I am wondering if any FAR's would prohibit the air-to-air refueling of two civilian aircraft in the US. In our use case, the receiving aircraft would be custom-built, and it would receive fuel pumped from a portable tank temporarily installed in a Quest Kodiak turboprop with the cargo door taken off.

There's the umbrella "don't be reckless" rule, but if it's done in a controlled way, what laws might stop us?

  • $\begingroup$ What rules are you operating under? I assume that this isn't a "Part 91" flight... Is the receiving aircraft manned? Do you have protections to prevent the leaking of fuel unless a strong connection is made? $\endgroup$
    – Ron Beyer
    Apr 27 at 14:39
  • $\begingroup$ It would be a Part 91 flight, both aircraft would be manned. And we have a plan for fuel leak mitigation. If it sounds like a lot of trouble, it is for a record-breaking attempt. $\endgroup$
    – varihard
    Apr 27 at 14:42
  • $\begingroup$ I'm pretty sure there's no specific FAR against in-flight refueling but-- is it always impossible to know how the FAA will construe the reg against "careless or reckless operation" or whatever it says in any given case. $\endgroup$ Apr 27 at 14:45
  • $\begingroup$ Thanks quiet flyer, what's an example of doing this without it being under part 91? In my heavily tracked professional flying career I never really paid attention to anything besides 91 and 135, embarrassingly $\endgroup$
    – varihard
    Apr 27 at 14:52
  • $\begingroup$ edit: i see that for a special airworthiness certificate, option no. 4 is "exhibition flights" which this could potentially fall under. $\endgroup$
    – varihard
    Apr 27 at 15:04

I can't provide a definite yes or no, but I can discuss some of the FARs that will need to be considered. In most cases you have to consider three groups of FARs; covering aircraft, aircrew, and operations.

For the aircraft, they have to have an airworthiness certificate.

The Kodiak is certificated, but you have to address operating without the cargo door (may be approved) and if the temporary installation of your refueling equipment needs any approvals. Many temporary installations don't but since your refueling equipment will connect to another aircraft's fuel system it may need a 337 or STC.

You say the receiving aircraft will be custom built. That implies an experimental certificate. There are two, maybe three, different experimental certificates that you could theoretically apply. The first is Experimental-Amateur Built (E-AB). This could work if you are not a business and this effort is for personal educational purposes. It's the least restrictive, but is in a gray area of applicability. The second is Experimental-R&D. It would be applicable, but it's the most restrictive certificate as it limits you to just R&D flights and crew proficiency flights and it requires annual renewal. Experimental-Exhibition might apply, but it's usually limited exhibition flying of existing, non-certificated (typically ex-military) aircraft. In any of these, I would expect that you would need to include aerial refueling within the operating limitations and that means getting an FAA inspector to buy off on it.

For the aircrew, I expect the one potential issue is one of compensation. If everyone holds at least a Commercial certificate that would avoid any gotchas. The other issue may be meeting the FAA training guidelines for formation flying.

Flight operations would be subject to Part 91 and the operating limitations of the aircraft. I would expect that refueling operations would be limited to airspace 'not over populated areas.'

So, I expect it would be possible but it could be difficult getting the necessary approvals.

  • 1
    $\begingroup$ I would add consulting with people with military air-to-air refueling experience, not just simple formation flight, both for your safety and as a defense against a claim you were “careless or reckless”. ADM isn’t about eliminating risks; it’s about identifying and mitigating them. $\endgroup$
    – StephenS
    Apr 28 at 23:52

I would start by contacting the ARTCC in whose airspace you would want to do this. Their Airspace and Procedures office should be able to assist, and get you in contact with the right people. They can also help, in the event that you get approval, with planning the airspace to use for the flight.

We used to do extensive airspace reservations for military flights, but we've done smaller scale stuff for civilians as well. We call the military ones "altitude reservations(ALTRV, pronounced Al-trav)", and generally use the term "waiver" for civilian use. It's mostly a difference in scale.

At ZDV, I've seen numerous civilian and government special flights involving similar requirements to aerial refueling (block altitudes, extended straight line patterns, formation flights, photo grids), but never refueling involving civilian aircraft.

I would think that the biggest issue might be insurance in case of a mishap.

Keep us posted, if you have any luck. I'd love to see this.


Yes, but you shouldn’t.

The FAA can allow nearly anything, with high enough level sign-off. But getting any sign-off out of the FAA can be an involved process, which can require significant domain knowledge. If you have to ask on here, you probably shouldn’t be doing it. Regardless of whether the FAR allows it, you’re going to need to manipulate FAA process to make that okay. If you don’t know how to do that, any answer you get on here is going to be too superficial or high-level to actually help.

It’s kind of like asking, “can I build a safe pedestrian bridge using toothpicks?” Obviously, yes: with enough time and money you can meet any performance requirement. And a question here might say “yes”, and even give you a broad overview of possible avenues. But if your main source of advice on method is stack exchange, you’re going to have a bad time. The format simply doesn’t allow transmitting enough of the knowledge base.

If you want to do this, you need to find a real-life expert on FAA processes and work with them. There are too many specifics.

  • $\begingroup$ "If you want to do this, you need to find a real-life expert on FAA processes and work with them. There are too many specifics" ------------------------------------------------------------------------------------------------------ .And that's why you start by contacting an ARTCC, and talking to their Airspace and Procedures office.If it can't be done, they'll tell you. $\endgroup$
    – atc_ceedee
    May 8 at 23:54
  • $\begingroup$ @atc_ceedee if you just want any yes-or-no answer, you’re right. If you want the answer to be “yes”, you should find someone to talk to them for you. $\endgroup$
    – fectin
    May 9 at 1:21

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