Originally Posted by nealsapilot
You also stated that you are able to "hold out". I'm sorry to say, but you are wrong again. If you "hold out", which basically means advertising the service, you automatically make these types of flights under "common carriage". Operations that constitute common carriage are required to be conducted under either FAR's 121 or 135. I'm sure that this is not the case.
I am a CFI too.
Go read the AC again... "Common Carriage" by the FAA's own definition consists of four elements, one of which is transport from point A to point B. Sightseeing (and photographic) flights which return to the point of origin cannot by definition be FAA Common Carriage. This is not hypothetical and this is nothing new, it's been this way for years.
I agree that anyone interesting in doing this type of flying should check with their local FSDO to avoid misunderstandings. I said this before.