NBAA Extends Part 91 Subpart F Benefits For Smaller Aircraft


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.


  1. My BS meter just pegged: “NBAA’s senior vice president of safety, security, SUSTAINABILITY, and international affairs…” He needs to read “The Ultimate Resource” by Julian Simon and get off the green movement, a spiral to the bottom.

    • I fail to see the connection of the green movement and Julian Simon’s book with this article about Subpart F. Please explain.

  2. I still remember a time of freedom where a couple of guys could just buy a plane together and and fly it. Now it’s Code of Regulations, 91.501, section b, item 10, subpart ii, referring to paragraph (b) (6).

    No wonder people today would rather buy a boat or a motorcycle!

    • No, it appears Subpart F is related to “business” use, ie chartered flights, flying employees around etc. vs a couple of guys punching holes in the air on any given day. Maybe I’m missing something so please explain how “91.501, section b, item 10, subpart ii, referring to paragraph (b) (6)” affects these couple of guys?

      • The freedom to buy a plane and use it as you wish Vs the legalese that makes every flight a possible violation.

        • Oh ok, so you’re just bent out of shape because of ALL regulations vs specifically Subpart F, as the tone of the article is “good news” for small aircraft owners involved in a business activity. Perhaps you should save your “all regulation infringes on my personal freedom” for another, more applicable article?

          • The article simply illustrates why private flying is now the least attractive hobby; you have to know ALL regulations down to the ii’s and the interpretations thereof.

        • Hey, Arthur! It looks like Subpart F only applies when an aircraft is operated as part of a fractional ownership program under Subpart K, which clarifies that a fractional ownership program is one where multiple aircraft are managed by a single program manager on behalf of multiple fractional owners over a multi-year basis – not private or joint ownership of a GA plane for personal use. I understand that all those words can get confusing if you don’t spend a lot of time looking at the regs – I know they sometimes can for me!

          I guess I’m glad that we have regulations in place (for the most part). I’m sure you can agree that being able to ‘use [a plane] as you wish’ might not be a great idea for those who have wishes that might not be all that wholesome. I think it’s been said before that laws aren’t for the honest, but for the dishonest!

          Hope that helps, and have a great day!

  3. DETAILS–we need DETAILS!

    How about some “News we can use”? Please provide examples of how small aircraft owners can benefit from this program? Do the aircraft have to be maintained differently–like a charter aircraft? Are there separate pilot qualifications? Would operating under these rules affect your insurance? Are there mandated rest period, like Part 135? Are there separate dispatch and weather minimums, like Part 135? Or can you continue to operate to Part 91 standards?

    This isn’t “news” until there is CONTEXT.