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Old February 24th 04, 11:16 PM
Gary Drescher
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"Robert M. Gary" wrote in message
om...
"Gary Drescher" wrote in message

news:yjK_b.113497$jk2.502928@attbi_s53...
"Dennis O'Connor" wrote in message
...
This gets hashed over about every six months...
Basically, a commercial ticket gives you the right to fly for pay, P E

R I
O
D...
It does not give you the right to hold out as an air taxi service by
providing aircraft...


Even in the case of specified part-119 exceptions, such as aerial
photography and local sightseeing?



No, you're fine if you are just doing local sightseeing. AOPA is
working to ensure this doesn't change. Make sure your insurance is ok
for sightseeing and your class 2 medical is good to go. Its common for
flight schools to sell photography flights.


Sure, but flight schools are licensed operators; I'm not. So there seems to
be disagreement here as to whether a non-operator commercial pilot can do
this. And the relevant FARs appear to be gibberish, so I'm still uncertain
as to what the answer is in practice.

For instance, according to FAR 1.1, to be considered a "commercial
operator", you have to be engaged in "air commerce". But according to 1.1,
to be considered "air commerce", your activity has to be interstate,
international, on Federal airways, or involving mail delivery. Otherwise,
no "air commerce", hence no "commercial operator". But part 119 only
applies to "commercial operators" as defined in 1.1. And parts 121 and 135
only apply to those to whom part 119 applies--except for local sightseeing
flights, which part 135 addresses even when part 119 doesn't apply. So as
long as you stay in one state, avoid Federal airways, don't deliver mail,
and don't do local sightseeing flights (but long-range sightseeing is ok!),
nothing in 119, 121, or 135 is applicable. That can't be what the FAA
meant, but it's what they've written.

--Gary