Jim...

That's not the current interpretation from Ok City. The FBO or club that
rents aircraft for instruction is not required to have 100 hour inspections.
The focus of the 100 hour inspection has been severely narrowed to mean that
the instructor him/herself must own the aircraft, rent it to the student,
and also be giving dual instruction for the purposes of the regs.

WHat is still a gray area is if (as in my case) a CORPORATION owns the
aircraft, I 100% own the corporate stock, and I give the instruction,
whether the corporation can rent the aircraft and I give the instruction
without the 100 hour inspection. I never worried about it; I simply did the
100 hour myself and didn't push the issue, but the issue is still
unresolved.

You may have a later Staff Counsel opinion and if so, I'd like a pointer to
it.

Jim



"Jim Macklin" wrote in message
...
Their own rules may require 100 hour inspections, but the
FAA does not for airplanes just used for rental. A renter
is considered the "operator" of the airplane.

Even an FBO that is using a fleet of airplanes for
instruction, that are required to have 100 hour inspections
for the instruction [ read dual flights] can rent those same
airplanes to a student or any other person even if the 100
hour inspecdtion is due [ time up].