand air service, strengthen rural economies, and produce better pilots.
A “Part 135 Lite” would not only bring affordable air service back to underserved regions and open new markets for small cargo, it would also give the next generation of pilots the experience they need.
The question is no longer whether such a framework would be useful—it’s whether the FAA will embrace its charter to facilitate safe air commerce, or continue to be its greatest hindrance.