2-1 CHAPTER 2. REGULATORY REQUIREMENT AND AUTHORIZATION
2.1 Regulatory Requirement. Section § 136.75(d) states:
“Minimum flight altitudes. Except when necessary for takeoff and landing, or operating in compliance with an air traffic control clearance, or as otherwise authorized by the Administrator [emphasis added], no person may conduct an air tour in Hawaii:
(1) Below an altitude of 1,500 feet above the surface over all areas of the State of Hawaii, and,
(2) Closer than 1,500 feet to any person or property; or,
(3) Below any altitude prescribed by Federal statute or regulation.”
2.2 Authorization. In the interest of enhancing aviation safety among commercial air tour operators in the State of Hawaii, the FAA provides CHs and operators with the option of obtaining an authorization to deviate from § 136.75(d)(1) to conduct commercial air tour operations below 1,500 feet above the ground or water surface below for the sole purpose of remaining in VMC and of avoiding entering IMC that was not forecast or observed and reported. The deviation is authorized by the Administrator through OpSpec/LOA B048. The authorization is not intended to allow deviation from § 136.75(d)(2), that states air tour operations may not be conducted closer than 1,500 feet to any person or property.
2.2.1 If a CH or operator wishes to obtain such an authorization, the Administrator will consider each individual application in its entirety. The FAA requires the inclusion of additional aircraft equipage, safety risk analysis, appropriate pilot training, and FAA acceptance of operating procedures (as they pertain to flight operations below 1,500 feet above the surface, as authorized through OpSpec/LOA B048) before such authorization is issued to Hawaii commercial air tour operators who apply for OpSpec/LOA B048. The FAA recommends that CHs and operators collaborate and establish industry consensus procedures to be applied by all air tour providers operating in the same airspace where cooperation among commercial air tour providers would enhance safety. This collaborative approach to developing commonly applicable procedures and methods may streamline application approval processes for all participants.
2.3 OpSpec/LOA B048. An air carrier CH may apply for and may be issued OpSpec B048, and a noncertificated commercial air tour operator who conducts operations under part 91 may apply for and may be issued LOA B048. The Honolulu Flight Standards District Office (FSDO) will approve the commercial air tour operations document(s) and manual(s), as applicable, and make the determination of whether to issue OpSpec/LOA B048. If the Honolulu FSDO is not the responsible Flight Standards office for the CH or operator, the responsible Flight Standards office should forward the application package to the Honolulu FSDO for review and approval. Upon its approval, the Honolulu FSDO will notify the responsible Flight Standards office of their decision, at which point the responsible office will issue OpSpec/LOA B048 in the Web-based Operations Safety System (WebOPSS). The conditions and limitations contained in the
2-2 CH’s or operator’s specific authorization given through OpSpec/LOA B048 are only applicable to commercial air tour flights conducted below 1,500 feet above the surface in the State of Hawaii in order to remain in VMC and avoid entering unforecast or unreported IMC.
2.4 Operations Over Units of the NPS. In accordance with 49 U.S.C. § 40128, as codified in 14 CFR part 136 subpart B, commercial air tour overflights of national parks are subject to additional restrictions, as outlined in a park unit ATMP, an FAA-issued IOA, or FAA/National Park Service/Operator Air Tour Voluntary Agreements (VA). National park units subject to such additional restrictions in the State of Hawaii include, but are not limited to: Kaloko-Honokōhau National Historic Park (NHP), Puʻuhonua o Hōnaunau NHP, Puʻukoholā Heiau National Historic Site (NHS), the USS Arizona Memorial, Hawaii Volcanoes National Park (NP), Haleakalā NP, and Kalaupapa NHP.
2.4.1 Independent from the authorization given through OpSpec/L OA B048, all commercial air tour operators must (per § 136.37) be authorized by OpSpec/LOA B057, as applicable, if they wish to conduct, or are currently conducting, operations over a national park under an ATMP, an IOA, or a VA within half a mile outside the boundary of any national park unit, or over an abutting tribal land, during which the aircraft flies (except as provided in § 136.35):
• Below 5,000 feet above the surface (except for the purpose of takeoff or landing, or to take action to ensure the safe operation of the aircraft), or
• Less than 1 mile laterally from any geographic feature within the park (unless more than half a mile outside the boundary).
Note: CHs and operators should consider including the following statement as a part of the commercial air tour operator’s accepted operating procedures to ensure pilots maintain compliance with part 136:
“With respect to the airspace over, and within ½ mile of the boundaries of the following national park system units: Kaloko-Honokōhau NHP, Pu’uhonua o Hōanunau NHP, Pu’ukoholā Heiau NHS, the USS Arizona Memorial, Hawaii Volcanoes NP, Haleakalā NP, and Kalaupapa NHP, the information contained within this document or manual applies to all commercial air tour operators, as defined by 14 CFR part 136, in receipt of interim operating authority (IOA). After Air Tour Management Plans (ATMP) are developed for these parks units, if the Administrator revises applicable conditions and limitations for safety that are more restrictive than those in the ATMP, the more restrictive parameters will apply. If, after an ATMP is developed, the language of this document or manual is less restrictive than the ATMP, the ATMP will control and this document or manual will be updated within 180 days of the ATMP being developed to reflect the more restrictive parameters set forth in the ATMP. This document or manual will not supersede, circumvent, or otherwise change any aspect of, or implementation of the ATMP, when developed, for these parks or park units or both. Please refer to the map legends for any specific national park or park unit flight restrictions.”
3-1 CHAPTER 3. AUTHORIZATION PROCESS
3.1 Process Overview. A commercial air tour operator may apply for and receive from the Administrator an authorization to be able to conduct commercial air tour operations below 1,500 feet above the surface in the State of Hawaii through OpSpec/LOA B048, in order to remain in VMC and avoid entering unforecast or unreported IMC. After each applicant’s submission of the complete application package, the FAA will review each individual application package and will discuss any necessary changes or additional necessary information with the applicant. After the Administrator has found the application package to be acceptable, the Administrator may issue OpSpec/LOA B048, as applicable.
3.2 Step 1: CH or Operator Notification. The CH or operator notifies the Administrator of their interest to obtain the authorization given through OpSpec/LOA B048. The notification may be submitted through the Safety Assurance System (SAS) platform, via email, or in a paper form (as applicable for part 91 operators or CHs).
3.3 Step 2: Application Package Submission. A CH or operator submits the OpSpec/LOA B048 application package to the Administrator. Steps 1 and 2 may be done simultaneously. The original application package and any future revisions or changes to any portion of it should be submitted in a manner acceptable to the Administrator. It is recommended that the application package includes:
3.3.1 A letter addressed to the Administrator explaining the CH’s or operator’s need for the authorization given through OpSpec/LOA B048 and the nature and scope of the intended operations.
3.3.2 The CH’s or operator’s specific operating procedures, considering the items described in this AC, including the manner in which the CH or operator intends to manage ground and flight operations, weather minimums and weather sources, recordkeeping, any prohibited operations, etc., as further described in Chapter 4, Operating Procedures.
3.3.3 The name and a description and definition of the KSSA in which the CH or operator proposes to conduct commercial air tour operations, and the CH’s or operator’s specific tour flight profiles. These areas may be described and defined by latitude and longitude coordinates, altitudes, and distances from reference points (as applicable), and a pictorial description of the CH’s or operator’s air tour flight profiles that is depicted on the applicable sections of the version of the Visual Flight Rules (VFR) Hawaiian Islands Sectional Chart that is current at the time of the application submission, as further explained in Chapter 4.
3.3.4 The list of the instrumentation on the aircraft to be utilized when conducting commercial air tour operations in the State of Hawaii under the authorization given through OpSpec/LOA B048. The aircraft list should also include the aircraft’s make, model, and series (M/M/S); registration number; and instrument flight rules (IFR) equipment as required by § 91.205(d) installed (at a minimum, instruments and equipment capable of conducting at least one type of instrument approach procedure (IAP) available in the area
3-2 of operation). It is also recommended that aircraft are equipped with an operable Automatic Dependent Surveillance-Broadcast (ADS-B) In and Out system. In addition, the CH or operator should submit any applicable Supplemental Type Certificate (STC), minimum equipment lists (MEL), and instrument inspection and maintenance program, as further explained in Chapter 5, Aircraft Equipment.
3.3.5 The CH’s or operator’s specific pilot training (as further explained in Chapter 6, Pilot Training) should include:
• P ilot ground and flight training,
• Training on each KSSA where the applicant intends to operate,
• Entry and exit points to the different KSSAs,
• Geographical areas and islands in the State of Hawaii,
• Areas of interest and commonly flown sightseeing locations, and
• Training for IMC operations on the specific aircraft to be utilized.
3.3.6 The manner in which the CH or operator intends to integrate the use of safety risk analysis to their operations.
3.3.7 The manner in which the CH or operator intends to perform recordkeeping of, at a minimum, the following:
3.3.7.1 Completed performance plans. Recordkeeping may take on many forms, depending upon the operator’s method of performance planning. For example, for each group of helicopters in the fleet, and for the maximum pressure altitude where tour operations will be conducted, a maximum allowable gross takeoff weight (GTOW) may be associated with each increasing degree of temperature. The CH or operator should develop a procedure requiring the max allowable GTOW to be posted and maintained throughout the day, and this weight and the time/temperature could be recorded on the performance section of a passenger list for each flight. Providing the actual GTOW based on fuel and payload is less than the max allowable GTOW, the flight will remain within performance limits. The record, in the form of a passenger list/performance review, should be retained for as long as the operator normally retains such documents, usually not less than 30 days.
3.3.7.2 Flight logs, including the passenger list and performance review for each flight.
3.3.7.3 Maintenance logs, indicating all servicing and maintenance performed, MEL deferrals and extensions, etc., should be available to pilots and should be consulted before initiating operations at the beginning of each crew change.
3.3.7.4 Pilot training records.
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3.3.7.5 Attendance to the formal commercial air tour safety meeting.
3.3.8 The operating procedures and pilot training subjects, which should be presented in an organized manner and include the following general information:
• Effective date,
• Purpose,
• Distribution list,
• Revision date,
• Explanation of changes,
• List of effective pages,
• Record of revisions,
• Table of contents, and
• Definitions, abbreviations, and symbols.
3.4 Step 3: FAA Application Package Review. The Honolulu FSDO will review each submitted package and will consider each CH’s and operator’s individual operation, discuss any necessary changes to the application package with the CH or operator, and make a determination if the authorization will be issued. If the Honolulu FSDO is not the responsible Flight Standards office for the CH or operator applicant, the applicant will submit the application package to their responsible Flight Standards office, and that office will then forward the complete application package to the Honolulu FSDO for coordination, review, and concurrence with the issuance of OpSpec/LOA B048.
3.5 Step 4: Changes to Application Package. If changes are needed, the CH or operator will revise the application package and will resubmit the revised version of the application package to the Administrator, via the Honolulu FSDO, for further review.
Note: Steps 3 and 4 might be repeated if the Administrator finds that additional changes are necessary to any part of the application package.
3.6 Step 5: Decision for Authorization Issuance. The Administrator notifies the CH or operator in writing of the decision to issue OpSpec B048 or LOA B048, and the addition of such to OpSpec A005. If the CH’s or operator’s application is denied, the CH or operator may petition for reconsideration of that decision under 14 CFR part 119, § 119.51(d).
Note: Steps 2 through 4 above should be repeated any time the CH or operator proposes to amend any documents that were relied upon in the determination of the issuance of the CH’s or operator’s original OpSpec/LOA B048, prior to the change or as requested by the Administrator. The Administrator will respond with acceptance/approval or a denial following the final submission of the CH’s or operator’s amendments to the documents submitted as part of the application
3-4 package. The CH’s or operator’s utilization of an amendment to the documents that were relied upon in the determination of the issuance of the CH’s or operator’s OpSpec/LOA B048 that changes the FAA determination could lead to initiation of removal of the authorization through the § 119.51 process.
Additionally, a CH or operator who has been issued the authorization via OpSpec/LOA B048 who requests amendment to the terms of that OpSpec should follow the amendment procedures in § 119.51.
3.6.1 For CHs, the operating procedures document or manual accepted by the Administrator should be made an appendix to the CH’s required General Operations Manual (GOM), and any additional training approved by the Administrator should be included in, or made an appendix to, the CH’s required approved training program. As for part 91 operators, the operating procedures document or manual accepted by the Administrator, and the training document or manual approved by the Administrator, should be kept by the operator in a paper or electronic file to be utilized, as stated as a condition of LOA B048.
4-1 CHAPTER 4. OPERATING PROCEDURES
4.1 Design, Description, and Definition of Areas of Operations. CHs and operators may derive significant benefit from collaborating with each other to establish consensus standards to avoid congested areas, sensitive locations, areas that lack reasonably safe precautionary landing sites, and to operate within KSSAs in a cooperative manner.
Although each CH or operator is responsible for developing their own policies, procedures, and training, ideally these would be based on collaborative Hawaiian air tour industry consensus standards. Industry groups can often facilitate development of consensus standards and common procedures. The CH or operator may present the following information in their operating procedures package to the Administrator for acceptance:
4.1.1 KSSAs. These areas may be designed by each CH or operator who applies for OpSpec/LOA B048. The CH or operator may use latitude and longitude coordinates, or distances from reference points and flight altitudes. These may be coordinated with other CHs and operators working in the same KSSA airspace. The KSSAs may also include special restrictions applicable to each area that may be presented in narrative form or as a pictorial description of specific applicable areas on the VFR Hawaiian Islands Sectional Chart or other map, chart, or aerial photo that provides sufficient detail, and in a manner acceptable to the Administrator.
4.1.2 C ATFPs . These profiles designated by each CH or operator may include specific flight altitudes, KSSAs, and transition areas to be flown, locations to be avoided, identification of air traffic restricted or prohibited areas, flight patterns in the general vicinity of specific landmarks or KSSAs, national park units, and transition areas, as defined and designed in cooperation with other commercial air tour operators working in the same areas. CATFPs may be depicted pictorially over the specific applicable areas of the VFR Hawaiian Islands Sectional Chart or other map, chart, or aerial photo that provides sufficient detail and in a manner acceptable to the Administrator.
4.1.3 T ransition Areas. T ransition areas should be wide swaths of airspace offering unlimited variation in lateral adjustment of flight paths between one KSSA and the next. CATFPs are not intended to be flown along narrow course lines, but rather, may be flown through transition areas along any flight path across the width of the area as needed to maximize separation from potentially hazardous weather, avoid overflying the same locations repeatedly, maximize access to potential safe precautionary landing sites, and avoid flying over known sensitive areas. The transition area should include CH or operator designated minimum routine flight altitudes (reflecting the 1,500 feet above the surface mandatory minimum altitude per § 136.75(d)). Sensitive locations throughout the transition area should be marked on the transition area chart or map. The width and extent of transition areas between KSSAs should begin at an exit point from one KSSA and end at an entry point adjacent to the next KSSA that feeds the flight patterns surrounding that KSSA (as cooperatively developed among CHs and operators working in the same KSSAs). Transition area flight segments may be presented as a pictorial description over specific applicable areas of the VFR Hawaiian Islands Sectional Chart or other maps or charts that provide sufficiently detailed air tour augmentation (depicting sensitive areas,
4-2 areas that do not offer reasonably safe precautionary landing areas, and other details) in a manner acceptable to the Administrator.
4.1.4 I sland -Specific Weather Complications. Many CHs or operators already have strong and well-considered policies, procedures, and training programs that include weather information and risk mitigating policies and procedures associated with the elements of OpSpec/LOA B048. Such material frequently predates the implementation of this AC or the supported OpSpec. This is not always the case. Where weather complications are not adequately discussed, the CH or operator should enhance the weather information forming the basis of appropriate policy, procedure, and training material to ensure all pilots will be aware of what climatic and local conditions produce reduced ceilings and visibilities, moderate or greater turbulence, etc., where and when these conditions are more likely to be encountered, and why. The objective of OpSpec/LOA B048 is to ensure that all CHs and operators who wish to participate in the benefits of OpSpec/LOA B048 will meet the minimum equipment, policy, procedure, and training that complies with the requirements established within OpSpec/LOA B048. Accepted procedures that preexist any submittal for OpSpec/LOA B048 should not be replicated but should be cited or referenced in the submittal. The CH or operator should describe the climate tendencies of specific areas within each island in which they propose to operate under this authorization while conducting commercial air tour operations.
4.2 R eporting Points, Radio Communications and Frequencies, Use of Aircraft Lights, and ADS-B Procedures. The CH or operator may present the following information in their operating procedures package to the Administrator for acceptance. The information may be presented in a similar manner as described in this AC or in any other manner acceptable to the Administrator.
4.2.1 The CH’s or operator’s commercial air tours operations manual or document should encourage the use of all installed lights, including landing, navigation, and anticollision lights, when operating below 1,500 feet above the surface and their use when operating at and above 1,500 feet above the surface, especially when flying in high density traffic areas such as approaching an initial entry point for a KSSA or while in the flight pattern within a KSSA area.
4.2.2 Consistent radio phraseology procedures should be considered for inclusion in the CH’s or operator’s procedures and should be adhered to. Discrete common traffic advisory frequencies (CTAF) for each island have been established. These facilitate air tour aircraft position and weather reporting and are published on the VFR Hawaiian Islands Sectional Chart. The FAA recommends CHs and operators establish position reports and locations where these reports should be transmitted, as well as common phraseology for weather reports (to include location and adverse weather phenomenon observed). These should be adopted and outlined in each CH or operator procedure manual for each island and for each KSSA where a discrete frequency has been assigned. Air tour operations in KSSAs that experience high density air traffic may benefit from discrete CTAFs to be monitored from before crossing the entry waypoint until after passing the exit waypoint, for weather and traffic reporting while conducting operations in and around the KSSA.
4-3 After passing the exit waypoint, the pilot should select and monitor the published island-specific CTAF.
Note: There are specific procedures for requesting a CTAF. Consult with the Federal Communications Commission (FCC) field office in Honolulu for appropriate procedures.
4.2.3 The CH or operator may also collaborate with other air tour operators to establish and document common procedures for entering, transiting, or exiting a KSSA. Absent any recommended KSSA-specific position reporting point, these procedures should consider including how all pilots will communicate the following in the interest of safety: tail number or ATC accepted call sign, position or area of flight (using cardinal directions and approximate distance from depicted waypoints along the CATFP), altitude, and intentions.
4.2.4 CHs and § 91.147 operators are encouraged to install and operate ADS-B on all air tour flights regardless of the issuance of OpSpec/LOA B048. CHs and operators who have been issued OpSpec B048 must ensure that installed ADS-B In and Out systems are operable and in transmit mode at all times while conducting air tour flights.
4.3 Minimum Flight Altitudes. The CH or operator should present to the Administrator the minimum flight altitudes at which it intends to operate under the authorization, which will not be authorized lower than the following:
• Flights over areas that are neither populated nor congested: No flights will be conducted at any altitude lower than 500 feet above the surface.
• Flights over populated or congested areas, unless operating in compliance with an air traffic control (ATC) clearance: No flights will be conducted at any altitude lower than 1,500 feet above the surface.
Note: Any challenging weather situation that requires descent below 1,500 above the surface to the extent necessary to maintain Class E cloud clearance or to enter Class G airspace below a reduced ceiling is considered significant for the purposes of reporting hazardous meteorological conditions in accordance with part 135, § 135.67 or conditions and limitations in LOA B048. Reporting hazardous weather (that requires an altitude deviation, a course reversal, or a precautionary landing) is secondary to the essential duties of maintaining aircraft control and navigating toward safety. Operators should develop procedures that meet the requirement of reporting hazardous weather conditions in accordance with § 135.67 or OpSpec B048 necessitating a descent deviation below 1,500 feet above the surface should generally be accomplished prior to initiating the descent if time permits. If time is of the essence and a deviation is necessary immediately to ensure the safety of flight, the reporting of hazardous weather should be accomplished as soon as practicable following return to 1,500 feet above the surface or a higher altitude.
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4.4 Procedures for Flight Operations Below 1,500 Feet. The CH or operator should present to the Administrator established communication procedures and actions to be taken by the pilot that explain the manner in which the flight may be continued in the event that there is a need to continue the flight operation at an altitude below 1,500 feet above the surface to avoid entering IMC. The communication procedures should include tail number or ATC-accepted call sign, position or area of flight (using accepted names of areas or cardinal directions and approximate distance from depicted waypoints along the CATFP), altitude, and intentions. The FAA recommends that communication procedures state that use of any unnecessary conversation or “chatter” or both on accepted or published frequencies is highly discouraged while conducting commercial air tours (to include cruise flight through transition areas). The CHs or operators should have established procedures to ensure that the pilots are knowledgeable of the following pilot-in-command (PIC) responsibilities:
4.4.1 If an in-flight deviation necessitates immediate action or deviation from any of the CH’s or operator’s accepted operating procedures, the PIC may deviate to the extent necessary in the interest of the safety of the flight to meet that circumstance.
4.4.2 The PIC of an aircraft is directly responsible for, and is the final authority as to, the safe operation of that aircraft.
4.4.3 In the event the pilot has deviated from the CH’s or operator’s accepted operating procedures or regulatory requirements, the pilot should report the deviation event to the Chief Pilot or designated supervisor within 24 hours of such deviation.
4.4.4 Each person must comply with the requirements of § 91.3 and/or § 135.19, as applicable.
4.5 Weather Minimums for Commercial Air Tour Operations Below 1,500 Feet Above the Surface. The CH or operator should present to the Administrator their weather minimums when conducting commercial air tour operations as part of their operating procedures for acceptance. These weather minimums must not be lower than those set under any regulatory requirement.
4.6 Weather Information and Resources. The CH or operator may present to the Administrator the following weather-related information as part of their operating procedures for acceptance:
4.6.1 Prior to departure on each individual commercial air tour flight, and in addition to any other regulatory requirement, when weather conditions are marginal or available weather information is minimal prior to departure, pilots should obtain updated weather information while en route. En route sources may include Flight Service Stations (FSS), the CH’s or operator’s ground support personnel by discrete 2-way radio frequency or satellite phone, or CTAF reports that are either broadcast or solicited.
4.6.2 When weather conditions are encountered that require a vertical deviation below 1,500 feet above the surface on a CTAFP, the PIC should use their best judgment to safely circumnavigate the weather. OpSpec/LOA B048 authorizes air tours flights in Hawaii to deviate below 1,500 feet above the surface for the sole purpose of remaining in
4-5 VMC. The FAA recommends air tour pilots deviate below 1,500 feet above the surface if a lateral deviation is not possible, to avoid low ceilings and areas of reduced visibility over land (for both airplanes and helicopters below 3 miles) and over water (for airplanes below 3 miles and helicopters below 2 miles) that were not forecast or reported. If visibility deteriorates below these values, and the flight is in rain, the pilot should execute an escape procedure such as changing course toward lower terrain and known improved visibility, descending as needed below 1,500 feet above the surface but not below 500 feet above the surface, and if conditions do not improve, in helicopters, executing a precautionary off-airport landing where possible. If over water, the helicopter pilot should reduce speed and proceed at VMINI toward the closest known area of better visibility conditions accessible without crossing higher terrain and prepare to execute a precautionary off-airport landing on shore or to execute an inadvertent instrument meteorological condition (IIMC) escape procedure. In doing so, the following should be accomplished:
• The pilot should discontinue tour narratives, focus on flying the aircraft toward better weather conditions or making a precautionary off-airport landing.
• Report the hazardous weather condition encountered in compliance with § 135.67 or LOA B048 conditions and limitations (via radio communication with other pilots in the vicinity and ATC/FSS of where and what kind of hazardous meteorological condition was encountered).
• When potentially hazardous meteorological conditions are encountered, reporting those conditions in accordance with § 135.67 is mandatory.
4.7 Unforecast or Unreported Weather Procedures. The CH or operator should include the procedures to be followed when unforecast or unreported weather below the allowable minimums is encountered in their operating procedures and training.
4.8 Safety Risk Analysis. Risk analysis is a multistep process aimed at mitigating the impact of risks on flight operations. Performing risk analysis prior to each flight minimizes the vulnerability of the flight operations and enhances safety.
4.8.1 The CH or operator should present to the Administrator the method(s) they will utilize to analyze, mitigate, and manage risks while conducting commercial air tour operations under the authorization.
4.9 Prohibited Operations. The CH or operator should include a description of their specific prohibited operations, if any. For example, CHs and operators may choose to prohibit special VFR departures. Special VFR departures are not prohibited by § 136.75(d).
However, in the case of a special VFR departure within controlled airspace, if it is not possible to climb unrestricted to 1,500 feet above the surface before leaving the Class D or C airspace and entering the Class E airspace, the air tour flight may not be able to comply with § 136.75(d) and should be postponed. Razorback ridge crossing at or above 300 feet above the surface is no longer permitted; all terrain must be crossed at or above 1,500 feet above the surface. Lateral separation between the aircraft and persons or property is limited to a minimum of 1,500 feet. Lateral separation between the air tour
4-6 aircraft and precipitous terrain is not established by regulation. OpSpec/LOA B048 will recommend CHs and operators to establish a minimum lateral separation between precipitous terrain and the air tour aircraft flight path of not less than 1,500 feet.