By Nick Sanderson, Founder, Unrestricted Airspace
The 135 Lite framework fixes it.
Lower-risk operations…
Smaller aircraft…
Shorter routes…
Real-world experience.
Not theory. Not classroom time.
Actual flying that builds real pilots.
Right now, we force everyone into one path:
Instruct → hit a number → hope it translates.
That’s not a pipeline.
That’s a bottleneck.
135 Lite creates real jobs, real hours, and real experience.
If it works, it scales.
If it doesn’t, the market kills it.
That’s how it should be.
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Nick Sanderson, a commercial pilot, U.S. Army veteran, and founder of aviation businesses, has proposed the “Rural Air Mobility and Small Aircraft Charter Freedom Act.”
He says such a law would:
- create a real pathway for pilots to gain meaningful experience outside the training bubble.
- put rural airports back to work and bring real economic value to those communities.
The proposed Bill is presented here for your consideration.
A BILL
To amend title 49, United States Code, to establish a limited commercial operating category for small aircraft, to improve rural air mobility, support aviation workforce development, and reduce unnecessary regulatory burdens while maintaining appropriate safety standards.
SECTION 1. SHORT TITLE
This Act may be cited as the
“Rural Air Mobility and Small Aircraft Charter Freedom Act.”
SECTION 2. FINDINGS
Congress finds the following:
- The United States historically maintained a robust small-aircraft air taxi network that connected rural and suburban communities to regional transportation systems.
- Excessive regulatory burdens have substantially reduced the availability of small-aircraft commercial transportation in the United States.
- Aircraft carrying eight passengers or fewer and operating at lower speeds present significantly lower systemic risk than turbine aircraft used in large commercial air carrier operations.
- Current regulatory frameworks impose disproportionate compliance costs on small aviation businesses and restrict transportation access for rural communities.
- The United States faces an ongoing shortage of experienced pilots, and meaningful operational flight experience is critical to maintaining a safe and capable aviation workforce.
- Establishing a limited commercial operating category for small aircraft will expand aviation access while maintaining appropriate safety standards.
SECTION 3. CREATION OF SMALL AIRCRAFT LIMITED COMMERCIAL OPERATIONS (SALCO)
The Administrator of the Federal Aviation Administration shall establish a new operating category titled:
Small Aircraft Limited Commercial Operations (SALCO).
SALCO operations shall permit the transportation of passengers, property, or a combination thereof for compensation or hire using small piston-powered aircraft under the requirements established by this Act.
SECTION 4. SHALL-ISSUE OPERATING AUTHORITY
(a) Authority to operate under SALCO shall be shall-issue.
(b) Any person or entity meeting the requirements of this Act shall be authorized to conduct SALCO operations upon filing a registration notice with the Federal Aviation Administration.
(c) The Administrator may not require discretionary certification, operational approval, or evaluation beyond verification that the statutory requirements are satisfied.
(d) Registration shall be deemed approved within 30 days of submission, unless the Administrator identifies a specific violation of this Act.
SECTION 5. AIRCRAFT ELIGIBILITY
Aircraft operating under SALCO must meet the following criteria:
- No more than eight passenger seats.
- Passenger seats shall be defined as seats intended for occupants other than required flight crew members. Seats occupied by pilots or required crew members shall not count toward the passenger seat limitation.
- Aircraft must be piston-powered.
- Maximum cruise speed of 300 knots or less.
- Maximum certificated takeoff weight of 12,500 pounds or less.
SECTION 6. MAINTENANCE REQUIREMENTS
Aircraft operating under SALCO must maintain:
- A valid airworthiness certificate.
- A current annual inspection.
- A 100-hour inspection when used for operations for compensation or hire.
All maintenance must be performed by a properly certificated mechanic or repair station in accordance with Federal Aviation Administration regulations.
Revised Pilot Qualification Section
SECTION 7. PILOT QUALIFICATIONS
(a) Pilot in Command Requirements
A pilot serving as Pilot in Command (PIC) in SALCO operations must hold:
- A Commercial Pilot Certificate
- An Instrument Rating
- A Second Class Medical Certificate or BasicMed qualification
Minimum flight experience:
- 500 hours total flight time
- 50 hours cross-country flight time
- 25 hours in make and model or similar aircraft
(b) Second in Command Requirements
A pilot serving as Second in Command (SIC) in SALCO operations must hold:
- A Commercial Pilot Certificate
- An Instrument Rating
Minimum flight experience:
- 250 hours total flight time
(c) Operational Mentorship Environment
When operating aircraft requiring two pilots under this Act, the Pilot in Command shall maintain operational authority and responsibility for the safety of the flight.
The Second in Command shall assist in flight operations and gain operational experience within the National Airspace System.
SECTION 8. INSTRUMENT PROFICIENCY REQUIREMENTS
All pilots conducting SALCO operations must complete an Instrument Proficiency Check (IPC) every six months conducted by a Certified Flight Instructor – Instrument (CFII).
SECTION 9. MULTI-ENGINE AIRCRAFT CREW REQUIREMENTS
Aircraft equipped with more than one engine operating under SALCO shall be operated with two qualified pilots on board at all times.
Both pilots must meet the pilot qualification requirements established under this Act.
SECTION 10. OPERATIONAL LIMITATIONS
SALCO operations shall be limited as follows:
- Flights may not exceed 500 nautical miles per leg from the airport of departure.
- Operations must remain within the United States.
- Aircraft may carry no more than eight passengers, excluding required flight crew.
- Operations may be conducted under VFR or IFR when the aircraft is properly equipped.
SECTION 11. WEATHER MINIMUMS FOR IFR OPERATIONS
Flights conducted under instrument flight rules (IFR) within the SALCO category shall not depart or conduct approaches unless the reported weather conditions at the destination airport are at least:
- 1,000-foot ceiling, and
- 3 statute miles visibility.
SECTION 12. OPERATOR LIMITATIONS
(a) No SALCO operator may operate more than five aircraft under this authority.
(b) Aircraft must be owned or leased by the registered operator.
(c) Operators must maintain pilot qualification records and aircraft maintenance records for inspection by the Federal Aviation Administration.
SECTION 13. AVIATION TRUST FUND FEE
(a) SALCO operations shall be subject to a $50 operational fee per flight leg.
(b) Fees collected under this section shall be deposited into the Airport and Airway Trust Fund.
(c) Operators shall remit such fees quarterly through a simplified electronic filing system administered by the Department of Transportation.
SECTION 14. FAA OVERSIGHT
The Federal Aviation Administration retains authority to:
- Conduct ramp inspections.
- Review operator records.
- Suspend or revoke SALCO operating authority for violations of the requirements established by this Act.
SECTION 15. PREEMPTION OF PART 135 REQUIREMENTS
Aircraft operating under SALCO shall not be subject to operational requirements contained in Part 135 of title 14, Code of Federal Regulations, except where specifically required under this Act.
SECTION 16. PILOT WORKFORCE DEVELOPMENT
Congress recognizes that SALCO operations provide meaningful operational flight experience within the National Airspace System.
Flight time accrued under SALCO operations shall be considered qualifying flight experience toward Airline Transport Pilot certification requirements, consistent with existing FAA regulations.
The Administrator shall ensure that SALCO operations provide a recognized pathway for pilots to gain operational experience in:
- cross-country operations
- instrument flight operations
- passenger and cargo transportation
- commercial operational decision-making.
SECTION 17. GOVERNMENT ACCOUNTABILITY OFFICE REVIEW
The Government Accountability Office shall conduct a review of SALCO operations ten years after enactment to evaluate safety performance, economic impact, and aviation workforce development outcomes.
SECTION 18. FLIGHT TIME CREDIT FOR REQUIRED CREW MEMBERS
(a) For purposes of flight time logging and certification requirements under title 14, Code of Federal Regulations, both pilots serving as required flight crew members during SALCO operations shall be considered required crewmembers.
(b) Each pilot serving aboard a SALCO flight shall be permitted to log flight time consistent with their assigned role as:
- Pilot in Command (PIC) when acting as the pilot responsible for the operation and safety of the flight; or
- Second in Command (SIC) when serving as the additional required pilot.
(c) For aircraft operating under SALCO that are required by this Act to operate with two pilots, both pilots shall be considered required crew members regardless of whether the aircraft type certificate requires more than one pilot.
(d) Second in Command flight time accrued under SALCO operations shall be creditable toward Airline Transport Pilot (ATP) certification requirements, consistent with applicable FAA regulations governing ATP eligibility.
(e) The Administrator of the Federal Aviation Administration shall ensure that flight time accrued under SALCO operations is recognized as valid operational flight experience within the National Airspace System.
(f) SIC pilots with fewer than 500 hours may not act as pilot flying during IFR operations unless supervised by the PIC.