TGrayson, can you get me the reg just in case?
No, since you admitted being too lazy to look it up.
But I will give you the LOI:
This is in reply to your request of May 1, 1984, that we render an opinion regarding the applicability of the 100-hour inspections requirement of Section 91.169(b) of the Federal Aviation Regulations to rental
Section 91.169(b) of the Federal Aviation Regulations provides that, except as noted in Section 91.169(c), a person may not operate an aircraft carrying any person, other than a crewmember, for hire, and may not give flight instruction for hire in an aircraft which that person provides unless, within the previous 100 hours of time in service, the aircraft has received either an annual or a 100-hour inspection.
If a person merely leases or rents an aircraft to another person and does not provide the pilot, that aircraft is not required by Section 91.169(b) of the Federal Aviation Regulations to have a 100-hour inspection. As noted above, the 100-hour inspection is required only when the aircraft is carrying a person for hire, or when a person is providing flight instruction for hire, in their own aircraft.
If there are any questions, please advise us.
Joseph T. Brennan
Associate Regional Counsel