The airplane is required to have 100 hour inspections if used for
rental.

Thought we had killed this myth a long time ago.

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FAA Letter of Interpretation

May 3, 1984

In Reply Refer To: ACE-7
Mr. Perry Rackers
Jefferson City Flying Service
PO Box 330
Jefferson City, Missouri 65101

Dear Mr. Rackers:

This is in reply to your request of May 1, 1984, that we render an
opinion regarding the applicability of the 100-hour inspections
requirement of Section 91.169(b) of the Federal Aviation Regulations
to rental aircraft.

Section 91.169(b) of the Federal Aviation Regulations provides that,
except as noted in Section 91.169(c), a person may not operate an
aircraft carrying any person, other than a crewmember, for hire, and
may not give flight instruction for hire in an aircraft which that
person provides unless, within the previous 100 hours of time in
service, the aircraft has received either an annual or a 100-hour
inspection
..
If a person merely leases or rents an aircraft to another person and
does not provide the pilot, that aircraft is not required by Section
91.169(b) of the Federal Aviation Regulations to have a 100-hour
inspection. As noted above, the 100-hour inspection is required only
when the aircraft is carrying a person for hire, or when a person is
providing flight instruction for hire, in their own aircraft.

If there are any questions, please advise us.

Sincerely,
/s/
Joseph T. Brennan
Associate Regional Counsel.