Originally Posted by
Bellanca
I believe there is an advisory circular on private carriage vs common carriage, and I want to say that 3 is the number of contracts that they throw out as being an acceptable number to still be private carriage.
That only applies if the pilot is providing the airplane (or is part of the organization that does). Anyone can pay a pilot to fly an airplane provided by themselves.
The trick here is for the pilot to not be part of the lessor entity...that would be private carriage (which might even be legal in this case) or 91K (which would not be legal without additional "stuff").
What's going on here is the owner is trying to run a private carriage/fractional in a round-about way, but I think he's got enough arms-length to make it legal.