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13 Answers

Commercial Pilot Advertising to do Private Carriage?

Asked by: 4420 views ,
Commercial Pilot

Can a newly-minted Commercial ASEL pilot advertise (say on facebook) that they are looking for a private-carriage Part 91 job? e.g. "Hi facebook pilot group, my name is _____ and if anyone knows of a private-carriage Part 91 job flying a single-engine piston in the area, I am looking for an opportunity to do that and get paid as a commercial pilot."

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13 Answers



  1. Adam Broun on Mar 05, 2022

    I would say yes, since the ask is not related to any specific operation. But if the pilot got ramp-checked at some point, and the particular operation smelled like an illegal charter, that post might not help if it looked like holding out.

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  2. Jeff Baum on Mar 05, 2022

    You need to be very careful treading into this area. Many have tried and many have run afoul of the FAA by thinking that a Commercial Pilot may fly for pay, period.

    Private Carriage has a specific meaning. Check out 14 CFR 110.2 which addresses some of the question.

    The real issue comes down to Who has “Operational Control” of the airplane? The definitions for these are found in 14 CFR 91 Subpart K (91.1001). Yes, these are directed more at Fractional Turbojet Operators, but there is a lot of guidance here.

    May you, as a Commercial SEL pilot, fly for a company or individual in THEIR airplane which they are the registered owner? Yes. May you place an advertisement looking for such employment? Yes. May you solicit people to pay you to fly them in an airplane which you arrange, supply or rent? NO! May you fly an airplane for a company/individual where others are onboard and the company/individual receive some form of compensation for the flight? No.

    May you fly an airplane which the company/individual does not own? Now it gets more complicated and it comes down to who controls the airplane. Is this a lease of the airplane or a rental? If they are renting without Operational Control, No. If it is a lease, is the company/individual leasing the airplane with full control and responsibility for the airplane, its utilization and dealing with maintenance? If the answer is “No”, then No, you may not. If the answer is “Yes”, then maybe.

    As you can see, it’s complicated. Basically – as a Commercial Pilot you MAY receive pay for your “Pilot Services”, but you may not be involved in any operation which runs afoul of 14 CFR 119 and 135. If you’re looking for “A Job”, you may advertise. If you’re looking for people/cargo to fly, you need a 135 certificate.

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  3. Russ Roslewski on Mar 05, 2022

    Why is this even a question? Is someone telling you that you can’t seek employment? The FAA does not regulate job-hunting methods. Being a “new” commercial pilot has nothing to do with it.

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  4. Mark Kolber on Mar 06, 2022

    I’m having a little trouble with the question. “Private carriage” doesn’t mean “Part 91.” “Carriage,” public or private, requires an operating certificate (yes, there is an FAA Part 135 private carriage” certificate). The typical corporate pilot job is not “carriage.” Exactly what type of job are you looking for?

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  5. Mark Kolber on Mar 06, 2022

    … unless it fits into a 119 or other specific exemption.

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  6. AviatorTrevor88 on Mar 06, 2022

    This is merely a theoretical question. I’m a flight instructor teaching a commercial applicant and want clarity on this scenario to answer his question.

    “Private carriage” is a term the FAA recognizes, and no you do not need an operator’s certificate for private carriage. If a friend of mine owns a Cessna 182 and says “I’d like to pay you to be my pilot and fly me in this C182 to wherever I want to go”, that is legal, and I don’t need an operator’s certificate, and that is referred to as “private carriage.”

    Common carriage refers to holding out – a willingness to take any one or any thing to a destination of their choosing, and I would be providing the aircraft. This type of work requires an operator’s certificate.

    But my question pertains to advertising your services to be a commercial pilot in an aircraft furnished by the client. I haven’t seen anyone directly answer that yet.

    There is a difference between SEEKING employment and ADVERTISING that you’re seeking employment. Merely seeking employment would be looking at job ads or inquiring at a charter or airline whether or not they have jobs available. No one disputes that is allowed. Where I’m worried this scenario crosses the line is that I would be making a social media post advertising my availability for employment if the client provides the aircraft.

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  7. Russ Roslewski on Mar 06, 2022

    I don’t understand why you think there is a difference as far as the FAA is concerned between seeking work and advertising for work. Heck, I don’t see that there’s a difference in any other field of work either. You can check the want ads for work, or you can walk into McDonalds and ask for a job, or you can post on the McDonalds Facebook page saying you’re willing to work. It doesn’t matter how you get there, your employment is the same.

    How do you think many, many, beginning pilots get jobs? By letting people at the airport know they’re looking. I’ve never heard anybody suggest that there’s anything wrong with that.

    I’m not sure what got you started down this train of thought, but you’re trying to make something of nothing. You can advertise your pilot services all you want. Make business cards and pass them out. Make a web page. Tell everybody on Facebook. Put a sign up at the FBO. Whatever. You’re not advertising air transportation, you’re advertising pilot services.

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  8. AviatorTrevor88 on Mar 06, 2022

    I just thought perhaps the example I gave would be considered “holding out”. It’s advertising my services to fly people from point A to point B for money. The difference is I’m not furnishing the airplane. I’m asking the client to furnish the airplane.

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  9. Mark Kolber on Mar 07, 2022

    >>”Private carriage” is a term the FAA recognizes, and no you do not need an operator’s certificate for private carriage. If a friend of mine owns a Cessna 182 and says “I’d like to pay you to be my pilot and fly me in this C182 to wherever I want to go”, that is legal, and I don’t need an operator’s certificate”

    That is incorrect. It actually one of the first questions asked on a commercial practical test and the answer is “no.” Search “flight department company.” That’s a situation in which Company A separately incorporates Company B to own the airplane and provide services. Company A owns 100% of Company B and the only thing Company B does is provide flight services to its owner. Nothing screams “Private carriage” more than that. Nevertheless, Company B needs a Private carriage Part 135 certificate.

    Yes, the 36 year old AC 120-12A suggests that you can. Being wrong is the most important reason it desperately needs to be updated.

    Check FAASafety.gov for illegal charter webinars. There’s a good one coming up next month. I’m involved. It’s an enforcement priority and the fact that, as a commercial pilot, as opposed to commercial operator, you cannot provide airplane and pilot to anyone outside of 61.113 sharing or 119.1 exceptions is very well established.

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  10. Mark Kolber on Mar 07, 2022

    >>I just thought perhaps the example I gave would be considered “holding out”.

    With a few exceptions, the real issue is not “holding out.” It’s a bit complicated but with the exception of rude sharing under 61.113 ride sharing, you are mostly allowed to hold out things you are authorized to do. You are allowed to “hold out” looking for a job. A CFI is allowed to “hold out” flight instruction. A Part 91 tour operator is allowed to “hold out” tours. A commercial pilot doing aerial photography is allowed to “hold out” her services,

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  11. Mark Kolber on Mar 07, 2022

    BTW, lest there being any doubt about it, this is a Part 135 Private Carriage Certifucate
    http://midlifeflight.net/posted/PrivateCarriageOpCert.png

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  12. AviatorTrevor88 on Mar 07, 2022

    If I understand you correctly, you are saying the only way I can legally be paid as a commercial pilot is to either fly for someone with an operator’s certificate, or to be engaged in one of the exempt activities listed on FAR 119.1(e)?

    You are saying I cannot in fact be hired to fly an individual in an aircraft *they* provide without an operator’s certificate??? This is news to me…

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  13. Mark Kolber on Mar 07, 2022

    You can fly for someone in their airplane. That’s not any form of “carriage.” “Carriage” comes down to providing airplane and crew to transport persons or property for hire. If I own an airplane and hire a pilot to transport me, it’s not “carriage” at all.

    That’s not to say the aircraft owner might be engaged in carriage, so you have to understand what the job entails.

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