What the heck can a commercial pilot actually get paid for?
It’s probably one of the most misunderstood topics in aviation. Scores of commercial students — and even flight instructors — don’t fully understand the rules surrounding being a commercial pilot. But the good news is that the regs are incredibly simple.
Today, I’ll break them down for you…
Having a commercial pilot certificate gives you the ability to get hired as a professional pilot. That’s it. And hired is the operative word.
With a few exceptions, you can get any flying job except a part 121 airline gig with just a commercial certificate (you’ll need an ATP cert for the airline job).
And yet, people somehow get themselves into trouble with the FAA for running illegal charter operations. Why?
Here’s the key: there’s NO pilot certificate lets you start a charter business, and airline, or some other type of aviation operation. For those, you’ll need a separate certificate from the FAA for your business operation — a 135 certificate or 121 certificate are good examples of those.
Think about it this way: if you were a culinary school grad, you’d need a bunch of licenses and approvals to open a restaurant — that’s not a limitation of your culinary school diploma, it’s a limitation of starting a business. You can still get hired by a licensed restaurant with your credentials, but the health department isn’t going to let you start a new restaurant without that piece of paper.
The commercial pilot limitations work the same way. To “hold out” as an aviation business, you need a license for that business from the FAA.
So, if a guy owns a plane you’re qualified to fly and needs a pilot, no problem — he can hire you to fly it for him.
If a charter operation is looking for first officers, apply away!
But if you’re offering your pilot services and the aircraft to fly someone to Myrtle Beach for the weekend, you’re obviously not just a pilot anymore. Suddenly, you’re a charter operator who’s holding out without a 135 certificate.
Why is that? Put simply, the reasoning is the exact same as the health department in the example above. When you open a restaurant, the health inspectors want to see the kitchen. They want to know where you’re sourcing your parts. Likewise, the FAA’s inspectors require a higher standard from 121/135 certificate holders — they require drug testing programs, and ops manuals, and higher pilot training for folks trying to provide flights to the general public.
There are some loopholes, though.
The FAA does provide is a set of exemptions under part 119.1 that allows CPL holders to automatically operate a number of businesses without needing a charter or airline certificate. A few examples include flight instruction (for those with CFI certificates), aerial survey and photography, air tours, ferry flights, cropdusting, and banner towing.
Those aren’t limitations to your pilot certificate, they’re extra benefits you have that get you around needing a separate certificate for your business! Thanks FAA!
When teaching commercial pilot privileges and limitations, people tend to intermingle those rules with part 121.135 certificate privileges — and that ends up confusing a lot of commercial pilot students about what they can do when they get their ticket. Just think of the restaurant analogy, and you’ll be able to figure out most scenarios a DPE can dream up on a checkride.
I’ll leave this here one more time: having a commercial pilot certificate gives you the ability to get hired as a professional pilot. If you’re trying to run a business that’s not covered by the part 119.1 exemptions, then you need an airline or charter certificate from the FAA.
Tony Sanchez says
Really helpful! Thanks a lot for this explanation.
the best explanation.
My question is in reference to your comment “So, if a guy owns a plane you’re qualified to fly and needs a pilot, no problem — he can hire you to fly it for him.”
What if the person that wanted to hire you didn’t actually OWN his/her own plane, but rather they RENTED the plane from a local FBO or even LEASED the plane for “x” number of hours from a local plane owner. After taking this step if they then called you up and asked you to fly them somewhere for hire would this be allowed?
As long as the pilot and the airplane are not connected in some way, the example you give is acceptable. So, the individual who wants to hire you to provide pilot services cannot also request your assistance in renting the airplane.
One thing that was not brought out in the above article/string was the concept of who is the “operator” of the flight. In the case of someone who owns/rents/leases an aircraft for you to provide pilot services to them in, THEY are designated as the operator. That means that they are liable to the FAA for any errors YOU make as the pilot (pilot deviation). This needs to be clearly understood and could dissuade someone from chosing to provide their own aircraft instead of using a “normal” charter company. Although, if they are not a pilot, there is little that the FAA can actually do to them (can’t suspend certificates that don’t exist…).
There are plenty of good discussions of varoius aspects of commercial ops on the FAA General Counsel’s website for Letters of Interpretation.
The restaurant analogy is a great memory aid. Thanks.
Nicholas Hardy says
I will be taking my CPL checkride – multi engine..in a couple weeks. This was excellent because it can be confusing especially when an individual has been paying for training and flight hours and finally wants to get some return on the initial career investment
Josue Cruz says
Awesome great post!!
Anthony Vansell says
Super helpful analogy and explanation. Thank you
Mitchell Kolwelter says
Great explanation and should clear things up for my Commercial Checkride in a few days, thanks!
As an aside, not all operations require the full size 135 operations certificate. There are a few simplified types of 135 certificates. Described in AC_120-49A section 6.3
Most notable here is a single-pilot 135 operator, which waives the need for many company training programs, manuals, and management positions. This operating certificate names the specific pilot so the two halves are linked. Think of it as the difference between a LLC/corporation and a sole-proprietor business license.