- You’re right, but it’s the CFI rating that’s more important in this case. Commercial operations with passengers is highly regulated compared to instruction. The FAA lawyers are focusing on limited, experimental and primary, but all of those require instruction of some kind in practical terms for safety reasons and possibly endorsements.
Do you really want low-time pilots flying P-40s, etc. around with no instruction in peace time? The US lost as many planes and pilots due to training accidents as the enemy in WW2.
- FAA lawyers are quoting the AC 61-142 on ride sharing expenses, but instruction is not ride sharing.
The recent history is that the FAA has clamped down on “air taxi app ride sharing” (correctly) and Youtube payments by one FSDO (incorrectly.)
In the Youtube case, a famous Youtube Part 91 single turboprop pilot called his viewers “passengers” or said “fly with me”, and was monetized on Youtube, and I think it was the Miami FSDO that basically lost their minds and started enforcement actions over not being an air carrier (for Internet viewers!) and collecting payments (for incidental Youtube views!) It was truly kafkaesque.