"Tony Cox" wrote:

This is a hypothetical discussion, so what the FAA does or
doesn't want really isn't the issue. My point is that the
requirements for pilot qualification and maintenance should
be based on risk and the perception thereof by the participants,
and not upon other factors.

I generally agree, but you're arguing for an all or nothing
approach. If a private pilot can pay for the flight and
take his grandma sight seeing, why not others who pay him?
You have to look not only at risk per flight/passsenger, but
also at the total effect of your rule. If it's all or
nothing, either you let the private pilot fly only solo or
you let him fly commercially and impose the higher risk on
larger numbers of passengers. It's reasonable to restrict
the totals as we do now by some limit. I just think the
limit is currently more restrictive than is justified.

This is correlated with, but certainly not exclusively based upon,
whether the operation is considered 'commercial' or not. In fact,
the existing FARs already make exception for 'commercial' operations
which occur with (presumably) informed consent of the participants
- flight instruction, which doesn't need to be pt. 135.

It seems quite reasonable to me that "Mark", flying a pilot and A&P
out to a help a stricken plane ought not be hampered by the FARs
either. If he wants to charge money, so be it. I'd not attempt to
regulate his reimbursement any more than I'd try to tell a CFI what
to charge. It seems that too many people accept that 'commercial
intent' should be the deciding factor, but don't really appreciate
that what the rules should be doing (and what they for the most
part do) is arbitrate risk.

They control risk in two ways. One is by requiring certain
training levels. The other is by limiting the number of
operations by prohibiting certain commercial activities that
would result in large numbers of operations. The problem
IMHO is that too many non-comercial activities are
prohibited.

Todd Pattist
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