slick1537 Posted July 26, 2009 Posted July 26, 2009 Hey guys I have a commercial question for all of you. I was wondering if any of you do fair rides. My question is what regulation do you operate under? I was looking at 91.147 and Part 136 but you need the LOA for that. I guess I always considered that regulation was geared toward fixed based tour operators and not fair ground operators because of their short times span. If the fair rides do fall under that reg do you need a new LOA for each fair ground you attend? Quote
kodoz Posted July 26, 2009 Posted July 26, 2009 Hey guys I have a commercial question for all of you. I was wondering if any of you do fair rides. My question is what regulation do you operate under? I was looking at 91.147 and Part 136 but you need the LOA for that. I guess I always considered that regulation was geared toward fixed based tour operators and not fair ground operators because of their short times span. If the fair rides do fall under that reg do you need a new LOA for each fair ground you attend? I have a follow-on question: are Part 91 tours a thing of the past for new operators? The 91.147 LOA required under 199.e.2 had to be received by Sept 11, 2007 (~.. So if you want to do tours now, you have to work under 119.e.7 (which limits you to 6 flights in a year), or you have to work under Part 135. Right? Quote
rick1128 Posted July 26, 2009 Posted July 26, 2009 (edited) You have to have an LOA. You do not need to get a new one for each fair. You do have to make changes to your LOA if you make a change in your business address or change aircraft. It appears that the major reasons for the process is to put ride operators under a drug and alcohol testing program. It is a fairly simple process. 1. Find a drug testing program to put yourself under, write a letter to your local FSDO and they may require you to provide additional information. And they send you two copies of the LOA, which you sign and send one back. The Sept 11th date only applied to ride operators that were already in business. You can still request the LOA. Edited July 26, 2009 by rick1128 Quote
BOATFIXERGUY Posted July 26, 2009 Posted July 26, 2009 Did them forever. Yes, you need the 91.147 LOA. No big deal. Basically the FAA wanted to know where all of the ride operators were on any given day and who was in charge before the complaints come in. Quote
slick1537 Posted July 27, 2009 Author Posted July 27, 2009 So you only need one LOA which proves you are under a drug testing program. You don't need a new one if you are doing rides in a different FISDOs jurisdiction? Quote
BOATFIXERGUY Posted July 27, 2009 Posted July 27, 2009 You need one for any different locations than are on your initial LOA. If you take a contract somewhere not listed in your initial letter, you need to get it included. If you have the LOA for doing tours from your airport / heliport and then decide to go to Sturgis, you need to get one saying you'll be at Sturgis from ____________ to _______________. Not really difficult, but the FAA wants to know where and when you'll be operating. The 6 flights a year are for conducting semi - part 135 stuff. You can haul charter with a letter and approval from the FSDO...6 times a year as long as they say ok. Quote
rick1128 Posted July 27, 2009 Posted July 27, 2009 You need one for any different locations than are on your initial LOA. If you take a contract somewhere not listed in your initial letter, you need to get it included. If you have the LOA for doing tours from your airport / heliport and then decide to go to Sturgis, you need to get one saying you'll be at Sturgis from ____________ to _______________. Not really difficult, but the FAA wants to know where and when you'll be operating. The 6 flights a year are for conducting semi - part 135 stuff. You can haul charter with a letter and approval from the FSDO...6 times a year as long as they say ok. I will disagree with you. I know of two ride operators that do rides at various fairs and events with only one LOA. I also hold a ride LOA and there are NO area restrictions. The regulations require you to have an LOA. So you must have the LOA in your possession while conducting rides. There is no requirement to notify your FSDO or the local FSDO of your conducting rides at an event. If you stated in your letter requesting the LOA a specfic area, the FSDO could place a restriction on your LOA. Placing such a limit on your LOA would be like telling a 135 operator that they have to get permission from other FSDO's if they do flights out of their districts. The letter is issued by the "Administrator". If your FSDO is telling you otherwise, then they are telling you wrong. Quote
BOATFIXERGUY Posted July 28, 2009 Posted July 28, 2009 FDSO telling you otherwise is par for the course. How many times is one thing ok for one FSDO, but not another? My FSDO didn't even know what the LOA was, or who issued the drug program numbers. The FSDO that issued my original did want to know if and when I had the birds somewhere else. Quote
rick1128 Posted July 28, 2009 Posted July 28, 2009 FDSO telling you otherwise is par for the course. How many times is one thing ok for one FSDO, but not another? My FSDO didn't even know what the LOA was, or who issued the drug program numbers. The FSDO that issued my original did want to know if and when I had the birds somewhere else. So send them an email the evening before the rides start. Quote
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