Air Tour Operations and Safety Management: A Practical Look at Letters of Authorization

Most people file 14 CFR 91.147 under paperwork: a short application, a letter from the Flight Standards office, and back to flying the loop. The section asks for more than a letter. As written in 14 CFR 91.147, the rule defines an "Operator," sets four general requirements in paragraph (b), lists seven items each Letter of Authorization application includes, and ends with a paragraph headed "Compliance." The Letter of Authorization is the fourth item in paragraph (b). The other three point to part 136, part 120 and part 5.

Who does 91.147 call an "Operator"?

The definition is one long sentence, and every clause in it carries weight. As written in 14 CFR 91.147(a), "Operator means any person conducting nonstop passenger-carrying flights in an airplane, powered-lift, or rotorcraft for compensation or hire in accordance with §§ 119.1(e)(2), 135.1(a)(5), or 121.1(d) of this chapter that begin and end at the same airport and are conducted within a 25-statute mile radius of that airport."

Pull that sentence apart and you get a stack of conditions: nonstop, passengers aboard, compensation or hire, one of three aircraft categories, the same airport at both ends, and a 25-statute-mile radius. The three cross-references into parts 119, 135 and 121 carry much of the detail. Read them in full, side by side, before you lean on the version of the rule that lives in your head.

Whether a particular tour program fits the definition is a conversation for your Flight Standards office. If you want to talk it through alongside what a safety program for those flights would track, book a demo.

What does paragraph (b) list?

Four requirements, introduced by one sentence with an exception built in. As written in 14 CFR 91.147(b), "An Operator conducting passenger-carrying flights for compensation or hire must meet the following requirements unless all flights are conducted under § 91.146. The Operator must:"

The first item is to "Comply with the safety provisions of part 136, subpart A of this chapter." The second is to "Register and implement its drug and alcohol testing programs in accordance with part 120 of this chapter." The third is to "Comply with the applicable requirements of part 5 of this chapter." The fourth is to "Apply for and receive a Letter of Authorization from the responsible Flight Standards office."

Read the verbs. Comply. Register and implement. Comply. Apply for and receive. Three of the four describe programs that keep running long after the paperwork is done. The letter is the part that arrives in an envelope. The rest shows up on a hot Tuesday in August, with the boarding line out the door and the third aircraft back from maintenance.

The exception deserves the same care. As the post describes it, the exception sits in a separate section of Part 91, 14 CFR 91.147, and that section's full text, not a summary, is the place to see which flights fall on which side of the line.

What goes into a Letter of Authorization application?

Seven items. As written in 14 CFR 91.147(c), "Each application for a Letter of Authorization must include the following information:"

1. "Name of Operator, agent, and any d/b/a (doing-business-as) under which that Operator does business."
2. "Principal business address and mailing address."
3. "Principal place of business (if different from business address)."
4. "Name of person responsible for management of the business."
5. "Name of person responsible for aircraft maintenance."
6. "Type of aircraft, registration number(s), and make/model/series."
7. "Antidrug and Alcohol Misuse Prevention Program registration."

Then paragraph (d), one sentence long. As written in 14 CFR 91.147(d), "The Operator must comply with the provisions of the Letter of Authorization received."

Now read that list of seven with a busy season in mind. The maintenance lead takes a job across the field. A second helicopter comes on for the summer and leaves in October. The mailing address follows the bookkeeper. Each change is small, and each one makes the application on file a little less accurate than the day it was signed.

Treat those seven facts like any other change that touches safety. When one moves, someone writes it down, looks at what else it affects, and raises it with the Flight Standards office. A single page kept with the letter, listing the seven items, the date each was last confirmed and who confirmed it, catches most of the drift. Paper works fine for this one. What matters is that somebody owns the page.

How does Part 5 point back to 91.147?

By name. As written in 14 CFR 5.1, the part applies to "Any person that holds or applies for a Letter of Authorization issued under § 91.147 of this chapter."

The dates sit in § 5.9. As written in 14 CFR 5.9(a), that paragraph covers any person that "holds a Letter of Authorization issued under § 91.147 of this chapter before May 28, 2024," and lists two items: "Develop and implement an SMS that meets the requirements of this part no later than May 28, 2027" and "Submit to the FAA, a declaration of compliance with this part in a form and manner acceptable to the Administrator no later than May 28, 2027." Paragraph (b) covers applicants: "Any person applying for authorization to conduct operations under part 135 of this chapter or a Letter of Authorization under § 91.147 of this chapter, or with such application pending on or after May 28, 2024, must develop and implement an SMS that meets the requirements of this part."

As written in 14 CFR 5.9(e), a list of sections does "not apply to those organizations with a single pilot who is the sole individual performing all necessary functions in the conduct and execution related to, or in direct support of, the safe operation of the aircraft." The FAA's industry FAQ describes those excepted sections as ones that "primarily focus on internal communications and management duties and responsibilities." Where a given operation lands is, again, a question for its Flight Standards office.

As written in 14 CFR 5.5(a), an SMS under the part "must be appropriate to the size, scope, and complexity of the person's organization and include, at a minimum, all of the following components": "Safety policy," "Safety risk management," "Safety assurance" and "Safety promotion." RISE supports a safety management system with tools for each of those four areas, and you can book a demo to see how they work.

What does an air tour safety program watch week to week?

The same loop, flown eight or ten times a day. Repetition is the hazard nobody writes down, because the fortieth flight over the canyon feels exactly like the fourth.

The people closest to the work see the hazards first. Weather building on the far side of the ridge, out of sight from the ramp. Passengers who have never stood near a running aircraft walking out to board. Loose phones and cameras in the cabin. The overlook where three operators circle at the same altitude. A day planned around the booking calendar instead of the forecast. Your pilots see some of this, your line crew sees more, and the person at the check-in desk is often first to notice the passenger who looks unwell. If raising something takes more than a minute, the seasonal hire you brought on in May will not bother.

From there the work is familiar: evaluate the risk, record a decision with a name and a date, give each corrective action one owner and a due date, and check later that the fix held, which is what auditors look for in an SMS. A pre-flight risk score with a threshold where a second person signs off turns a gut call into a conversation. In RISE, an Administrator can build that kind of scored form with the form builder, setting low, medium and high thresholds above which approval can be required. The flight risk assessment resource gives you something concrete to adapt for a tour loop.

Where to start this month

Pull the Letter of Authorization and your copy of the application, and check each of the seven items in 91.147(c) against the operation as it runs today. Anything that has moved goes on the page, with a name next to it.

Then print 14 CFR 91.147, its cross-references and 14 CFR Part 5 Subpart A, and read them together at one table with a pen. Every "does this cover us" question you write in the margin goes to your Flight Standards office. While you wait on answers, book a demo to see how RISE records, tracks, routes and reports on the safety work your team already does.

Last, write down the five hazards on your tour loop that worry you most, and put one owner next to each. None of this needs a budget meeting.

When the hazard list outgrows a notebook, RISE takes reports from pilots, line crew and desk staff, including people without an account through a form link or printable QR code, scores risk evaluations on a 5 by 5 matrix with the acceptance decision and the person recorded, and tracks every corrective action to a named owner and due date. If that is the work in front of you, book a demo.

Sources

• eCFR: 14 CFR 91.147, Passenger-carrying flights for compensation or hire
• eCFR: 14 CFR Part 5 Subpart A, General
• FAA: Part 5 FAQ, From Industry (Revision 7, August 4, 2025)