"Larry Dighera" wrote:
...
I believe a waiver is only necessary for airmen who
don't hold a Commercial Certificate or ATP.

The waivers I've seen obtained by my friend in this business and his
pilots I believe say a commercial certificate is required. Whether or
not they would issue a waiver to a private pilot, thus for
noncommercial activity, would be a question to be posed to the FSDO.

Fred F.