Can a commercial pilot perform non-stop air tour operations under part 91 within 25SM of the airport using a rental airplane from the FBO?

I noticed that in the LOA application, the operation needs to provide:

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

I wonder if this has to be the operator's own aircraft?

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    $\begingroup$ Welcome to aviation.SE! $\endgroup$
    – Pondlife
    May 5, 2019 at 4:15

1 Answer 1


Beyond the aviation angle of this question there are legal liability and insurance concerns common to any business that ought to be addressed. Any person renting equipment ostensibly for personal use, but in reality is using it to run a business on the side, ought to have a commercial lease agreement in place with the owner of the equipment. Have you spoken with the FBO about your plans?

Regarding aviation specifics, these sort of questions have come up before and the CFRs don't offer much in the way of ownership requirements for aircraft involved in commercial operations. Own vs lease just doesn't seem too critical from an operational standpoint as far as the Feds are concerned. I won't start another "holding out" discussion here, but you should definitely talk to the FBO about your plans before moving forward with this idea.

  • $\begingroup$ Your points about insurance etc. are spot on. Non-stop air tours within 25SM can be done under part 91, however. They're one of the exceptions in 119.1(e) that don't require an air carrier certificate. They're still a commercial operation, though. $\endgroup$
    – Pondlife
    May 5, 2019 at 17:34
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    $\begingroup$ Thanks for pointing that out Pondlife, I guess I could benefit from my own advice regarding getting into the FARs! I will edit... $\endgroup$ May 5, 2019 at 21:28

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