My question is about whether I need a part 121/125/135 certificate to perform commercial operation that is not air transportation.

14 CFR 119.1 (a) says that part 119 applies to air carrier or commercial operator. According to the definitions in 1.1, both involve "carriage of persons or property".

So what happens, for example, if I post an ad to fly over your house in figure eight for you to enjoy for $200 an hour. In this case I'm getting compensated, I'm "holding out" for this operation, but it does not involve carriage of persons or property. If I'm reading the regs correctly, part 119 does not apply so I don't need a part 121/125/135 certificate. (I explicitly picked an activity not covered by 119.1 (e) to avoid potential confusion.) Do I just need a commercial pilot license and can I operate under part 91?

  • $\begingroup$ I would pay for this service! (Probably not $200, though. :)) $\endgroup$
    – Someone
    Commented Jul 9, 2023 at 0:29

1 Answer 1


In my opinion, as long as you have a commercial certificate and at least a 2nd class medical you could fly over someone's house (at a legal altitude of course) and get paid for the service. You would not need a Part 121, 125, or 135 certificate.

Perhaps the easiest way to evaluate the issue would be to consider what FAR you might be in violation of if you operated as you indicate in your question. I don't see any regulation that you would be in violation of.


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