AC 136-5

Advisory circular · Enhanced Flight Following Center (EFFC) for Commercial Air Tour Operators

Approved
January 23, 2026
Last reviewed
February 2, 2026
Family
AC 136-5 · 1 version
14 CFR parts
61, 91, 119, 120, 135, 136

Guidance, not mandatory unless a rule or AD requires it. DRS record last changed February 2, 2026.

Show pages 1–11

3-1 CHAPTER 3. OPERATIONS CONTROL SPECIALIST (OCS) DUTIES AND

RESPONSIBILITIES

3.1 OCS Duties and Responsibilities. Each commercial air tour operator should describe in their General Operations Manual (GOM) or other FAA-accepted document the duties and responsibilities of an OCS. This includes preflight risk mitigation strategies, risk control measures, and the use of a shift change checklist. The level of operational control authority delegated to the OCS should be clearly defined in the commercial air tour operator’s GOM (for 14 CFR part 119 certificate holders (CH)) or described in Operations Specifications (OpSpec) A008, Operational Control, if applicable. Operators must also ensure that each person authorized to exercise operational control are listed in the GOM in accordance with 14 CFR § 135.23(a). The minimum duties of an OCS should include:

3.1.1 Operational Control. The commercial air tour operator should authorize each OCS to exercise operational control, directing the pilot to decline, divert, abort, or reroute the flight. The OCS should not provide opinions to the pilot suggesting that a flight can be initiated or completed when weather is a factor. Likewise, in the opinion of the pilot, whenever a flight should not be initiated or continued due to weather or other safety factors, the OCS should not suggest or direct otherwise.

Note: One principle employed by several operators is the OCS should follow the “advise, suggest, direct” concept, advising the pilot of any potential hazards along proposed routes, suggesting possible mitigation strategies, and, if needed directing the commercial air tour pilot to decline, divert, or terminate the flight.

3.1.2 Communications. Ideally, the OCS should communicate directly with the commercial air tour pilot via radio or other means to provide weather advisories and notifications of other factors affecting the overall safety of the flight. If direct communication is not possible between the OCS and pilots, a secondary means through a communications center staffed by trained communications specialist (CS), should be available. These procedures should be incorporated into the CH’s GOM or other written standard operating procedure (SOP). If communications between the air tour pilot and OCS are expected and there is a loss of communication, the operator should be prepared to activate the Accident/Incident Plan (AIP).

3.1.3 Weather Reporting. The OCS may provide pilots with weather briefings, to include current and forecasted weather along the planned route of flight. While the OCS may obtain weather from non-National Weather Service (NWS)/FAA weather sources to aid in situational awareness, only information derived from the NWS or other FAA-approved sources will be used in making “go” decisions. However, any weather source that is relevant to the safety of flight should be used for advisories as a flight progresses. This information may be relayed to the pilot by an appropriately trained OCS.

3.1.4 Monitor the Progress of the Flight. The OCS should monitor the progress of each commercial air tour flight. This may be accomplished through a variety of means, including satellite tracking, position reports, etc. Weather conditions in the area(s) of

3-2 operation should be monitored, and methods communicating adverse or forecast deteriorating weather conditions to the pilot should be established. In the event the OCS cannot directly monitor a flight’s progress via satellite or other graphic means, commercial air tour operators should have established procedures for monitoring the flight via position reports or other means.

3.1.5 Preflight Risk Analysis. EFFC personnel/pilots should be trained in basic risk analysis, with the ability to stop or terminate a flight as risk dictates. The analysis is ongoing as flights progress and conditions change. If the risk level increases as the day/flight progresses, the appropriate higher risk approval authority should be immediately notified to approve, mitigate, or terminate continued operations.

3.1.6 Risk Analysis. Risk analysis is a continuous and iterative process encompassing risk assessment, mitigation, and reassessment. The risk assessment phase is a key element within the broader risk analysis process. This involves identifying hazards, calculating the probability of their occurrence, and determining the likely severity of outcomes should a hazard occur.

3.1.7 Risk Mitigation. Risk mitigation and its effectiveness in reducing risk is an essential component of the risk analysis program. In cases where the risk assessment rates a particular risk element as high, preplanned, and preapproved mitigations may be advisable. Risk mitigations should not be improvised at the time of need to prevent unintended consequences. Following application of effective mitigation measures, both individual and total residual risk factors should be reassessed. This risk mitigation/reassessment cycle should be repeated until all higher risks are effectively mitigated.

3.1.8 Risk Threshold. Each individual risk element is evaluated against the operator’s predetermined risk threshold and aggregated into a total risk score after applying approved mitigation strategies. This total risk is then compared to the operator’s predetermined aggregate threshold. If the final aggregate residual risk or individual risk elements or both exceed the operator’s predetermined thresholds, a higher level of operator management approval (above the OCS) should be sought. If this approval cannot be obtained, the flight should be declined.

3.1.9 Participation of Personnel. The OCS should participate in preflight risk analysis, providing essential preflight information and should limit their approval to low-risk scenarios, typically routine commercial air tour flights with minimal risk. Unmitigated risks above the low level should be forwarded to upper-level management (e.g., Director of Operations (DO), Chief Pilot, etc.) for consideration in accordance with company procedures.

3.1.9.1 The OCS should ensure the pilot completes all items on the operator’s preflight risk analysis worksheet. Procedures for determining the minimum items for the risk analysis should be clearly outlined in the operator’s risk analysis program.

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3.1.9.2 The OCS should verify the pilot’s completion of all items on the preflight risk analysis worksheet. Additionally, they should assist the pilot in mitigating any identified risks prior to takeoff. If communication systems are available and maintained, the OCS can provide real-time information during flights in case of unexpected changes in conditions.

3.1.9.3 Risk mitigation strategies offered by the OCS should be presented as validated options previously endorsed by the operator. Ad hoc risks mitigation may lead to unintended consequences. It’s important to note that the PIC ultimately decides the acceptability of the recommended risk mitigation strategies.

Conversely, the OCS should assess mitigation strategies proposed by the PIC and have the authority to direct the PIC to decline or abort a flight if, in their opinion, the proposed risk mitigation is inadequate, inappropriate, or if the residual risk remains excessive.

3.1.9.4 Operators are encouraged to document the use of mitigation strategies and their impact on the safe conduct of a flight.

3.1.9.5 The air tour operator should establish a procedure for OCS acknowledgment in writing, specifying the accurate completion date and time of the preflight risk analysis worksheet. According to the OCS’s professional judgment, this documentation should confirm that the flight can be conducted safely.

3.1.9.6 The method of acknowledgement may vary as specified by the commercial air tour operator in their risk analysis program. This acknowledgement can be on the same risk analysis worksheet completed by the PIC or on a separate record. The record needs to include the acknowledgement date and time, sufficient information to identify the PIC, the flight date, the flight route details, confirmation of accurate completion of the preflight analysis worksheet, and the OCS’s professional judgment that the flight may be conducted safely, along with any other information deemed appropriate by the CH. The method of acknowledgement may be in writing, electronic, etc., as specified in the risk analysis program.

3.1.9.7 When, in their professional opinion, the OCS cannot concur that a flight can be conducted safely, the OCS should direct the PIC not to accept the flight. If the OCS observes changes in the risk analysis factors during a commercial air tour operation, the OCS should advise the PIC, recommend possible mitigation strategies, and, if the risk becomes unacceptable, direct the PIC to divert or abort the flight. This OCS authority should be documented in the CH’s or operator’s risk analysis program and GOM or other FAA-accepted document, as applicable.

Note: Chapter 7, Risk Analysis Tool, provides additional information related to the purpose, suggested use, of a risk analysis tool, and an example of a risk assessment matrix.

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3.1.10 Emergency Assistance Capabilities. The OCS plays an important role in providing emergency assistance to PICs during emergency situations, such as an encounter with inadvertent instrument meteorological conditions (IIMC), if equipped with advanced communication technology. Two-way communication systems have the potential to enhance situational awareness, preventing unknown IIMC encounters for the pilot. In many circumstances, the OCS may observe the aircraft’s position and maintain communication with the PIC when the aircraft is below air traffic control (ATC) radar and communications coverage. Under these circumstances:

3.1.10.1 The OCS may need to relay crucial information to ATC regarding an aircraft declaring an emergency and the pilot’s intentions.

3.1.10.2 Additional communication resources enable active OCS personnel to deliver accurate weather information or route recommendations to airborne aircraft.

This capability is important and crucial for a commercial air tour to avoid or navigate away from severe or deteriorating weather conditions. In certain situations, the OCS may be the only means by which the PIC can receive accurate weather information or route recommendations to escape severe or deteriorating weather conditions.

Note: The utilization of advanced communication technology by the OCS can significantly contribute to the overall safety of the flight, providing timely and critical information to the PIC, especially in emergency scenarios. The OCS’s ability to relay information to ATC and offer real-time guidance enhances the operational response and decision-making capabilities during unforeseen events, ultimately ensuring the well-being of the flight and its passengers.

3.2 OCS Shift Change and Relief Procedures. Commercial air tour operators should develop a shift change and relief checklists for use by OCS personnel during shift changes. Procedures for briefing the incoming OCS on ongoing and upcoming commercial air tour operations should be developed, documented, and regularly trained.

The shift change checklist should, at a minimum, encompass the following:

• Active ongoing commercial air tour operations.

• Weather affecting possible flight areas.

• Temporary flight restrictions (TFR).

• Technology anomalies to include “COMMUNICATION” and “INTERNET” status.

• New flight operations policies, manual changes, etc., that have taken effect since the last shift for an oncoming OCS.

Note: Refer to AC 120-96, Operations Control Center (OCC) for Helicopter Air Ambulance (HAA) Operations, for additional OCS shift change procedures.

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3.3 OCS Interfaces. Some commercial air tour operators may view it as a best practice for the OCS to transmit routine, noncritical information to the PIC through the communications center. This practice ensures that all involved parties (OCC, pilot, and any other EFFC personnel) are aware of information being provided and potential route deviations resulting from OCS suggestions or direction. Refer to AC 120-96, Chapter 3, Paragraph 3.2, OCS Shift Change/Relief Procedures, for additional information.

3.3.1 Direct Communications. In cases where the OCS is performing tasks such as those listed in 14 CFR § 135.619(a) and needs information from or intends to pass information to the pilot, the OCS will normally communicate directly with the PIC. This direct communications link is crucial, especially in time-critical situations or when technical discourse is necessary to reach a consensus position regarding risk analysis or weather options. It is recommended that the OCS promptly informs the communications center of the nature of the communication and any potential impacts on the commercial air tour operation as soon as it becomes feasible.

3.3.2 Non-Normal Event. The EFFC should be notified by all employees or personnel any time they are made aware of an out-of-the-ordinary event during a commercial air tour flight.

Such events include diversions, precautionary landings, or any occurrences deemed appropriate by the operator. These notification processes should be thoroughly documented in the operator’s GOM or any other accepted document or SOP. This documentation ensures a comprehensive record of non-normal events and supports subsequent analysis and improvement of operational procedures.

Note: The primary interface between the OCS and the PIC tour operations occurs primarily before the commercial air tour flight and at the termination of the flight.

Direct communication during any portion of the flight between the EFFC/OCS should be limited to matters related to the safety of the flight.

3.4 Accident/Incident Procedures. Procedures for the OCS to follow in the event of an overdue aircraft, or if an aircraft is known to have been involved in an accident or incident, should be thoroughly documented in the GOM or SOP. These procedures should include steps for notifying appropriate company personnel, as well as emergency medical services (EMS), fire, and police, if necessary, in the area where the aircraft is believed to be located. It is recommended that the OCS maintain a comprehensive listing of all EMS, fire, and police dispatch centers, along with their phone numbers for the areas where commercial air tour operations are typically conducted at the OCS workstation.

3.4.1 Task Delegation. The OCS may delegate some tasks related to the Post-Accident/Incident Plan (PAIP) to other EFFC personnel. If this delegation occurs, it should be noted in the PAIP documentation.

3.4.2 Overdue Aircraft. See Appendix B, Diagrams and Examples, for an overdue aircraft flowchart example to supplement GOM accident notification procedures.

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3.4.3 Human Factors. Operators should also consider the human factors associated with OCS staff involvement in risk analysis or other activities preceding an accident or incident and the impact of this involvement on the OCS’s ability to effectively continue in their duties.

3.4.4 OCS Involved With an Accident/Incident. In the event that an OCS involved with a flight

(e.g., having concurred with and signed off a personal Flight Risk Assessment Tool (FRAT), advised a pilot of inclement weather, or directed a diversion) subsequently experiences an accident or incident, it is recommended that the OCS be temporarily relieved of duty. The operator may choose to establish a policy ensuring that the individual receives adequate debriefing, appropriate counseling, and sufficient time to resolve the psychological trauma associated with peripherally involved in an accident or incident. The manager responsible for EFFC operations should review the OCS’s fitness for duty before authorizing the return of the OCS to their duties.

4-1 CHAPTER 4. OPERATIONS CONTROL SPECIALIST (OCS) TRAINING

4.1 Training General. Although not required by regulation for commercial air tour operations conducted under either 14 CFR part 91 or 135, commercial air tour OCS personnel should be trained in accordance with a training program established by the operator. Ideally, OCS personnel should be pilots experienced in commercial air tour operations.

4.1.1 Initial Training. Prior to performing the duties of an OCS, each individual should satisfactorily complete the commercial air tour operator’s OCS initial training program.

Documentation of initial OCS training documents should be maintained and retained for the entire duration of their employment and 90 days thereafter.

4.1.2 Recurrent Training. After completing initial training satisfactorily, each OCS should complete recurrent training every 12 months, focusing on the topics outlined in the operator’s training program. It is recommended to maintain and retain documentation of recurrent training for a minimum of 12 months unless superseded by more recent training.

4.2 Training Subjects. The recommendations below serve as a guide for developing commercial air tour OCS training.

4.2.1 Training Elements. In conjunction with initial classroom or computer-based training, OCS candidates should pass an operator-specific knowledge test. Initial training may adopt a scenario-based approach, incorporating one-on-one supervised sessions or coached on-the-job training (OJT), or both, leading to the operator-specific practical test.

Throughout OJT, the OCS instructor should be cognizant of and responsible and accountable for all actions undertaken by the OCS candidate under their direct and continuous supervision. Recurrent training should include periodic abnormal/emergency procedures drills, and both training and testing should be completed before the end of the twelfth calendar month since the last test was conducted.

4.2.2 Instructors. Individuals authorized by the commercial air tour operator to facilitate OCS training and testing should possess experience as OCS personnel or be individuals recognized as suitable and knowledgeable by the commercial air tour operator. Initial OJT should be conducted by specifically designated and current OCS trainers, and this authorization should be outlined by position or individual name in the OCS training program.

4.2.3 Training Hours. The training program should allocate sufficient hours of instruction to comprehensively cover the topics specified within the training program. One approach to determining necessary training hours for various topics may be conducting a knowledge assessment by the prospective OCS. This assessment can gauge the prospective OCS’s depth of knowledge in various areas, and the results may inform the appropriate allocation of training hours to ensure a thorough understanding across all subject areas.

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4.3 Training Topics. The OCS training program should cover the following topics:

4.3.1 Operations Control Specialist (OCS).

• Duties and responsibilities.

• Operational control, concepts, and definition.

4.3.2 Aviation Weather.

• General meteorology.

• Prevailing weather.

• Adverse and deteriorating weather.

• Wind shear.

• Use of aviation weather products available to the operator.

• Cue-based weather training.

• Available sources of information.

• Weather minimums (see Figure 7-1, Risk Assessment Matrix Reflecting Quantification of Factors).

4.3.3 Navigation.

• Navigational Aids (NAVAID).

• Instrument approach procedures (IAP).

• Navigational publications.

• Navigation techniques.

4.3.4 Flight Monitoring.

• Maps/charts.

• Operators commercial air tour routes.

• Local points of interest and checkpoints on navigational publications.

• Local area hazards.

• Primary flight monitoring procedures (specific to operator as per General Operations Manual (GOM)/standard operating procedure (SOP)).

• Alternate flight monitoring procedures (if applicable).

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4.3.5 Air Traffic Control (ATC).

• Airspace.

• ATC procedures.

• Aeronautical charts.

• Aeronautical data sources.

• ATC basic information.

• Who they are and what they do.

• How to contact local ATC in case of an emergency or loss of communication with a pilot.

4.3.6 Aviation Communication.

• Available aircraft communications systems (e.g., very high frequency (VHF), satellite capable, etc.).

• Operator-specific capabilities and what they can do.

• Limitations of aircraft communication.

• Areas of line-of-sight communication.

• Areas without line-of-sight communication.

• Other sources of communication.

• Relayed communication.

• Normal communication procedures.

• Abnormal communications procedures.

• Emergency/alternate communication procedures.

4.3.7 Aircraft Systems. The operation should consider that specific aircraft limitations may require increased levels of operational control, with considerations tailored to each aircraft in a nonstandardized fleet. In other words, less-equipped aircraft necessitate more meticulous management. The following are suggested topics for OCS personnel. It is important to note that this information is presented at a basic level suitable for the operation of commercial air tours.

• Communications systems (company aircraft capabilities, see paragraph 4.3.6 above).

• Navigation systems.

• Surveillance systems.

• Specialized systems (if applicable).

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• General maintenance.

• Minimum equipment lists (MEL) (if applicable).

4.3.8 Aircraft Limitations and Performance.

• Aircraft operational limitations.

• Aircraft performance and performance plans.

• Landing zone (LZ) and landing facility.

• Suitable diversion airports or landing facilities based on landing performance requirements.

4.3.9 Aviation Policy and Regulations.

• Title 14 CFR parts 61, 91, 135, and 136 (pertinent sections).

• Title 49 of the Code of Federal Regulations (49 CFR) part 830.

• Company operations specifications (OpSpecs).

• Company general operations policies.

• Enhanced operational control policies.

• Aeronautical decision making and risk management.

• Lost aircraft procedures.

• Emergency and search and rescue procedures, including plotting coordinates in degrees/minutes/seconds format and degrees/decimal/minutes format.

4.3.10 Crew Resource Management (CRM).

• Concepts and practical application (e.g., working as a team and flight ownership).

• Risk management and risk mitigation.

• Preflight risk analysis procedures.

• How to assist pilot with risk assessment form.

• How to evaluate a risk assessment form.

4.3.11 Area of Operations for Commercial Air Tours. Familiarity with information appropriate to the OCS position pertaining to local geographical features:

• Terrain features.

• Obstructions (e.g., wires, buildings, etc.).

• Weather phenomena for local area.

• Airspace and ATC facilities (sterile cockpit situations).

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• Heliports, airports, LZs, and fuel facilities.

• Instrument approaches (if applicable).

• Predominant air traffic flow.

• Landmarks and cultural features, including areas prone to flat-light, whiteout, and brownout conditions.

• Local aviation and safety resources and contact information. Areas that lack communication should be well-identified.

4.4 Methods of Instructional Delivery. The method of instructional delivery is at the discretion of the operator. Although classroom instruction is a preferred method for many topics, some may deem it more suitable to conduct training on some subject areas through computer-based training or a similar method.

4.4.1 Initial Training. The operator should develop a tailored training program for its OCS personnel. All newly appointed OCS personnel should successfully complete this training before assuming the duties within an EFFC.

4.4.2 On-the-Job Training (OJT). OJT can serve as a continuation of the training, reinforcing learning to ensure a comprehensive understanding. Topics established for OJT should be clearly identified in the commercial air tour operator’s OCS training program. Newly trained OCS personnel are highly recommended to work under the supervision of an experienced OCS (or other qualified personnel) for a specified period after completing the initial training.

4.4.3 Recurrent Training. Commercial air tour operators may utilize ongoing training for OCS personnel, such as annual training modules incorporating abnormal/emergency procedures drills. Alternatively, training could occur quarterly, provided the operator meets preplanned hours and topics within a fixed 12-month training period. Training should be tailored to the operator’s capabilities and documented at least annually.

4.4.4 Testing. OCS should pass a knowledge and practical tests administered by the commercial air tour operator. For 14 CFR part 119 certificate holders (CH), the testing should be inclusive of the CH’s approved training program. The operator is responsible for developing the knowledge and practical tests, covering all topics taught during the initial and recurrent training.

4.4.5 Failure to Complete Recurrent Training. If an OCS candidate fails to satisfactorily complete recurrent training and testing within the preceding 12 months, the air tour operator should not allow the individual to perform OCS duties until the training and testing are completed. Due to the criticality of the OCS position, there should be no provision for a grace period. Requalification following a lapse can be achieved by satisfactorily completing recurrent training and testing, with the duration of the lapse determined by the commercial air tour operator.

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4.4.6 Retesting. It is recommended that an individual achieve a minimum score of 80 percent in any initial or recurrent OCS testing, with the test subsequently corrected to 100 percent through a focused review with the OCS instructor for each missed element. In the case of a test failure (scoring below 80 percent), the OCS retest should be preceded by retraining in the subject areas where failure occurred, covering all topics from the initial or recurrent training, as applicable. If an operator administers a retest after an initial failure, it is recommended to use a different version of the test. The knowledge test should be satisfactorily completed and corrected to 100 percent before proceeding to the practical test. While failure of the practical test does not necessitate a reapplication of the knowledge test, a subsequent failure in a practical retest indicates a significant knowledge deficiency. Therefore, it is recommended that the individual undergo requalification training and retesting.

4.4.7 Test Formats. The knowledge test may take the form of oral, written, or a combination of both, and it should be completed before the practical portion of the test. The practical segment of the test should evaluate the real-time application of all OCS procedures, including the utilization of all regularly available and used equipment, computer programs, and other technology employed by the OCS, with special emphasis on new technology and areas of previously identified systemic issues. The chosen method(s) of testing by the commercial air tour operator should be documented in the approved training program (for 14 CFR part 119 CHs), or a similar document for 14 CFR part 91 commercial air tour operators.

4.4.8 Annual Recurrent Testing. CHs should outline OCS training and testing procedures in their GOM or approved OCS training program. Procedures for retesting after failure and requalification training following an extended absence should be described. As there is no regulatory requirement for requalification training and testing, the operator may define the term beyond which requalification is necessary, considering the need for additional training to achieve requalification. Minimum test scores (80 percent recommended) and procedures for correcting tests to 100 percent should be detailed in the OCS training program.

4.5 Training Records. Commercial air tour operators should maintain a training record for each OCS throughout the duration of their employment and for an indefinite period thereafter. The training record should include a chronological log for each training course, detailing the number of training hours and the examination dates and results.

These records may be stored in paper form or electronically at the discretion of the commercial air tour operator.