CFR 125.205 states that

§ 125.205 Equipment requirements: Airplanes under IFR. No person may operate an airplane under IFR unless it has— (a) A vertical speed indicator; (b) A free-air temperature indicator; (c) A heated pitot tube for each airspeed indicator;

but CFR 91.205 (d) (which describes the instrument equipment requirements for IFR (Instrument airworthiness), does not require pitot heat)

(d) Instrument flight rules. For IFR flight, the following instruments and equipment are required: (1) Instruments and equipment specified in paragraph (b) of this section, and, for night flight, instruments and equipment specified in paragraph (c) of this section.
(2) Two-way radio communication and navigation equipment suitable for the route to be flown. (3) Gyroscopic rate-of-turn indicator, except on the following aircraft:
(i) Airplanes with a third attitude instrument system usable through
flight attitudes of 360 degrees of pitch and roll and installed in accordance with the instrument requirements prescribed in § 121.305(j) of this chapter; and
(ii) Rotorcraft with a third attitude instrument system usable through
flight attitudes of ±80 degrees of pitch and ±120 degrees of roll and installed in accordance with § 29.1303(g) of this chapter.
(4) Slip-skid indicator.
(5) Sensitive altimeter adjustable for barometric pressure.
(6) A clock displaying hours, minutes, and seconds with a sweep-second > pointer or digital presentation.
(7) Generator or alternator of adequate capacity.
(8) Gyroscopic pitch and bank indicator (artificial horizon).
(9) Gyroscopic direction indicator (directional gyro or equivalent).

So which is controlling?


1 Answer 1


Operations that are subject to U.S. 14 CFR Part 91.205(d) do not apply to operations conducted under U.S. 14 CFR Part 125.205. These are two different CFR's (Part 91 and Part 125).

Note: 14 CFR Part 125 applies to airplanes having a seating capacity of 20 or more passengers or a maximum payload capacity of 6000 pounds or more. [...] "Part 125 provides for the operation of large airplanes that are not conducting operations in common carriage...." (for example, "private carriage") (Ref: para 2.1.1 of AC 125-1A)

(emphasis is mine)

By the way, pitot heat is required under U.S. 14 CFR Part 91, Appendix A for Category II operations, (Group II instruments and equipment). See Appendix-A-to-Part-91(2.)(b)(5). Group I and Group II have to do with instrument and equipment maintenance requirements.

  • 1
    $\begingroup$ Yes, after I posted the question, a friend called me and told me about this.... duh! I should have known that... Thanks! $\endgroup$ Sep 14, 2023 at 22:05

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