I came across this once, and despite searching with Bing and Google cannot find it again. As memory serves, the FAA counsel wrote a letter finding that glider sight-seeing operations do not need approved drug testing programs.

All help is appreciated!

  • $\begingroup$ To save some research time, can you specify what reg the "approved" drug testing programs would be (have been under). Are you referring to Part 135? $\endgroup$
    – user22445
    Sep 13, 2023 at 0:57
  • $\begingroup$ @RTO Good question, but alas I don't know. It was something I read in passing a while back, and I was thinking to send it to a friend who is getting his Part 135 for turboprop charter flights. $\endgroup$ Sep 13, 2023 at 1:19
  • $\begingroup$ Go to FAA Interpretations, input FAR Part 91.147, and read the "Fields" and "Ragland" interpretations. $\endgroup$
    – user22445
    Sep 13, 2023 at 2:05
  • $\begingroup$ @RTO, Thank you, I didn't know about the FAA Interpretations Search site (faa.gov/about/office_org/headquarters_offices/agc/…). The Fields interpretation was the one I was looking for, esp. re the conclusion that 91.147 does not apply, and therefore there is no need for a LOA or drug testing program. Do you want to turn your comment into an answer so I can give it the nod? $\endgroup$ Sep 13, 2023 at 3:39

1 Answer 1


Based on the cited FAA Regulations, and pertinent excerpts from the "Field" memorandum/interpretation linked below, it appears that glider sight-seeing operations do not need a drug testing program.


Specifically, 120.1 - Applicability:

states that "This part applies to the following persons:

(a) All air carriers and operators certificated under part 119 of this chapter authorized to conduct operations under part 121 or part 135 of this chapter, all air traffic control facilities not operated by the FAA or by or under contract to the U.S. military; and all operators as defined in 14 CFR 91.147 .

This FAA Memorandum/Interpretation - Subject: Interpretation on Regulation of Sight seeing Rides in Gliders - states, in pertinent parts:


Likewise, § 91.147 states that it applies to air tours conducted in airplanes and helicopters; it therefore does not apply to air tours conducted in gliders. See § 91.147(a).


Although glider sightseeing rides are not explicitly excepted from part 119, it is our opinion that such operations would not need to be conducted under the authority of a part 119 certificate. First, a glider operation could not be conducted under part 121 or part 125 rules, which apply to airplanes, or part 135 rules, which apply to airplanes and rotorcraft. See§§ 119.21-.25. Next, as discussed above, the final rule implementing the part 136 air tour rules and the§ 91.147 rule affirmatively state that glider sightseeing operations are not covered by the rule thereby indicating the FAA' s intent to not include these operations in the part 119 construct. See 72 Fed. Reg. at 6885 (stating the rule "does not apply to gliders (powered or unpowered)"). Therefore, the FAA would not require an operator that conducts air tours for compensation or hire in gliders to hold a part 119 certificate.

Accordingly, an air tour conducted for compensation or hire in a glider may be conducted under the part 91 operating rules. It need not comply with the§ 91.147 commercial air tour rules or the part 136 air tour rules. The operator need not hold a part 119 certificate.

(emphasis is mine)


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