When I retire in a couple years I want to fly my 172 and make some money. Even if I just break even that's ok. My CFI certificate has expired and I don't want the hassle of having it re-instated. I do have a commercial pilot license.

What would it take to give "scenic airplane rides" legally (so I have insurance). I read far 91.147 but it says nothing about the airplane itself.

  • 3
    $\begingroup$ Are you talking about working FOR a Part 135 operation, or BEING a Part 135 operation? $\endgroup$
    – Ralph J
    Apr 19, 2015 at 0:03
  • 2
    $\begingroup$ @RalphJ, limited sightseeing flights are possible outside 135 (under 91.147). aopa.org/Advocacy/Regulatory-,-a-,-Certification-Policy/… $\endgroup$
    – BowlOfRed
    Apr 19, 2015 at 4:49
  • 1
    $\begingroup$ I think this would fall under 119 1(e)(2) for the aircraft. $\endgroup$
    – BowlOfRed
    Apr 19, 2015 at 5:02
  • $\begingroup$ We are not lawyers. This is not legal advice. Etc., etc. $\endgroup$ Apr 20, 2015 at 21:27

2 Answers 2


It needs to be airworthy, as per 91.403, which is defined to include compliance with all ADs:

(c) No person may operate an aircraft for which a manufacturer's maintenance manual or instructions for continued airworthiness has been issued that contains an airworthiness limitations section unless the mandatory replacement times, inspection intervals, and related procedures specified in that section or alternative inspection intervals and related procedures set forth in an operations specification approved by the Administrator under part 121 or 135 of this chapter or in accordance with an inspection program approved under § 91.409(e) have been complied with.

It needs a 100-hour, as per 91.409:

(b) Except as provided in paragraph (c) of this section, no person may operate an aircraft carrying any person (other than a crewmember) for hire ... unless within the preceding 100 hours of time in service the aircraft has received an annual or 100-hour inspection and been approved for return to service in accordance with part 43 of this chapter or has received an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. The 100-hour limitation may be exceeded by not more than 10 hours while en route to reach a place where the inspection can be done. The excess time used to reach a place where the inspection can be done must be included in computing the next 100 hours of time in service. (source: 14 CFR Part 91.409).

Part 43 Appendix D specifies the items which need to be checked in the 100-hour inspection.

And it needs to have all the other necessary mechanic's inspections, including ELT, transponder/pitot static system, etc., and pilot checks, like VOR accuracy.


It would have to be completely in compliance with ADs and if you are going over 25sm from your base airport or doing any true charter work you need a Part 135 AOC and have to be in compliance with the Part 135 regs. You can get a single pilot operator certificate for one pilot and one plane. You also would need to comply with Part 136 which regulates air tours.

Things you would have to do are brief passengers on safety features of the aircraft and provide life jackets (if flying over water). You also need permission to fly over national parks.

136.37 A commercial air tour operator may not conduct commercial air tour operations over a national park or tribal land except

(1) In accordance with this section;

(2) In accordance with conditions and limitations prescribed for that operator by the Administrator; and

(3) In accordance with any applicable air tour management plan for the park or tribal lands

   (b) Application for operating authority. Before commencing commercial air tour operations over a national park or tribal lands, a commercial air tour operator shall apply to the Administrator for authority to conduct the operations over the park or tribal land

If you are approved you may be subject to a limited number of tours over the area.

If you are keeping it under Part 91, with in 25sm, you will need a letter of authorization from your FSDO.

Regulations for Part 91
§91.147 Passenger carrying flights for compensation or hire.
Each Operator conducting passenger-carrying flights for compensation or hire must meet the following requirements unless all flights are conducted under §91.146.

(a) For the purposes of this section and for drug and alcohol testing, Operator means any person conducting nonstop passenger-carrying flights in an airplane or helicopter for compensation or hire in accordance with §§119.1(e)(2), 135.1(a)(5), or 121.1(d), of this chapter that begin and end at the same airport and are conducted within a 25-statute mile radius of that airport.

(b) An Operator must comply with the safety provisions of Part 136, subpart A of this chapter, and apply for and receive a Letter of Authorization from the Flight Standards District Office nearest to its principal place of business.

(c) Each application for a Letter of Authorization must include the following information:

   (1) Name of Operator, agent, and any d/b/a (doing-business-as) under which that Operator does business;

   (2) Principal business address and mailing address;

   (3) Principal place of business (if different from business address);

   (4) Name of person responsible for management of the business;

   (5) Name of person responsible for aircraft maintenance;

   (6) Type of aircraft, registration number(s), and make/model/series; and

   (7) An Antidrug and Alcohol Misuse Prevention Program registration.

      (d) The Operator must register and implement its drug and alcohol testing programs in accordance with Part 120 of this chapter.

      (e) The Operator must comply with the provisions of the Letter of Authorization received.

I would assume that the aircraft would have to comply with Part 91 requirements. If in doubt ask your local FSDO.



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