Is it legal to take paying passengers on scenic flights if its within 25 SM within your home airport without a Letter of Authorization from the FAA?
MY FBO is trying to do these Scenic flights and the FSDO claimed we needed a letter from them first to do these Scenic flights. However they are very slow in giving us this letter (months) and It appears to me in FAR 119.1 that we dont even need such a letter?
What about people that come in wanting to take pictures? Can we do this on our own?
What about 91.147?
§ 91.147 Passenger carrying flights for compensation or hire.
Each Operator conducting passenger carrying flights for compensation or
hire must meet the following requirements unless all flights are conducted
under § 91.146.
(a) For the purposes of this section and for drug and alcohol testing, Operator means any person conducting nonstop passenger-carrying flights in an airplane or helicopter for compensation or hire in accordance with §§ 119.1(e)(2), 135.1(a)(5), or 121.1(d), of this chapter that begin and end at the same airport and are conducted within a 25-statute mile radius of that airport
(b) An Operator must comply with the safety provisions of part 136, subpart A of this chapter, and apply for and receive a Letter of Authorization
from the Flight Standards District Office nearest to its principal place of business by September 11, 2007.
(c) Each application for a Letter of Authorization must include the following
(1) Name of Operator, agent, and any d/b/a (doing-business-as) under which that Operator does business;
(2) Principal business address and mailing address;
(3) Principal place of business (if different from business address);
(4) Name of person responsible for management of the business;
(5) Name of person responsible for aircraft maintenance;
(6) Type of aircraft, registration number(s), and make/model/series; and
(7) An Antidrug and Alcohol Misuse Prevention Program registration.
(d) The Operator must register and implement its drug and alcohol testing
programs in accordance with part 121, appendices I and J, of this chapter.
(e) The Operator must comply with the provisions of the Letter of Authorization received