Clear Approach Safety
Clear Approach Safety

§ 91.147 commercial air tours

SMS software for air tour operators

Commercial air tour operators holding a § 91.147 letter of authorization were brought under 14 CFR Part 5 by the 2024 final rule. Most SMS vendors write for Part 135 charter and leave you to translate. This does not.

Air tours are explicitly in scope

When the FAA finalised its expanded SMS rule on 26 April 2024, it named three groups: Part 135 certificate holders, certain Part 21 type and production certificate holders, and commercial air tour operators conducting operations under § 91.147. If you hold a § 91.147 letter of authorization, you are required to develop and implement a safety management system meeting Part 5 and to submit a Declaration of Compliance by 28 May 2027.

This was not an accident of drafting. Air tour operations have been a sustained focus of NTSB recommendations, and the inclusion of § 91.147 in the final rule reflects that.

What is different about air tour risk

The four pillars of Part 5 are the same for everyone. What differs is the hazard profile your reporting and risk assessment have to capture. Air tour operations concentrate risk in areas a generic safety tool handles badly:

  • Repetitive low-altitude routes. The same terrain, the same turn points, day after day — which normalises deviations that would stand out on a one-off flight.
  • Terrain and obstacle proximity. Controlled flight into terrain remains a dominant risk category, and it is one the trend taxonomy here explicitly tags.
  • Weather sensitivity and commercial pressure. Tours are sold in advance to passengers who have travelled to be there. That pressure is a genuine organisational hazard and belongs in your risk register as one.
  • High-frequency, short-duration sorties. Many cycles, short turnarounds, and the fatigue and maintenance exposure that come with them.
  • Passenger handling on and around active ramps. Ground operations is a first-class hazard category here, not an afterthought.

How this platform handles it

Reports carry tail number, aircraft type, ICAO airport code, and a free-text location field that fits a route or a landing site as readily as an airport. Occurrence times are captured in local time and UTC, which matters when your operation runs many short sorties across a day.

Hazard categories cover flight operations, maintenance, ground operations, cargo handling and security. AI trend-tagging classifies free-text reports against a fixed aviation taxonomy that includes terrain, weather and approach-related tags, and those tags become filters on your dashboard — so a pattern across many small reports becomes visible instead of staying buried in prose.

Risk assessment uses the standard FAA 5×5 matrix from AC 120-92D, with initial and residual scoring and control validation windows. More on how the matrix works.

Pilots who fly for you need to be able to report

Air tour flying is often seasonal and often flown by pilots building time. Both facts make attributed reporting less likely, not more. Anonymous submission is built in, and exports redact reporter names and tail numbers by default, so you can share trend data internally or with the FAA without exposing who filed what.

Priced for the size you actually are

A two-aircraft tour operator carries the same regulatory obligation as a large charter fleet and a fraction of the budget. Plans start at $99 per month. See pricing.

See whether it fits your operation

Twenty minutes, no card. Tell us what certificate you hold and where your implementation plan stands, and we will show you the parts that apply to you.