Old 12-09-2011, 04:55 PM
  #18  
sandrich
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Joined APC: Feb 2011
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Originally Posted by mikearuba View Post
So in this case it would only be holding out if I advertise myself as a commercial pilot AND am able to provide an airplane (on my biz card)? Or it's holding out of more than several people call me up to fly THEIR airplanes after having given them my biz card (and I do it)?
Theres really no cut and dry way to explain it. Everyone has their own definitions. Instructors teach what they were taught. Their students practice what their instructors taught them. So its and ongoing circle of a theoretical game of telephone... FARs are notorious for loose interpretation, so that when a violation is questionable, the FAA can use that grey area in their favor. I'd say that the common carriage/holding out is one of the most in-the-air issues in commercial aviation. Let me go ahead and bust out my CFI thinking cap here...
Check out Advisory Circular 120-12A. It explains that "private carriers are sometimes referred to as contract carriers...and carriage is usually on a long term basis." The part that gets me is when it says private carriage is where THREE CONTRACTS is the basis of the operation, but 18-24 contracts is considered holding out....talk about one of those grey areas...That being said, the only reason to use a commercial pilot business card would be to promote business, which could be considered on par with putting your name in the yellow pages as a pilot (which is holding out). Like I said, this is my opinion, so take it for what its worth. My greatest advice would be to just call the FISDO and see what they say, because they're the ones who'd bust you if it happened to be a violation.
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