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2 Answers

Can I deliver goods under a 91?

Asked by: 3561 views , , , ,
Commercial Pilot, FAA Regulations, Private Pilot

I own a courier service, and we are putting a flight route together for a few of our clients. If we sell them a share of the aircraft, and act as a management company, can we legally transport medical specimens daily for these companies with "their" aircraft? They will pay for costs of flight and maintenance, and the compensation I receive is for general management of their aircraft. Any help on this would be greatly appreciated!

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2 Answers



  1. John D Collins on Nov 25, 2013

    You might want to read AC 120-12A and read thru some of the opinions of the FAA general counsel found at http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/

    Search on terms such as holding out, property, aircraft management

    I would also retain an aviation attorney to guide you on this subject as it could represent putting you and your company in legal jeopardy.

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  2. Mark Kolber on Nov 27, 2013

    I definitely agree with John’s recommendation that you see a business aviation attorney to discuss this business scenario. The FAA is very picky about the fuzzy intersection between Part 91 and Part 135, with a lot of technicalities going into the “correct” set-up of what you are trying to do.

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