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If I own a plane, say a Piper arrow, and I want to charge 175/hr for the aircraft and 50/hr for instruction, is there any regulation on when to perform engine overhauls (TBO)?

askacfi.com and avweb.com indicate no TBO requirements.

However, 14 CFR Subchapter G - Air Carriers and Operators for Compensation or Hire: Certification and Operations may indicate I do.

What specific regulations show what is or is not required?

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    $\begingroup$ Related $\endgroup$ – Dave May 4 at 14:21
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    $\begingroup$ Your title and question body are a little different, so I'm not sure what you're asking. Are you asking if flight instruction and rental require an operating certificate per Part 119; or are you asking if aircraft used for flight instruction require a 100hr inspection? $\endgroup$ – Pondlife May 4 at 16:24
  • $\begingroup$ You are correct. I am aware of the ref'd 91.409. I'm looking on the proof / reg of TBO reqs. Thanks $\endgroup$ – chup May 4 at 17:27
  • $\begingroup$ Thanks, I reworded your question a little. If I got it wrong then of course just roll back or edit again. You might also like to quote the specific 119 regulation that suggests a specific TBO requirement. But as a general comment, regulations typically say "X is required", not "X is not required". ACs, legal interpretations and other FAA docs might say something like that, though. $\endgroup$ – Pondlife May 4 at 18:51
  • $\begingroup$ Maybe just add part 91 to the title? I wish I could add any tbo requirement. I can't find any. just rumors of them. The following is my likely incorrect "ref" on "for hire" and "Commercial Operators" A CFI is a "commercial" Pilot Subchapter G Air Carriers and Operators for Compensation or Hire: Certification and Operations Contains Part 119 View Table of Contents for Part 119 Certification: Air Carriers and Commercial Operators $\endgroup$ – chup May 4 at 19:52
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§91.409 Inspections. (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, and no person may give flight instruction for hire in an aircraft which that person provides, unless within the preceding 100 hours of time in service the aircraft has received an annual or 100-hour inspection…

You can rent out your airplane without complying with 100 hour inspections provided that you don’t provide both the pilot and the airplane. Insurance will be a lot more, probably 3-4 times as much. If you are renting it out you might have more than 100 hours in a year so you need to make sure you comply with 100 hour ADs.

I do it with my Cherokee from time to time when I know people who want to learn to fly. The students can use any CFI they want and pay them separately from renting. Depending on how many people want to learn, I have an open pilot policy with only some CFIs and me as named insureds or if there are only a few students, everyone is a named insured.

Edit: The only maintenance requirement for Part 91 operators is 91.409 discussed above. TBO is not specifically mentioned in the FARs so you won’t find a rule saying that you don’t have to comply with manufacturer’s TBOs. I have a folder of 116 Legal Interpretations and NTSB opinions. A search of them finds no mentions of TBOs.

As you point out there are lots of articles that mention it. I'd trust them. This AVWebarticle by maintenance guru Mike Busch says,

Both Lycoming and TCM publish engine TBOs in the form of non-mandatory service bulletins. Some Part 121/135 operators have Operations Specifications that require them to comply with all manufacturer’s service bulletins (even non-mandatory ones), while others have Op Specs that require compliance only with mandatory service bulletins.

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  • $\begingroup$ Yup, thanks, what about TBO ? $\endgroup$ – chup May 4 at 15:41
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    $\begingroup$ @chup TBO replacement is a requirement that is built into the operating limitations of Part 135 operators. Along with complying with Service Bulletins. Neither apply to Part 91 and I don’t recall a FAR specifically addressing either. $\endgroup$ – JScarry May 4 at 15:54
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    $\begingroup$ @chup Since it’s not required by 91 or 135 you probably won’t find it in the FARs. avweb.com/ownership/the-savvy-aviator-4-debunking-tbo $\endgroup$ – JScarry May 4 at 19:59
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    $\begingroup$ @chup AFAIK TBO is not mentioned in the FARs at all. Search with this site:ecfr.gov TBO $\endgroup$ – JScarry May 4 at 22:45
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    $\begingroup$ @chup If you are a Part 135 operator you must per §135.63 Recordkeeping requirements. have an operating certificate. It spells out tons of stuff not in the FARs specific to the operator and the aircraft they use. Not my area but you could start here if you are interested. faa.gov/licenses_certificates/airline_certification/… $\endgroup$ – JScarry May 5 at 0:15

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