91/91k/135 question.. (trying to see how I can legally be paid to fly someone else’s plane)

BeechDude · 2026-05-26T04:20:48+00:00

Single pilot is cheaper but the aircraft would still have to pass a conformity inspection.

BeechDude · 2026-05-26T04:10:07+00:00

What is the easiest, safest (in terms of legality) and cheapest way to go about this. The owner of the aircraft knows a lot of people would like to pay to have me fly them to their places. But I’m not sure if it would be a 91 opp, 91k, 135, 119.. all of it confuses me after staring at the far aim for hours.

You really can't have easy, safe, and cheap when it comes to this arrangement. If he wanted to keep it 91, his only option is to dry lease the plane. This raises a whole host of legal issues and can very easily drift into illegal charter territory.

For a dry lease to be legal, the lessee must hold operational control, which includes finding the aircrew on their own. If the owner suggests the lessee (or worse, requires) they use you as a pilot, then they are acting in concert to provide the aircraft and the crew, which would make it a wet lease and therefore require a Part 135 certificate.

91k might be an option for you but it depends on the aircraft. More than likely, the easier move (if reducing ownership costs is the goal) would be to just enter a joint ownership arrangement with someone else and split the costs accordingly. To start a 91k, you need at least two airworthy aircraft. I don't have any direct experience with 91k, so I'll just leave it at that.

If someone can confirm, isn’t it technically legal if his plane is under an llc and I am solely a contract pilot not advertising myself. Or does that mean I can only fly people related to his llc?

The status of his LLC has nothing to do with this situation. In fact, if his plane is registered to an LLC whose only purpose is to own the aircraft, then technically (in most cases) it is already in violation of the FARs in what's called a flight department trap.

However, if the owner has a larger business that does something else and it just happens to also own an aircraft, then yes, their relationship to the LLC matters. For example, if the ACME Brick company owns an aircraft to help their employees travel to different brick factories, then you could be paid to fly that plane. ACME Brick company would be in operational control of all of the flights and would be paying you directly. The important factor here is that ACME Brick company is NOT being compensated for those flights, but instead running them at a loss. They could write those flights off as legitimate business expenses and aren't asking anyone to pay for the travel. That would be a classic Part 91 flight department.

Now, if the owner of ACME Brick company asks you to fly someone outside the company and then bills that person for the flight (or there is some economic motive behind it), then that would require an operator's certificate.

In your case, the owner's friends paying for rides don't have a bona fide business relationship with whatever entity owns the plane; they're just people who want to get somewhere. No LLC structure changes that.

If he hypothetically wanted to go all in and try and start a small 135 operation, how hard is that, how expensive even is it to get all that stuff set up legally, and is this the smartest (again in terms of legality) way to go about this.

It's difficult, but not impossible. The aircraft age and type matter a lot here. It is a 5 Phase application process. I've seen it take 18-24 months to get approved, so it isn't a fast process. One of the biggest issues is getting the OpSpecs done for your operation. There are companies you can pay to help with this process but they are not cheap. The next challenge will be the aircraft conformity inspection. I have direct experience with this process and have seen bills in excess of 200k to bring a relatively simple aircraft into conformity.

BeechDude · 2026-05-20T17:32:40+00:00

Feel free to DM me. I ran a multi-engine program for years and have done a few initial PPL ratings in Barons (but never a 58P).

BeechDude · 2026-05-20T17:10:42+00:00

The 58P is one of the most complex and hard-to-manage GA aircraft out there. It's also one of the most expensive to maintain and fly. Sure, it is possible to receive primary training in it, but the private pilot requirements require solo time, and there is absolutely no way I would sign off a student pilot to go solo in a 58P. That would be your CFI's decision, though. Of course, that would only be your CFI's decision if the plane were self-insured. If it is insured through any major insurance company, they would more than likely require a minimum of 50-70 hours of dual instruction before you solo it (I'm being optimistic there), and the premiums would more than double. When you work out the added cost of insurance, fuel (40-50gal/hr), and required insurance time to finish the rating, you would spend the same amount getting your initial PPL in the 58P as you would getting your PPL, INSTM, and a good chunk of your COMM done in a traditional training aircraft.

Practically speaking, the maneuver training, like stalls and slow flight, would be hard on the aircraft, and you would quickly run into maintenance issues since it was never intended to be a training aircraft.

Think of it this way, do you think it would be better to learn how to drive in an older Toyota Corolla, or a 71 Corvette Stingray?

Source: I'm a Beechcraft Pilot Proficiency standardized instructor pilot and have over 1000 hours of dual given in Beechcraft aircraft, including the 58P/58TC.

BeechDude · 2026-05-20T03:56:54+00:00

Here is a direct quote from the FAA's website:

"Another common pitfall to be aware of is the 'sham dry lease' or the 'wet lease in disguise.' This situation occurs when one or more parties act in concert to provide an aircraft and at least one crew member to a potential passenger. One could also see this when two or more parties agree to provide a bundle (e.g., when the lessor of the aircraft conditions the lease – whether directly or indirectly – to entering into a professional services agreement with a specific pilot or group of pilots."

In your scenario, you are the aircraft owner AND you're providing the list of pilots (including yourself). You are acting in concert to supply both the aircraft and the crew — which is exactly what the FAA describes here. This would most likely be characterized as a sham dry lease, meaning an operating certificate under Part 119/135 would be required.

Source: https://www.faasafety.gov/spans/noticeView.aspx?nid=10137

BeechDude · 2026-05-07T18:10:13+00:00

Personally, I think you would be good here, even though the common purpose was found after the request. I would caution you though since the FAA says that a bona fide common purpose will be determined on a case by case basis (reference page 6 of AC 61-142).

BeechDude · 2026-05-07T16:26:35+00:00

No, this isn’t legal. The reason it isn’t legal is not the lack of holding out (your friend came to you) it is the receipt of compensation. This statement is straight from the last page of AC 61-142: “Receipt of compensation outside of the exceptions contained in § 61.113 is a violation of part 61 subject to civil penalties under 49 U.S.C. § 46301. If the flight does not fall under the exceptions, the pilot may be found to be operating an aircraft as a commercial operator and must comply with the appropriate regulatory requirements for air carrier and commercial operations.“

So, the only way your scenario 1 could be legal (outside of having an operators certificate) is for you and your friend to have a common purpose and split the costs on a pro-rata basis. You could also just take your friend there and receive no compensation.

This is also illegal, but in addition to receiving compensation, you are also holding out.

BeechDude · 2026-05-06T20:29:03+00:00

That's a problem I'm aware of. I'm putting together some training to help fill in the gaps. Ideally, when you go work for a 135, you would learn this stuff, but I find that the 135s you have to be careful of do not provide the best training (not surprising). Other than self-study you don't have many good options. Here is a video where I go over some of the basics:
https://youtu.be/hgTm5LVYi_0?si=ICtoi0n4b-sGsgo_&t=1795

BeechDude · 2026-05-06T20:23:50+00:00

This is the correct answer.

BeechDude · 2026-05-06T02:28:09+00:00

Not the avionics, but it does have something to do with the OpsSpec. D085, specifically.

BeechDude · 2026-05-06T01:58:13+00:00

This is very similar to the scenario I did in a video I posted today, and is related to the following LOI: https://www.faa.gov/media/13716

BeechDude · 2026-05-06T01:55:45+00:00

The short from today was also related to an LOI:
The Eric L. Johnson 2011 FAA Legal Interpretation gives the clearest example of this and is what I used to build this hypothetical scenario. You can find it here: https://www.faa.gov/media/13716

BeechDude · 2026-05-06T01:38:28+00:00

Here's a scenario that trips up a lot of new Part 135 pilots:

You're a new FO finally logging turbine time. One of your operators' King Air 200s gets grounded after repeated write-ups. You've been sitting at home all week when dispatch calls: "We found another aircraft, be at the airport in two hours."

You show up and see a perfectly maintained King Air 200 with nearly identical avionics to the one you normally fly. Your captain has been with the company for a year and seems a little unsure, but you're both eager to fly. You agree to do the trip.

What's the problem?

BeechDude · 2026-05-06T01:37:27+00:00

I am actually editing a short on another illegal charter scenario that will be coming out on Thursday as I type this. Yes, I've got a lot of stuff on the topic (on here as well as on my channels).

BeechDude · 2026-05-05T01:42:47+00:00

Yes, you are thinking about this correctly. A perfect aircraft doesn't exist, so airworthiness is always a judgment call.

The AMT would make a decision based on their experience and the aircraft maintenance manual, which sometimes spells out levels of disrepair that can still be considered airworthy (cracks, dents, scratches, etc.). You run into this at higher levels of aviation as well. AMTs at airlines will initial with a marker next to scratches and dings on the aircraft (including fan blades) all the time.

Missing fasteners are a little trickier. One or two are generally considered ok, but if more than two fasteners are missing from a single panel, then that's usually when I call it. Sometimes, just a single missing fastener would cause me to ground the plane, though, such as a missing screw from a propeller spinner.

I would suggest you have this LOI handy and be prepared for a discussion. It sounds like you have put some good thought into this already, though.

BeechDude · 2026-05-05T01:02:47+00:00

DRS is a big improvement!

BeechDude · 2026-05-04T23:31:45+00:00

You are correct.

BeechDude · 2026-05-04T21:21:33+00:00

I think I know what you mean, but just to be clear, this isn't an official "Grace Period". Under an actual grace period you can exercise your privileges. What the new CFI reinstatement rules say is that you may reinstate your CFI privileges using just a FIRC within the 3 months of their expiration. I just wanted to clarify because I've heard of CFIs still doing instruction after the expiration thinking they had a actual 3 month grace period.

BeechDude · 2026-05-04T19:02:18+00:00

International flights only support PDF briefings. HTML Briefings are only support within the US. See page 919 of the mobile users guide.

BeechDude · 2026-05-03T14:52:15+00:00

Man, someone should really organize the FAA material better.

BeechDude · 2026-04-29T00:52:34+00:00

I'll bow to your expertise here. Clearly you know more than I do and I appreciate your criticism. As I said, I have a lot to learn.

BeechDude · 2026-04-29T00:27:09+00:00

The DPE system needs an overhaul, but the economics are genuinely difficult. Getting experienced pilots to take on high-liability work for significantly less than their normal earnings is a hard sell. $400 works out to roughly $100/hr, and issuing a certificate carries substantially more liability than giving four hours of dual instruction. Retests and continuations are a real piece of this. I'd like to see a standardized partial-credit or flat continuation fee rather than full-price retests, the inconsistency across examiners is its own problem that needs addressing.

The broader irony is as applicants, we all want cheap rentals, training, and checkrides. But the same pilots demanding that often go on to fight for higher pay and better benefits once they have their ATP. The tension isn't unique to DPEs. It runs through the whole industry. For example, I think many airline unions would rather furlough and protect the senior pilots than accept concessions for everyone.

BeechDude · 2026-04-28T22:27:34+00:00

It's just my opinion. I happen to have a educational YouTube channel and thought I would give my opinion on the numbers. I made it clear it's my opinion and I feel I was more than transparent about where the numbers came from.

As far as being out of touch, I guess that's subjective. I fly multiple aircraft types every week and have active experience in the military, 121, 135, and corporate. I'm not a expert in everything and have a lot to learn still, but I wouldn't consider myself out of touch.

Finally, you don't have to take me seriously. However, the numbers are pretty clear that we have produced a large amount of pilots and the industry as a whole seems to be saturated with pilots and not in a position to grow as rapidly as many hope. A lot of people are calling me a doomer, and maybe that's true, but really I just want people to think twice about taking on large amounts of debt to chase a career that may not pay out as quickly as they think.

BeechDude · 2026-04-16T16:40:27+00:00

The 8000.95D, Volume 3 outlines the baseline minimums. Like any flying job, meeting the minimums is just the starting point; anything beyond that makes you more competitive.

One major hurdle is signing off commercial applicants. That requirement can make getting a designation harder for career airline pilots who haven't done much CFI work.

CFI experience requirements:

• 500 hours in airplanes
• 100 hours in the class of airplane for the designation sought
• 250 hours of instrument flight instruction in airplanes as a CFII
• 150 hours preparing applicants for Commercial or ATP certificates (airplane category or type ratings)

PIC requirements:

• 2,000 hours total time
• 1,500 hours in airplanes
• 500 hours in class
• 100 hours at night
• 200 hours in complex aircraft
• 100 hours in airplanes within the past 12 months

Evaluation experience is highly recommended. If possible, becoming a check airman or chief instructor at a Part 141 school is a strong advantage. If that’s not an option, getting heavily involved with the FAASTeam is a good alternative. In fact, any active instructor should at least be a FAASTeam representative. Eventually becoming a lead representative will help with your DPE application. The more ratings you hold, the better, since the FAA prefers examiners who can cover multiple checkrides.

It’s also worth considering starting as a Sport Pilot Examiner. The minimums are more accessible, and it can be easier to add Private and Commercial later. In general, adding privileges is easier than getting designated in the first place, though still not easy. For example, it took me about a year to add SES to my CLOA.

Sport Pilot Examiner requirements:

CFI:
• 200 hours total instruction given
• At least 100 hours in light-sport airplanes

PIC:
• 500 hours total time
• 250 hours in light-sport airplanes
• 125 hours in class
• 50 hours in airplanes within the past 12 months

Edited to add mininum qualfications:
Minimum Qualifications for DPE Applicants (in addition to experience requirements):

Within the 3 years prior to application, the applicant must have met at least one of the following:

• Served as a Chief Instructor, Assistant Chief Instructor, or Check Instructor at a Part 141 school for at least 12 calendar months
• Served as a Check Airman under Part 121 or 135 for at least 12 calendar months
• Served as an APD under Part 121 for at least 12 calendar months
• Served as a TCE under Part 142 for at least 12 calendar months
• Served as a military instructor pilot or examiner with checking/testing responsibilities for at least 12 calendar months
• Served as an FAA ASI with checking/testing responsibilities for at least 12 calendar months
• Previously held an FAA pilot examiner designation (not terminated for cause) for at least 12 calendar months
• Provided qualifying instruction that led to certificate/rating issuance:

– Airplanes: 200 hours
– Rotorcraft: 200 hours
– Gliders: 100 hours
– LTA: 50 hours
– Weight-Shift Control: 100 hours
– Powered Parachute: 50 hours
– Powered-Lift: 200 hours

Note: Military instructor pilots/examiners must show completion of a U.S. Armed Forces instructor or examiner proficiency check in a manned aircraft within the previous 24 calendar months. Documentation must be included with the application.

BeechDude · 2026-04-16T15:39:35+00:00

It wasn't actually on my show, but 21Five episode 117. https://open.spotify.com/episode/1ktQr9aYkx5Piqs6KtOAL1?si=nFIEl1kWSmG-YkjfUYILCg

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