NBAA Small Aircraft Exemption extended until 2026

The NBAA received an extension to its Small Aircraft Exemption until March 31, 2026 which allows NBAA members operating small aircraft to take advantage of the flexibility offered to larger, turbine-powered aircraft operators.

“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,” said Doug Carr, NBAA’s senior vice president of safety, security, sustainability and international affairs. “It’s important that members understand and comply with the Letter of Intent submission to the docket and notification to FSDOs to ensure the NBAA Small Aircraft Exemption continues to be valid and is utilized appropriately.”

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Exemption 7897M, the current version of the NBAA Small Aircraft Exemption, provides operators of piston-powered airplanes, small planes (with a gross weight of 12,500 lbs or less) and rotorcraft many advantages. These advantages include the use of alternative maintenance programs and limited cost reimbursement for some flights following Part 91 Subpart F of the Federal Aviation Regulations. The cost-sharing benefits of Part 91 Subpart F are generally limited to an aircraft with a maximum takeoff weight over 12,500 lbs, multi-engine turbojet aircraft or fractional ownership program aircraft.

The exemption applies to operations listed in 14 CFR § 91.501(b)(1) through (7) and 91.501(b)(9). The cost-reimbursement options of Part 91 Subpart F are useful in scenarios like the transportation of guests on a company aircraft and employees using aircraft belonging to a subsidiary company. In addition, time-sharing, interchange and joint ownership agreements are also permitted.

In 2022, the FAA introduced a requirement for the operators intending to use the exemption to submit a Notice of Joinder in the public docket. The newest revision has renamed this as “Letter of Intent.” Members are required to submit a letter to the docket to use Exemption 7897M, even if they have a Notice of Joinder on file.

The letter must include:

• The member’s legal name and/or the legal name of the authorized individual submitting the Letter of Intent.
• The member’s physical address and/or the physical address of the authorized representative. If the authorized representative does not receive mail at the physical address given, a mailing address where they do receive mail must be provided.
• The member’s email address and/or email address of an authorized representative.
• The member’s telephone number(s).
• The member’s NBAA membership number
• An attestation that the member will comply with all the conditions and limitations of Exemption No. 7897M.

Operators using this exemption must notify the appropriate Flight Standards District Office of their intent and provide that FSDO with a copy of their time-sharing, interchange or joint ownership agreement under which each aircraft is operated, if appropriate.