Getting a Part 135 Certificate

Don’t expect help from me.

Last night, I received yet another e-mail from a helicopter operator with questions about getting a Part 135 certificate. I thought that it was about time for me to explain why people who e-mail me for help about this won’t get it.

But first, a bit of an explanation of what a Part 135 Certificate is.

What Is a Part 135 Certificate?

A Part 135 certificate is literally a piece of paper issued by the FAA that permits a commercial aircraft operator to perform air-taxi operations. The phrase air-taxi refers to the mission of picking up a passenger at Point A and transport him to Point B. A Part 135 Certificate also permits an operator to conduct aerial tours beyond the 25 statute mile limitation set by Part 91 or the relatively new Part 136. Part 135 gets its name from the Federal Aviation Regulations (FARs) Part 135, but a Part 135 operator must also comply with all other applicable FARs, including Parts 61, 91, and 119.

Zero Mike Lima at Monument Valley

Zero-Mike-Lima at Monument Valley during one of my multi-day excursions.

A Part 135 certificate is worth more than its weight in gold for an operator that has one and can use it properly. For example, if I didn’t have one, I’d be limiting my operations to short tours within 25 miles of my starting point and aerial photo/survey flights. With a Part 135, however, I can also take my tours as far as I like, transport passengers between two points, and even offer day trips and multi-day excursions. In the highly competitive area I live in — Arizona is just swarming with helicopter operators — a Part 135 Certificate gives me the competitive edge I need to stay in business. (With less local competition, I might even become profitable. Wouldn’t that be special?)

There are three types of Part 135 certificates: Single Pilot, Single Pilot in Command, and Basic. I have a single Pilot Part 135 certificate. That means that under my company’s certificate, only one pilot is allowed to fly the aircraft under Part 135: me. (Hint to jobseekers: that’s one reason why I don’t ever hire other pilots.) A Single Pilot in Command certificate is similar, but is used mostly in organizations with aircraft that require more than one pilot; just one of those pilots is allowed to fly as pilot in command, but any other pilot can be second in command. The Basic Part 135 certificate — and I may have its name wrong — allows multiple pilots to act as pilot in command on multiple aircraft. The Grand Canyon tour operator I worked for had a Basic Part 135.

At a recent meeting at my local Flight Standards District Office (FSDO; pronounced fizz-doe), I learned that there are only 4,800 Part 135 certificates in the entire country. If you take a moment to consider what percentage of those could possibly be helicopter operators, you’ll realize that I’m part of a very small club.

The penalty for conducting a Part 135 operation without a Part 135 certificate? Well, I know of at least one pilot who had his license permanently suspended. Ouch. When you consider the amount of time and money a commercial pilot — especially a helicopter pilot — might have invested in a career, that’s a very costly penalty.

Airline operations, by the way, are Part 121, which has tighter regulations.

How to Get a Part 135 Certificate

You work with your local FSDO to get a Part 135 Certificate. It requires multiple meetings at the FSDO to work your way through a flow chart of activities. Although I’ve heard of people getting their Single Pilot Part 135 as quickly as three months — it took me four months — it takes other people years. In fact, more than a few operators have gone out of business while working through the process.

There’s a lot of paperwork. The biggest challenge to most people is the creation of a Statement of Compliance. That’s where you list all the applicable FARs and state exactly how you will comply. My Statement of Compliance was 54 pages long. It wasn’t difficult for me to create because, after all, I am a writer. But I’d say that 90% of the people who try to get their Part 135 certificate stumble on this component, which occurs about halfway through that flow chart.

You’ll also need to get on a drug testing program, create a training manual for carrying (or not carrying) HazMat, and obtain a secure location for basing your aircraft. You’ll need to create forms for pilots to log time flown, aircraft flight time, and squawks. You’ll need to have perfect maintenance records. If you’re going for a Basic Part 135, you’ll need all kinds of other manuals and documents, as well as staff in predetermined positions, such as Director of Operations, Director of Maintenance, etc.

The FAA did not make the process easy. If it were easy, everyone would have a Part 135. Instead, they made it a challenge.

I am extremely fortunate to be working with an excellent FSDO full of people who are reasonable and helpful. Yes, I’m required to jump through the same hoops as everyone else, but my contacts at the local FSDO help me make those jumps. In turn, I comply with their requests promptly, without question. After all, their mission is to keep me safe. Why wouldn’t I want to be safe?

Why I Won’t Help You Get Your Part 135 Certificate

I’ve already given you several hints on why I won’t help you get your Part 135 Certificate. Did you read between the lines to get the answer? If not, I’ll spell it out for you.

  • Rise to the challenge. I personally believe that the FAA makes it challenging to get a Part 135 Certificate as a test to see if applicants are worthy. Let’s face it: the FSDO folks spell out what you need to do — using a flowchart, for Pete’s sake! If you come into the application process with the right attitude, they’ll help you achieve your goal. But they won’t just give you a certificate for showing up. You have to earn it. By jumping through all the hoops and smiling the whole time, you’ll prove that you have the right stuff to be a safe and cooperative aircraft operator. If I help you get your certificate, you won’t prove anything other than that you can’t do it alone.
  • Membership has its privileges. That old American Express slogan can easily be applied to the 4,800-member club of Part 135 certificate holders. We can do things that Part 91 operators can’t. This gives us far more flexibility in our operations. I can’t tell you what a joy it was to finally be able to say yes to a client request for an air-taxi flight. Saying yes means more business, more revenue.

I get e-mails and calls at least twice a month from helicopter operators hoping I’ll help them get their Part 135 certificate or make their business grow. Apparently, it isn’t enough for me to write about my own experiences here so they can use them as learning tools. Instead, they want me to take them by the hand and walk them through the process.

Why should I? What’s in it for me?

I did the hard work I needed to do to get my certificate and build my business. Why would I want to make it easier for potential competition? Isn’t it in my best interest to have other operators jump through the same hoops I did and prove they’re worthy of getting a Part 135 certificate? Wouldn’t I rather be sharing the skies with pilots who passed muster with the FAA? Wouldn’t I rather refer overflow business to an operator I know has the ability to do his own homework?

You want a Part 135 certificate? Take my advice: Call your local FSDO and set up a meeting to get started. Then put a smile on your face, roll up your sleeves, and get to work.

29 thoughts on “Getting a Part 135 Certificate

  1. Ahh, sounds a lot simpler than getting an Air Operators Certificate (AOC) from our friendly CAA in the UK – a process which will undoubtedly become more complicated when full responsibility is transferred to EASA in due course.

    Setting aside the competition issue, have you considered offering consultancy on Part 135 applications (maybe only out of your state)? Certainly in Europe there are people making good money out of AOC consultancy.

  2. I have considered doing Part 135 consulting. But in reality, I believe that people should do their own work to get their Part 135 certificate. It really is a test and I want other operators to pass it on their own.

    • Maria,
      Enjoyed your comments & agree wholeheartedly. I’m at the other end of the cycle…….flew all my life and got my Part 135 cert in 2002 (www.palmerairtaxi.com). My insurer tells me that they will probably stop insuring me for commercial ops at age 72……nothing personal, just business, etc. that’s 5 years from now so I’m thinking about selling my business (i. e. certificate) in the near future. I haven’t a clue how to value it or where to look for buyers……. Any thoughts? FYI, if I use the 5x earnings method, it would say the biz ( charter & customer list) is worth $425K or so. I don’t know many guys / gals with that kind of money to lay out for a start-up air taxi!

      Dave Palmer
      Info@palmerairtaxi.com
      817-229-7258

      • This happened to a friend of mine. He owned and flew the first turbine conversion Sikorsky S55 — in fact, he was the test pilot for the conversion! Great pilot, did all kinds of utility and long-line work. I can still remember him climbing up the side of that helicopter in flip-flops and crawling through the window into the cockpit at age 72.

        But that’s the same year his insurance company pulled the plug on his insurance. He held onto a helicopter he couldn’t fly for about a year before finally selling it. Not sure what he’s doing now. Too sad.

        Best of luck on the sale of your business. I doubt you’ll get that much for your certificate — hell, they aren’t that hard to get — but someone with deep pockets who doesn’t want to deal with the FAA for certification might make you a good offer. Let us know how you do.

  3. Surfing the net lead me to your article above. I am a business broker/Investment Banker. Currently I have been assigned the task of selling a well established Helicopter Tour Company in the sate of Hawaii. This industry is somewhat new to me, and so I have been educating myself intensively so that I am able to understand the business, the industry, the aircraft, Full part 135, and be able at the same to valuate such business. I now have come to understand that the value of the assets, namely the aircraft, far exceeds the application of this multiple of that multiple to the cash flow. Additionally, the cost of maintenance, and the related insurance costs, and the difficulty in obtaining adequate purchase financing make the sale of a Helicopter Tour Company very challenging and very difficult indeed.

    I am wondering if possible, you could offer some comments/opinion about the business valuation of this business, or perhaps you could refer me to some previous sales.

    I do know that all of this depends on the location, the type of aircraft and how many.

    I appreciate your input and cooperation at all times.

    Regards,

    Jacques A. Bouzoubaa

  4. I had a meeting today with FAA. I am a stones throw away from being annointed. It was a pain. It is revisions on top of revisions on top of meeting on top of meeting……..
    Its finally at an end. FAA in my state was a really big help. I had the hoops to go through…but in the end it really makes you self sufficient. You find that this helps to make future revisions that you have to do all the time. You become the watch dog for your own 135. couple years though…..couple years.

    • Congratulations, Matthew!

      I really believe the whole process is a test to see if we’re “worthy.” Someone who is smart and capable and wants it badly enough will work hard to get it. Afterwards, things are much easier, especially if you’re single pilot (as I am) and don’t have to deal with multiple pilots, aircraft, training, etc.

      Someone who isn’t willing to put in the effort simply doesn’t deserve to get the rewards of having the certificate. Someone with an attitude that says “the FAA is a pain in the ass” isn’t the kind of pilot I want to be sharing the skies with.

      I think you’ll find that having a Part 135 will give your company the competitive advantage it needs to succeed and grow. Best of luck to you!

  5. Well I came across your writing as I was looking around for info on certain aspects of my 135 certificate and the process of upgrading it from single pilot to basic 135. I found it a bit deflating that you are so against helping your fellow aviators in an area that you and I both know is unfamiliar waters for almost everybody who is not already operating under 135 and many that are. It seems to me you are just writing a promotion for the FAA. Why you just did not refer everyone to the FSIMS like most of our friends down at the FAA. The main problem here, as you are aware of, is half of the guys in the “fizdoes” have no clue either so they keep piling on the paper work and returning documents because they have some new regulation or forgot to mention this or that….”Part 43 required or not, Part 119.1 oh it changed but its not in the system yet” are just two of the roadblocks I have heard lately and those are just a few of the hangups. If you are a smaller operator and need to fly for a living, sitting behind a desk “writing” and preparing tons of manuals etc. would cause you to go go bankrupt. Oh by the way, ask around to see the price of having someone or a company do it for you…..My point is don’t make it sound so simple and easy because there is a lot more to it than just sitting down and writing out some compliance statement or MEL or any other manual. My area FSDO is obviously not as yours as I can name several operators that have been log jammed for more than three years doing the 135 process….Is that fair? That alone is good enough for each of us to help one another with any process involving the FAA. Maybe you are one of the operators that think if you help someone else you will loose business and you are entitled to your beliefs and operating customs or maybe you sincerely believe that by not assisting anyone they will figure it out on there own and be the better for it. (they will just ask someone who is willing) Lastly the FAA is not keeping you safe…you are keeping you safe by maintaining high standards of operations and training to ensure good judgement calls by you and your pilots. The FAA’s number one mission is surveillance not certification. Hope you take no offense just the other side of the coin …guidance is a good thing!!

    Greg Bettis

    • I can only assume that I’m lucky to have a good FSDO and great POI. My friend Jim, who has a business virtually identical to mine, was at odds with the FAA for a long time — until he finally (just recently) got a “good” POI. Now his whole opinion has changed. Maybe it’s the people.

      Maybe I made it sound simple and easy because it was that way for me. I showed up for my first meeting fully prepared. I even had my Statement of Compliance done — that was something halfway through their flowchart. To this day, I can remember the three guys I initially met with and how surprised they were when I pulled out document after document at that meeting. I made their job easy. Maybe that’s the problem with other folks.

      As for being log-jammed, when the ball is in the FAA’s court, you need to remind the FSDO person who is handling the approval process. A polite phone call first, then a letter. I can’t recall them ever holding any part of my process up for more than two weeks. I do recall reminding them that I was waiting for various things. You have to be proactive throughout. You can’t whine, you can’t complain, you can’t refuse to do something that’s required, you can’t take shortcuts, you can’t be a pain in the ass.

      Competition is only a small part of the reason I won’t help others. (Where I am based in AZ, I have far more competition than any business should have to deal with; what’s one more?) I stated very clearly what the other reason was. Do I really want to share the airspace with pilots incapable of meeting the Part 135 requirements on their own? If the FAA is holding them back, they might be doing so for a reason. I did my part — I earned the privileges of a Part 135 operator. Why shouldn’t everyone else?

      And I have to disagree with what you said about the FAA keeping me safe. They are keeping me safe. They’re keeping me safe by controlling the operations of others who can’t meet their requirements for certain operations. And they are forcing operators like me to keep high standards. Do you honestly think every operator would deal with all the paperwork and other FAA/DOT requirements if they didn’t have to? If there wasn’t a POI and FSDO looking over their shoulder? Drug program auditors waiting in the wings to review their paperwork? PMI showing up at their hangar door unannounced to look at their logbooks? The threat of losing a Part 135 certificate for breaking any rule?

      Do you know how much time and money I have invested in my business? Do you realize what I would lose if the FAA decided that I wasn’t worthy of being a Part 135 operator? Or if they pulled my pilot certificate for doing something dumb? Don’t you think that’s in the back of my mind every time I get a call from a potential client and begin planning a Part 135 flight? And stays on my mind until the flight is done and helicopter is tucked back in the hangar? Don’t you think it’s the risk of FAA action that prevents me from landing in a dumb place just to make a client happy? Or flying where I shouldn’t?

      No, my blog post wasn’t a promotion for the FAA. It was a recounting of my experiences. I won’t apologize for having an easier time of it than other people. I made it as easy as I could. There’s nothing really stopping others from doing the same.

  6. Very interesting topic, before I enquire through official channels does anyone know if it is possible to get a part 135 cert if you are not based in
    the USA for example Europe.

    I have come across a few part 135 OPS for sale usually with one piston multi engine aircraft where the owner is retiring? Just wondered if such a business is transportable outside of the state in which it was authorised.

    • It’s always best to go through “official channels” when you want accurate information. Call the closest FAA FSDO and ask. They’ll set you straight on all your questions.

  7. This is question has been on mind for some time, but have not been able to answer although I have contacted the local FSDO and could not get them to give me a clear answer. Also, I asked the following: How could a foreign Buyer be able to purchase a US aviation company operating with Full Part 135, and again no one seems to know the answer for sure. Can anyone?

    • The US DOT requires air carriers to be owned and managed by US citizens. For a corporation this usually means that 2/3 of the board must be US citizens and 75% of the voting interest must be owned by US citizens.

      • Thank you very much. I appeciate the reply. I have a japanese national who is interested in Buying an US Part 135 operation in the state of Hawaii…Could you elaborate more on your posted comment. Thank you. Thank you again.

  8. I am a fairly new commercial rotorcraft pilot located in WV. I am thinking about starting a helicopter business in my area but have not starred the process yet. I was wondering if anyone new if you had to currently be in business to start the part 135 process, as I am not yet.

    • I’m pretty sure you do need to have some kind of business set up. There’s some sort of financial stability requirement that’s best proved by having existing financial records. My company had been in business for three years as a Part 91 operator when I started the process.

      Your best bet is to talk to the local FSDO. They can advise you better than I can.

  9. Maria,

    I thank you for being up front on your choice to allow other to do their own research and find the answers they a looking for. I have only one question related to the 135 process. After you pass the documentation phase how does the POI appoint a Check Airman if you use a small aircraft that may not be used in a 135 operation already?
    Out of FSIMS Document
    Volume 2 Chapter 4 Section 6 2-460 B. 1
    “Single pilot” operators may be granted approval to use a check airman who meets all the requirements of part 135 to serve as a check airman and is presently employed by another air carrier who is using the same type of aircraft. These operators shall be limited to one check airman approval at any one time.

    Lastly, Did you get a sightseeing certificate before you got your Single Pilot 135 certificate, and if you did would you recommend that over a Single Pilot 135 if all someone wants to do is give sightseeing flights/air tours.

    Thank you for any advice that you may give.

    • Not sure why you’re asking me when your local FSDO could provide better answers. I went through this process nearly 8 years ago. Things have changed. For example, back then there was no “sightseeing certificate.” (I assume you mean flights conducted under Part 136.)

      My check airman has always been my FAA POI or someone he assigned to do the flight. I think this is the best solution. Not only do I save money — I’m not charged a fee for the flight — but my POI stays connected to me and my operation and has confidence that I know what I’m doing and am not taking shortcuts. That helps me build a solid relationship with the FAA.

      I recommend a Part 135 certificate for ANY commercial aircraft operator interested in making money with an aircraft. Having a Part 135 gives you the ability to say YES to nearly every request you get. Why would you want to limit yourself to sightseeing flights? I don’t know about where you live, but if I had to rely on sightseeing flights to remain profitable, my business would have gone under years ago. Tourists are cheapskates, tourism is seasonal, tourism relies on a strong economy — which we just don’t have these days. Unless you have a monopoly in an extremely scenic area that attracts tourists, building an aviation business on tourism will be tough — especially with just one pilot and aircraft.

      Go to your FSDO and talk to the folks there. They can help you — and get you started at the same time. Good luck!

      • I only ask about the check ride part seeing you have first hand knowledge. I will be honest I have many years before I am ready to even start a business. I have started doing the research now so when I am ready there are no surprises. I also thank you for your up front answer. I have a very stable job right now and was tossing around the idea of doing sightseeing on the weekends for some side money. I live in an area where the majority of the customers would be locals and not as much of the tourist variety. I only started looking at 135 while doing the research into sightseeing tours. Once again thank you for your time and advice. I just wanted to throw my questions at you for I like you would some day like to do a job I am happy to go to each day.

        • Well, if you do decide to go for a Part 135, don’t wait. It took me 4 months, which is VERY fast. The average person takes over a year to get it done. Good luck, whatever you decide.

          • Maria,

            Thank You again for your words of advice and hopefully I will be able to figure something out in the next couple of years.
            Enjoy the flying and the many beautiful sights.

  10. Not sure if anyone out there might be able to assist me, but I am currently looking for a new Director of Training for one of the large helicopter operators (part 135) and have specific instructions to stay away from EMS, the gulf coast companies and Canada. That being said, this is a large training department, 800 pilots, 800 maintenance professionals. Any suggetstions, or networking contacts would be a HUGE favor.
    Thanks,

    Jason

  11. So much misinformation it scares me!

    First, the FAA doesn’t make anyone safe. All those regs are based how many people you can kill at a time and are written in blood. Try as they may to regulate us to safety, there is no substitute for competent professionals.

    Second, the 135 process is extremely slow for most people for many reasons. Meeting with the FAA fully prepared and knowledgable is a prerequisite! They are not there to guide you through the process, they are there to supervise experienced professionals doing a job. Everything you need is available at FAA.gov including guidance material for the inspectors!!! Forget the flow chart, you have THEIR checklists at your disposal!!! How much easier can they make it? Yet, there are those gov employees that give rise to “at the FAA we’re not happy ’till you’re not happy.”

    As for types of certificates, it’s almost infinite. Generally, you have single pilot, basic, and scheduled. The single pilot lets 1 PIC operate on-demand. The basic brings in required positions of part 119 and allows many PICs to operate on-demand. The scheduled brings in more DOT paperwork, not just FAA, and allows you to bid on EAS contracts and such as well as, obviously, flying a posted schedule and selling seat fares instead of charters. What you have approved in your Ops Manual and Ops Specs doesn’t necessarily fit in any of the above, hence infinite variations. Whatever you get approved in the documents becomes, in effect, law for your operation. You may find through the years, as I have, there are manuals that allow operators to do things that would otherwise be illegal not only under 135, but 91/61 as well! Still, that rubber stamp means it’s all yours.

    Don’t worry about check airmen. If you have to ask, you won’t have one. Your POI will do your rides until you have so many pilots it becomes a burden for him/her. Then they start giving you check airmen authority. Scheduled operators see it first because, not only do they do currency rides, they have to do Operating Experience (OE, used to be IOE for initial) for many hours on new pilots as well as upgrades. Initial and recurrent rides use a lot less time and for those, if needed, check airman authority will be limited to the chief pilot, training manager, trainging department, etc. Check Airman may only use their authority within the company. There are exceptions, generally with training providers, where a company writes into their training manual that certain training will be conducted by a contractor. Flight Safety, SimCom, etc may have their instructors approved as check airmen for your company, but that is not the norm. Think of them as DPEs, if you have to ask how to become one, you won’t.

    Lastly, two suggestions for anyone with the gumption for such an endeavor. It’s an endurance race, keep your head down and don’t look at the mountain ahead of you. Do your research, make an outline, and start filling in the blanks. You WILL get there if you don’t waste time counting the steps. When you’re actually writing, remember less is more. Keep it as simple as possible. KISS is a phrase they, the FAA, are familiar with. If your inspector sees a maze as long and complex as the one before you, they WILL procrastinate and you WON’T make progress. Your inspectors will also come to you with the latest and greatest and ask you to include this and that. Ignore them. If you did your research you have it right. The inspectors get new directives all the time about somebody’s pet project that’s fashionable for a week, a year… Who cares? They don’t, they’re doing what they’re told and regurgitating what they need to without thought. This, unfortunately, is the way of our government.

    • Oh, Tom! So sorry to scare you! Are you recovered now?

      Thanks for being so highly critical of a blog post I wrote 2-1/2 YEARS ago based on experiences I went through 8 YEARS ago. Times have indeed changed. Much more information is available on the Web. Aren’t we all so lucky that you came along to correct what I’d written?

      I am in awe of your superior knowledge and generosity for sharing it with us.

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