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6 Answers

Is “Free Flight Time” Compensation?

Asked by: 1838 views Private Pilot

I know this topic beat to death in cyberspace.  But I wanted to make sure I'm interpreting the rules correctly.  As a PPL (other than acting as a safety pilot/unpaid glider towing) there is no scenario where a PPL can log time and act as pilot in command other than operating your own airplane or paying a rental fee and that ANY flight time that would be considered "free or discounted" equates to compensation?  Even if the insurance wickets are met, the following scenarios are off limits?

For example a friend asks you take his plane and fly to airport X to pick up his son from college and bring him home for the weekend.  It's 2 hours of "free" flight time.  Can't do it, it's compensation.

You're in FL and your buddy says "hey feel free to use my plane and take your wife on a sunset flight."  Nope.  Free flight time = compensation.

"Hey man my plane is in TX and I just can't break free to go get it.  Will you go down there commercial and fly it to Missouri for me next weekend?"  Even if you pay travel expenses, it's compensation as it's free flight time.

You're renting a plane and the FBO/owner says "hey, if you fly over to airport X and pick up a part for us we won't charge for the rental today."  Nope, compensation.

Am I interpreting this correctly?  Many thanks!

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6 Answers



  1. Mark Kolber on Mar 26, 2022

    IMO the second scenario is no problem. You are using the airplane for your own purposes, not providing a service to someone else in exchange for free flight time. It’s a gift, not compensation.

    That’s the key. Quid pro quo. “Compensation” in whatever form is receiving something of value *in exchange* for providing something of value to someone else.

    In #1 you are providing transportation.

    In #3 you are providing a ferry service to the owner.

    In #4 you are transporting property for the FBO owner.

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  2. Mark Kolber on Mar 26, 2022

    BTW, being super-technical, the FAA has said it not the free use of the airplane that\’s compensation but the logging of the time.
    https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/1997/Harrington_1997_Legal_Interpretation.pdf

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  3. Bryan on Mar 28, 2022

    I fully agree with Mark’s assessment. In your second scenario, your buddy gets nothing out of letting you use the plane other than goodwill. He’s actually taking a good deal of risk should you damage anything. That’s true even if he pays for the gas, oil, ramp fees, etc. and the use of the plane is completely free to you.

    But the very second you transport something or someone for him (including the plane itself), it becomes an exchange of goods that exceeds the privileges of a private certificate.

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  4. SDFlyer on Mar 31, 2022

    Thanks guys was just curious as I think these kinds of things present themselves out in the real world fairly often. I don’t know if as the pilot, if you paid some cash for the use of the airplane if that changes the scenario or not, i.e., becomes a form of “renting.” Doesn’t seem like compensation if the pilot actually compensates his buddy for offering use of his plane. I heard of one scenario where an owner was gone for the summer and asked a hanger neighbor to “exercise” his plane every couple weeks while he was gone The neighbor paid one of the hanger rental fees for the guy in exchange for getting to fly it. Dunno.

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  5. Mark Kolber on Mar 31, 2022

    Partial payment (or even full payment) by the pilot may or may not make a difference. After all, free flight time isn’t the *only* form of compensation, nor even the silliest. The real “rule” from a practical standpoint is the “if it quacks like a duck” rule. If brought to the FAA’s attention and it looks like transportation compensation, the FAA will find a way to reach it.

    A good example is the Super Bowl case. “Mr. Ed’s Bar and Grille” hosted a big Super Bowl party and hired a Part 135 charter to provide air transportation for the customers. The charter fell through and a pilot offered to help out for free. Pilot figures with the multiple trips he did, he spent about $1100 of his own money (in 2002 dollars – figure at least double in fuel cost alone today). Not good enough. The evidence indicated some kind of business relationship between the pilot and “Ed.” Hence there was compensation in the form of “good will” – an expectation of “some prospective economic advantage.”

    See what I mean about the “quack”? In this one, the pilot was taking over for a charter company to transport people who already paid for transportation. Do you believe the pilot did it out of the goodness of his heart? The FAA and the judges who heard the case didn’t.

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  6. Gary Moore on Apr 04, 2022

    How about thoughts on a variation that I think is rather common. I just bought a new airplane in a far away state. The previous owner offers to deliver the airplane to me for costs? Any issues there?

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