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Regulation · July 2026

Part 135 IFR dispatch: the checklist before you issue a flight release

Issuing an IFR flight release is the moment the certificate holder commits to a flight. By the time the release goes out, the person with operational control should have verified a specific list of items — not from memory, but from a checklist that can be reconstructed after the fact. Here is what that checklist contains under Part 135.

1. Crew currency and qualification

Before any IFR release:

  • Instrument currency (135.297): PIC must have logged 6 instrument approaches, holding, and intercepting/tracking in the preceding 6 calendar months. See the instrument currency article for what counts.
  • Medical certificate (135.243): PIC must hold a current second-class medical. The 12-month window from exam date, not the certificate expiry printed on the document.
  • Recurrent training (135.293): PIC must be current on required recurrent training. Check the training record, not just the pilot's statement.
  • Type rating (if applicable): Required for any aircraft over 12,500 lb MTOW or certain turbine-powered aircraft per 61.31.
  • Duty and rest (135.267): Planned flight time plus positioning must not exceed the duty period limit. Prior rest must meet the minimum requirement before the FDP begins.

2. Weather minimums at departure

Under 135.215, no person may begin an IFR flight when current weather reports or forecasts indicate that weather conditions at the departure airport are below the lowest published IFR minimums for that airport — unless an alternate airport is listed in the flight release and that alternate is legal.

The "below minimums at departure" rule catches operators who plan to depart VFR and pick up an IFR clearance in the air. Under Part 135, if conditions are below IFR minimums, you cannot depart even under VFR with the intent to fly IFR unless the alternate requirement is met.

3. Weather minimums at destination

Under 135.219, no person may dispatch an aircraft under IFR unless current weather reports and forecasts indicate that weather conditions at the destination airport will be at or above the lowest applicable IFR minimums for the planned ETA.

The minimums used are the lower of the published minimums or the operator's approved minimums from the OpSpecs. Part 135 operators may have approach minimums listed in OpSpecs that differ from published values — check the OpSpecs, not just the approach plate.

4. Alternate airport requirements

Under 135.223, an alternate is required if current weather reports and forecasts do not indicate that visual approach conditions will exist at the destination at the ETA. The alternate airport must meet its own weather minimums at ETA — not the destination's minimums.

The standard alternate minimums for IFR are 600-2 (precision) or 800-2 (non-precision) unless higher minimums are specified for that airport in the procedures. An alternate with a NOTAM for its ILS out of service during the planned ETA window may not be legally usable as an alternate under precision minimums.

Special alternate minimums (higher than standard) are published in the front of each approach chart booklet. Check these before selecting an alternate.

5. Fuel requirements

Under 135.209, an IFR flight must have enough fuel to fly to the first airport of intended landing, then to the alternate (if required), and then for 45 minutes at normal cruise. This is the regulatory floor — the GOM may require more.

"45 minutes at normal cruise" is not 45 minutes at holding speed or reserve speed — it is cruise speed, which burns more fuel per unit time than a conservative holding calculation. Operators who compute fuel at holding speed to get a favorable calculation are not meeting the standard.

6. NOTAMs and TFRs

Not a regulatory checklist item with a specific citation, but an operational and legal reality: departing into a TFR is a certificate-affecting event. NOTAM review for the departure, route, destination, and alternate must be documented in the flight release package. The PIC's signature on the release constitutes acceptance of the current NOTAM picture.

7. Aircraft airworthiness

Under 135.179 and the MEL, any deferred maintenance items must be reviewed for IFR applicability. Some MEL items that are permissible for VFR are not permissible for IFR (e.g., an inoperative autopilot in certain single-pilot IFR operations). The release must reflect the current deferred-item list and confirm each item is within its repair interval and IFR-legal.

Weight and balance must also be computed for the actual planned payload and fuel load — not a generic W&B from the last flight.

The flight release document

Under 135.63 and 135.83, the flight release (also called a dispatch release for commuter operations) must contain specific information: identification of the flight, departure and destination airports, alternate (if required), type of operation (IFR/VFR), fuel on board, and the signature of the person authorizing the release.

The release is a legal document. It must be kept for 12 calendar months under 135.63. An FSDO investigator can and will pull it after an incident. A complete, accurate release package — with the currency checks, weather analysis, fuel calculation, and NOTAM acknowledgment attached — is the documentation that demonstrates the certificate holder exercised operational control responsibly before that flight departed.

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