"Gary Drescher" wrote in message news:KE7Wb.271797$xy6.1381578@attbi_s02...

Brian, could you elaborate, please? I just re-read 119.1 and could not find
any statement restricting freight ops to commercial operators.

Well, the first half of the very first sentence says that the entire
Part 119 applies to this situation. 119.1(a) and 119.1(a)(1).

119.1 Applicability: (a) This part applies to each person operating or
intending to operate a civil aircraft (1) as an air carrier or
commercial operator, or both, in air commerce[.]

The operation described is that of a direct air carrier and commercial
operator, so this part applies. To see how it applies, just read the
rest of part 119.