Let's say Bob just got his commercial certificate. He decides to have leaflets printed up advertising his willingness to fly other peoples' planes for hire. Bob then goes around to local airports handing out these leaflets. Clearly Bob is holding out. But in the case of these potential revenue generating flights, he does not have operational control over the planes and/or flights. Is Bob breaking the law? Also, would these flights fall under common carriage?


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    $\begingroup$ Substitute the word "resume" for "leaflets". Does that alter your perspective on the question? (Hint: it's perfectly legal to look for a job, it's not legal to start an air charter service without a part 135 operating certificate.) $\endgroup$ Apr 2 at 23:03

1 Answer 1


Yes, this is legal.

Just the act of "holding out" is not against the rules. "Hold out" is a transitive verb; it requires some object, some thing/idea which is being held out.

AC 120-12A lays out what defines a common carrier:

(1) a holding out of a willingness to (2) transport persons or property (3) from place to place (4) for compensation.

Providing transportation as a single package, in exchange for compensation, is the defining characteristic of a common carrier. "I will be flying this aircraft from San Jose to Los Angeles at 10:00 on Sunday morning. Anybody who likes may come with me, if they give me $100." That is what an air carrier does.

If Bob is advertising his services as a pilot and no more, that is not common carriage. "I am a licensed commercial pilot and if you point me toward your aircraft and tell me to fly it to Los Angeles or anywhere else, I will fly it."

Now Bob does have to be careful that he is not accidentally joining in someone else's illegal common carriage scheme, a so-called "134.5" operation in which Bob's employer is selling tickets on a flight—just as an air carrier would—without having the proper air carrier certificate. Even if Bob is simply providing his pilot services to an employer, it would still be his PIC responsibility not to break the law by flying for a 134.5 operation. But if Bob's employer hires Bob to fly their family to their vacation down in Los Angeles that is private carriage.


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