NBAA Extends Part 91 Subpart F Benefits For Smaller Aircraft

Image: NBAA
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Key Takeaways:

  • The National Business Aviation Association (NBAA) has extended its Small Aircraft Exemption through March 2026, providing operators of piston-powered airplanes, small airplanes, and rotorcraft access to Part 91 Subpart F benefits.
  • This exemption allows smaller aircraft to utilize cost-sharing, alternative maintenance programs, and limited cost-reimbursement options typically available only to larger, turbine-powered aircraft.
  • Benefits include cost-reimbursement for transporting guests or employees of a subsidiary, and provisions for time-sharing, interchange, and joint-ownership agreements.
  • To utilize the exemption, NBAA members must submit a letter of intent to the public docket, detailing business information and attesting adherence to the exemption's terms.
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The National Business Aviation Association (NBAA) has secured an extension for its Small Aircraft Exemption through the end of March 2026. Doug Carr, NBAA’s senior vice president of safety, security, sustainability, and international affairs, said, “This valuable exemption allows operators of piston-powered airplanes, small airplanes and rotorcraft to realize the cost-sharing benefits outlined in Part 91 Subpart F, making more effective use of their aircraft.” Subpart F of Part 91 was written into the regulations to accommodate the fractional-ownership business model pioneered by NetJets. NBAA said its members who operate small aircraft for business can “take advantage of the flexibility usually offered to operators of larger, turbine-powered aircraft.”

NBAA members must submit a letter of intent (LOI) to the public docket to use Exemption 7897M. The letter must include detailed information on the business entity and an attestation that the operator will adhere to the terms of the exemption.

Previously only available for aircraft of more than 12,500 pounds gross weight, the benefits of Subpart F include “alternative maintenance programs” and limited cost-reimbursement from passengers for certain flights. NBAA wrote: “The cost-reimbursement options of Part 91 Subpart F are useful regarding transportation of a guest on a company aircraft, the use of the aircraft by employees of a subsidiary company and other common scenarios. Time-sharing, interchange, and joint-ownership agreements are also permitted under Part 91 Subpart F.”

Mark Phelps

Mark Phelps is a senior editor at AVweb. He is an instrument rated private pilot and former owner of a Grumman American AA1B and a V-tail Bonanza.
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