Here is a question I received this morning regarding required equipment for over water flights:
I’d like to fly to the Florida Keys. Of course, we all know the FAR about flying high enough to get to land power off. I can’t find the rule about flying over water and what the requirements are for equipment. Can you help? I did find a bit about it in the ATP section but what applies to private? I know people fly it all the time and just want to be on the right side of this. Thanks.
Thanks for the question. The funny thing is that I asked myself this exact same question this past week when preparing for an upcoming trip. I know that airline and charter operations are governed by regulations in 14 CFR 121 and 135. But where do the regulations say specficially what equipment is required to be on board for overwater flights for flights operated under 14 CFR 91?
The two most common quoted regulations for over water equipment requirements are 91.205 and 91.509. 91.205 states that:
If the aircraft is operated for hire over water and beyond power-off gliding distance from shore, approved flotation gear readily available to each occupant and…at least one pyrotechnic signaling device.
91.509 which is titled, “Survival equipment for overwater operations.” has similar requirements. Paragraph (a) & (b) says:
(a) No person may take off an airplane for a flight over water more than 50 nautical miles from the nearest shore unless that airplane is equipped with a life preserver or an approved flotation means for each occupant of the airplane. (b) No person may take off an airplane for flight over water more than 30 minutes flying time or 100 nautical miles from the nearest shore, whichever is less, unless it has on board the following survival equipment: (it then goes on to list the equipment)
Here’s the interesting thing though. FAR 91.205 (b)  applies only to “for hire” operations and FAR 91.509 falls under 14 CFR 91 subpart F which is for large (over 12,500 lb) and turbine-powered multiengine airplanes and fractional ownership programs. I am honestly having a hard time finding a federal aviation regulation that mandates any kind of required survival equipment to be on board for over water operations if you are in a small airplane (12,500 lbs or less) not operating for hire. I specified FAA reg. because I know that certain states like Alaska mandate certain survival equipment to be on board at all times. Also certain countries, like the Bahamas, mandate flotation devices to be on board for over water flights as well.
So what it is a prudent and safe pilot to do?
If the regulation requires for hire operations and turbine powered airplanes to have flotation gear than I think it would be wise to operate your aircraft in a similar manner. Although purchasing a flotation device for each passenger may seem costly, it would be a small price to pay in the unfortunate event that you would need them. If you are worried about the cost and don’t fly in an area where you would utilize them that often, you can also consider renting them. I know a lot of FBO’s in south Florida offer over water survival kits, including personal flotation devices or life rafts for rent. If you are planning a fuel stop at a particular airport I would inquire about the availability and cost of renting this equipment. If you are considering purchasing any kind of over water survival equipment, one of the go-to-places for many operators is Eastern Aero Marine out of Miami, Florida. They have been in business since 1952, so they know a thing or two about the business. You can visit their website at http://www.theraft.com. They also have developed a nice table where you can see what equipment is required to be on board for your particular operation. The required equipment table covers everything from small airplanes to transport category aircraft in an airline operation.
Again, excellent question and let me know what you decide to do. My best advice for you would be to…
Fly Safe (and prepared).