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6 Answers

Compensation for hire

Asked by: 3580 views Commercial Pilot, FAA Regulations, General Aviation

Fellas I'm fairly new to this and I'm curious to how this belongs. If I start working for an aerial photography company lets say flying around a Cessna with a camera does this fall under part 91 ops since I'm being paid to fly their airplane around ? Or am I getting paid to operate the camera? Also what about when I just reposition the airplane to the next town over and I'm not operating the camera?  Assuming I have a commercial certificate with an instrument rating.  The question is  where does this type of flying fall under?

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6 Answers



  1. Mark Kolber on Sep 28, 2014

    The short answer is that 119.1 includes serial photography as I’ve of these activities a commercial pilot may do under Part 91. But be sure you understand the restrictions such as no landings at airports other than the one you took off from. You can see misty of them discussed by searching serial photography on the FAA. Chief Counsel website at http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/Interpretations/

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  2. Mark Kolber on Sep 28, 2014

    Stupid spell check (sigh)

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  3. victor torres on Sep 28, 2014

    Thanks a lot Mark! I went to the far website and read two letters which went into detail.

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  4. Best Answer


    Kris Kortokrax on Sep 28, 2014

    Victor,

    Not sure from your post what answer you found.

    If you look at the Bonilla interpretation, you will see that the FAA reversed its position on landing at other airports. They allow landing to address aircraft or human needs. The human needs outlined in the letter seem to include meals and rest. This would allow sleeping overnight on a long mission.

    The only caveat seems to be that any persons on board when the aircraft departs on the mission, must remain with the aircraft through the mission and return to the starting airport. Otherwise, you would be providing transportation.

    The letter can be found at:

    http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2011/bonilla%20-%20%282011%29%20legal%20interpretation.pdf

    Another question would be if you are in the aircraft by yourself or if there is a photographer on board. If you are the only one on board, I don’t think there would be any transportation issue. But then, if you are the only one on board, how do you manage the flying and photography at the same time? If you are looking through the viewfinder, who is looking for other air traffic (see and avoid)?

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  5. victor torres on Sep 28, 2014

    Kris I read the letter thoroughly and understand it a lot better now. Basically I’m being paid to fly a Cessna and operate a sophisticated automated camera simultaneously which this does fall under the 119 exemption. I however cannot let anyone board my aircraft and take them to some airport along my route because conveniently I’m headed in that direction, because otherwise I would need a 119 commercial operator certificate because the flight now has dual purposes. The only exception to that is if we eventually return to the starting point, assuming we landed at other points to meet aircraft/human needs? Hope I understood it correctly fellas.

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  6. Mark Kolber on Sep 29, 2014

    Pretty much go it, victor. When the Lieber letter was issued I wondered how many others immediately thought, “Now there’s an invitation to pilots to run out of fuel or continue into bad weather.” Fortunately, the Chief Counsel’s office quickly withdrew it realizing such a strict black line wasn’t necessary to differentiate the photo flight from the transportation flight.

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