"James M. Knox" wrote in message
...
"Ron Natalie" wrote in
m:

Renting out an aircraft is a commercial operation in itself,

It's renting of a piece of property. It is a commercial operation
and will require the renter to hold a state sales certificate
(although not have to pay state tax in most states).

It is not an "operation" as far as the FAA is concern. Operating
involves providing an aircraft and a pilot.

We are in complete agreement, as far as I can tell. Renting an aircraft
is
a commercial operation -- just the same as renting a fishing boat or
renting a pair of skis. It's subject to state and federal laws concerning
operating a business, including the collecting and payment of applicable
taxes, plus required permits.

But, as you say, the FAA has no special regulations for this. It's NOT
what they are talking about when they refer to a "commercial operation."

If the inspection is important as health and safety law, all that FAA has
done with the opinion Ron posted is allow any club to forever put off the
100 hour inspection; by merely having the members provide their own
instructor. If the law is not important as health and safety law, then the
opinion acts in restraint of trade, by preventing the school from providing
an instructor.