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Old 09-13-2018, 08:14 PM   #1  
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Lightbulb "Selling by the Seat" Part-135 On-Demand

Hey y'all,

Long time listener, first time caller.

I'm a soon-to-be retired AF pilot and looking to start up a very modest 135 operation.

I recently came across a publication by NBAA about selling Part-135 by the seat on a scheduled basis (as opposed to on-demand).

https://www.nbaa.org/admin/options/c...y-the-seat.pdf

Quote...

"Under the definition of “on-demand” in the FAA regulations, 14 CFR 110.2 (Definitions), a Part 135 on-demand operator can operate up to four round-trips a week in the same city-pair market utilizing nine-seat or fewer non-turbojet aircraft, or any size rotorcraft aircraft when the departure location, departure time and arrival location are held out to the public (i.e., “scheduled” operations)"

I guess what that's saying is that if I used a C402, C208, PC12 etc, I could do charter, but also limited scheduled service if I wanted to.

So, here's my question for all of you folks who are more familiar with the part 135 world than I am. Why aren't more Part 135 operators doing this? What am I missing?

Is it
A) Legally questionable
B) Hard to market scheduled service
C) Not as financially lucrative as charter
D) Something else completely

Thanks for any insight!
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Old 09-13-2018, 09:49 PM   #2  
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I’m thinking that you’d need to have a pretty lucrative city pair with high-yield seats in order to make 4 1/2 round trips per week worthwhile. And, if that’s the case, it’s probably indicative of a market that could support on-demand (whole airplane) flights and make the scheduled gamble less appealing.
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Old 09-13-2018, 10:07 PM   #3  
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14 CFR Part 110 has a lot of the answers you seek:

Quote:

Commuter operation means any scheduled operation conducted by any person operating one of the following types of aircraft with a frequency of operations of at least five round trips per week on at least one route between two or more points according to the published flight schedules:
(1) Airplanes, other than turbojet-powered airplanes, having a maximum passenger-seat configuration of 9 seats or less, excluding each crewmember seat, and a maximum payload capacity of 7,500 pounds or less; or
(2) Rotorcraft.
Noncommon carriage means an aircraft operation for compensation or hire that does not involve a holding out to others.

On-demand operation means any operation for compensation or hire that is one of the following:
(1) Passenger-carrying operations conducted as a public charter under part 380 of this chapter or any operations in which the departure time, departure location, and arrival location are specifically negotiated with the customer or the customer's representative that are any of the following types of operations:

(i) Common carriage operations conducted with airplanes, including turbojet-powered airplanes, having a passenger-seat configuration of 30 seats or fewer, excluding each crewmember seat, and a payload capacity of 7,500 pounds or less, except that operations using a specific airplane that is also used in domestic or flag operations and that is so listed in the operations specifications as required by § 119.49(a)(4) of this chapter for those operations are considered supplemental operations;
(ii) Noncommon or private carriage operations conducted with airplanes having a passenger-seat configuration of less than 20 seats, excluding each crewmember seat, and a payload capacity of less than 6,000 pounds; or
(iii) Any rotorcraft operation.
(2) Scheduled passenger-carrying operations conducted with one of the following types of aircraft with a frequency of operations of less than five round trips per week on at least one route between two or more points according to the published flight schedules:

(i) Airplanes, other than turbojet powered airplanes, having a maximum passenger-seat configuration of 9 seats or less, excluding each crewmember seat, and a maximum payload capacity of 7,500 pounds or less; or
(ii) Rotorcraft.
(3) All-cargo operations conducted with airplanes having a payload capacity of 7,500 pounds or less, or with rotorcraft.
Scheduled operation means any common carriage passenger-carrying operation for compensation or hire conducted by an air carrier or commercial operator for which the certificate holder or its representative offers in advance the departure location, departure time, and arrival location. It does not include any passenger-carrying operation that is conducted as a public charter operation under part 380 of this chapter.
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Old 09-14-2018, 07:52 AM   #4  
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it costs a lot of money per seat in small planes to make profit. Old piston twins are not cheap to operate 135
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Old 09-14-2018, 08:17 AM   #5  
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Quote:
Originally Posted by flyingisok View Post
Hey y'all,

Long time listener, first time caller.

I'm a soon-to-be retired AF pilot and looking to start up a very modest 135 operation.

I recently came across a publication by NBAA about selling Part-135 by the seat on a scheduled basis (as opposed to on-demand).

https://www.nbaa.org/admin/options/c...y-the-seat.pdf

Quote...

"Under the definition of “on-demand” in the FAA regulations, 14 CFR 110.2 (Definitions), a Part 135 on-demand operator can operate up to four round-trips a week in the same city-pair market utilizing nine-seat or fewer non-turbojet aircraft, or any size rotorcraft aircraft when the departure location, departure time and arrival location are held out to the public (i.e., “scheduled” operations)"

I guess what that's saying is that if I used a C402, C208, PC12 etc, I could do charter, but also limited scheduled service if I wanted to.

So, here's my question for all of you folks who are more familiar with the part 135 world than I am. Why aren't more Part 135 operators doing this? What am I missing?

Is it
A) Legally questionable
B) Hard to market scheduled service
C) Not as financially lucrative as charter
D) Something else completely

Thanks for any insight!
I and another member here (also a AF officer) tried to do this recently. You need a LOT of money and some good lawyers to deal with the FAA. We eventually ran out of money just trying to get the FAA to approve us. We both bought a company that had a 135 cert and were applying for our own and had lots of opportunities but the FAA just killed us with bureaucracy. Be very careful you have a good lawyer who knows how to deal with the FAA or you waste a ton of money and get nothing to show for it. If the local FSDO doesn’t like your idea or doesn’t want you to start (more work for them and a lot of risk for approving) they will stick you in bureaucratic hell until you go away.

This isn’t a buy a plane and sell a seat sort of endeavor. It will take a minimum of 2 years before you can even put a website up. Our POI demanded we take ours down. All it said was coming soon.

There is a lot of truth to the joke you need 2 million to make 1 million in aviation.
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