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BFR in an RV that's not really transition training?

Davy8or

Active Member
I have used the search function for a while. I know it's no longer called a BFR by the FAA, but it's what I call it. What I really want to know is, can I get a BFR (or "Flight Review" for the pedants) done in an RV-6/A, 7/A, or preferably a 9/A even though I'm not really seeking tradition training?

I do not have an RV, nor have I committed to buying one, but I do have a BFR coming up in July I think and I'd love to do it in an RV to get the experience of an RV. I'm only interested in the try-gear versions as I do not have a tailwheel endorsement and zero tailwheel time. Also, the /A is what I might buy next.

I just want to pay a CFI and rent an RV in Northern California for the purpose of getting a BFR, is that possible? At this point I really can't legitimately call it transition training.
 
In my case the insurance company was more concerned with total hours flown as PIC of a -6A rather than anything formally labeled transition training.
 
Bfr

I don't think you can legally rent an rv for flight training.. but if you find someone that lets you use it for gas only, then it's ok.
 
Not sure what the FAA says but in Australia the BFR (now AFR) has to be in the type of aircraft you have flown the majority of the time in, in your last ten flights.
 
Not sure what the FAA says but in Australia the BFR (now AFR) has to be in the type of aircraft you have flown the majority of the time in, in your last ten flights.

In the US it is simpler ? the flight review has to be conducted in an aircraft for which the pilot is rated. No currency stipulation at all.
 
You can?t rent an RV, and gas only isn?t legal either. If you find a CFI with an RV, I think you can pay for the instructor if they give you the airplane free. But this could get the FAA real interested if they hear about it.
 
I do not have an RV, nor have I committed to buying one, but I do have a BFR coming up in July I think and I'd love to do it in an RV to get the experience of an RV.
Quit agonizing over it, buy the bloody thing and get your flight review and transition training at the same time. You know you want it, so just do it!

:)
 
I have done my BFR with factory trainer Mike Seager. He?s busy and may not want to just do a BFR ?just for fun? meaning his time is devoted to transition training for owners. Legally you are rated to fly an RV, (insured is another matter) but amateur builts can?t be rented except for the means of transitioning I believe.
Might be better just to start pounding rivets quickly for your next BFR.
 
The answer is a flat-out ?no? - unless you have access to an RV and an instructor who are truely free, no gas, no strings attached.
I have the waiver from the FAA to give transition training for hire in my RV. But the paperwork says I may not sign off a flight review under this waiver, even if during the course of the transition training we satisfy the flight review requirements! So I think the FAA is serious about this.
 
The answer is a flat-out ?no? - unless you have access to an RV and an instructor who are truely free, no gas, no strings attached.
I have the waiver from the FAA to give transition training for hire in my RV. But the paperwork says I may not sign off a flight review under this waiver, even if during the course of the transition training we satisfy the flight review requirements! So I think the FAA is serious about this.

I had no issues using my transition training as a flight review. Sounds like others have done the same. Maybe you got some screwy limitations? The FAA isn't known for their consistency, except when it comes to lack of common sense.

As for the OP, if you can find a willing transition training instructor (without the limitation above) I don't see why you couldn't do it. There is no requirement about having to own or be building an RV to get transition training.

Chris
 
Most interesting, is it a "LODA" you have? Why would this restriction be given to you, any idea of a reason? This seems to be all kinds of silly stuff.

The answer is a flat-out ?no? - unless you have access to an RV and an instructor who are truely free, no gas, no strings attached.
I have the waiver from the FAA to give transition training for hire in my RV. But the paperwork says I may not sign off a flight review under this waiver, even if during the course of the transition training we satisfy the flight review requirements! So I think the FAA is serious about this.
 
To answer the above questions:
Yes, the FAA calls the waiver a ?LODA? - ?Letter of Deviation Authority?.
The FAA?s (or at least, the OAK FSDO) stand seems to be no for-hire use is allowed unless there is no way except in an EAB. My LODA specifically forbids me from signing off a high performance endorsement or a Flight Review, even if these things were accomplished incidental to the transition training. It also forbids ?introductory rides?. It says the pilot must reasonably expect to complete an RV-10, or purchase an already built one, within 6 months. (I?m sure ?reasonably? is up for arguement, just as ?Is buying gas compensation??).

I wish it were otherwise. I am currently not doing transition training, since the cost of the extra insurance exceeds what I made. If I were able to give introductory rides, or Flight Reviews, there might be enough interest to justify the cost.
 
No doubt in my mind if an instructor is giving transition training, he would also log the Biennial flight review in your logbook. It's just a matter of request.
 
No doubt in my mind if an instructor is giving transition training, he would also log the Biennial flight review in your logbook. It's just a matter of request.

From my limited researched knowledge, it appears that CFI and LODA people are doing lots of unauthorized stuff with flight reviews, apparently this is just another of those examples. It is hard to understand how the LODA could supersede other FAA instructions.
 
From my limited researched knowledge, it appears that CFI and LODA people are doing lots of unauthorized stuff with flight reviews, apparently this is just another of those examples. It is hard to understand how the LODA could supersede other FAA instructions.

It requires an understanding of what a LODA is.
LODA - Letter Of Deviating Autority

It is a written document (letter) from the FAA, authorizing someone to deviate from some portion or specific detail of the FAR's.
In this case, the FAA got behind the idea that if type specific transition training were done, that it would improve safety. The FAA new that they couldn't expect a lot of CFI's to provide their aircraft for free so they needed to have a way around the "no compensation or hire" usage of E-AB aircraft, but instead of totally rewriting the FAR's, they chose to use the LODA process and issue them on a case by case basis.
Since the only reason it was being allowed, was so that people could safely transition into the model aircraft the LODA is issued to, it typically specifies that it is for transition training only. No primary flight training is allowed, and often times it even mentions other training type operations.

BTW, Mike Seager does transition training in aircraft that are Experimental / Market Survey which specifically allows customer training. Because of this there is no LODA, so no exclusions on signing off BFR's, HP endoresments, or tail wheel endorsements (though I think he prefers people to be tail wheel qualified before they come to fly with him).
There is still the limitation of no primary training.
 
I remember talking about this to an FAA flight standards guy at Oshkosh a few years ago, and he agreed that it seemed silly to him not to allow someone to get endorsements as part of their transition training.

Later, I saw this news release: https://www.eaa.org/en/eaa/eaa-news...leases-revised-loda-policy-for-public-comment

I have not been able to find the actual proposed regulation yet; there was another proposed rule from May 2016 dealing with training requirements but it has apparently not yet progressed to "final rule" status.

Anyway, the FAA is at least apparently looking at this. How long it will take them to progress to a change is anyone's guess. The Part 23 changes took years...
 
So can we then assume that NO CFI with a LODA can do a "legal" flight review (by him in that plane)?

It requires an understanding of what a LODA is.
LODA - Letter Of Deviating Autority

It is a written document (letter) from the FAA, authorizing someone to deviate from some portion or specific detail of the FAR's.
In this case, the FAA got behind the idea that if type specific transition training were done, that it would improve safety. The FAA new that they couldn't expect a lot of CFI's to provide their aircraft for free so they needed to have a way around the "no compensation or hire" usage of E-AB aircraft, but instead of totally rewriting the FAR's, they chose to use the LODA process and issue them on a case by case basis.
Since the only reason it was being allowed, was so that people could safely transition into the model aircraft the LODA is issued to, it typically specifies that it is for transition training only. No primary flight training is allowed, and often times it even mentions other training type operations.

BTW, Mike Seager does transition training in aircraft that are Experimental / Market Survey which specifically allows customer training. Because of this there is no LODA, so no exclusions on signing off BFR's, HP endoresments, or tail wheel endorsements (though I think he prefers people to be tail wheel qualified before they come to fly with him).
There is still the limitation of no primary training.
 
So can we then assume that NO CFI with a LODA can do a "legal" flight review (by him in that plane)?

No

It all depends on what the LODA letter they have says.
Each is issued by a different office. Some may not have the limitations that were intended.
 
Is a LODA public information available to anyone? How can we find out if a person/plane has a LODA or not and therefore what restrictions might apply to him?
 
Is a LODA public information available to anyone? How can we find out if a person/plane has a LODA or not and therefore what restrictions might apply to him?

They're kept on file at the issuing FSDO. If you know which one that is, I imagine they'd send you a copy (for a fee, no doubt). But why not just ask the owner of the airplane to see it, if you're contemplating renting his EAB? I'm always amazed that pilots who have never met me, seldom ask to see my cfi certificate. I could be some nut who just walked in off the street (some probably say I am -:) ). I take no offense at being asked to show someone my certificate.

Shoot, if you want to see mine, I'll bring it home next time I'm at the hangar (it stays in the plane, with the OpLimits); I'll scan it and send you a copy. As I recall there's like half a dozen pages!
 
They're kept on file at the issuing FSDO. If you know which one that is, I imagine they'd send you a copy (for a fee, no doubt). But why not just ask the owner of the airplane to see it, if you're contemplating renting his EAB? I'm always amazed that pilots who have never met me, seldom ask to see my cfi certificate. I could be some nut who just walked in off the street (some probably say I am -:) ). I take no offense at being asked to show someone my certificate.

Shoot, if you want to see mine, I'll bring it home next time I'm at the hangar (it stays in the plane, with the OpLimits); I'll scan it and send you a copy. As I recall there's like half a dozen pages!
What he said. My first interaction with a FSDO was turning in a boss and instructor for not being a CFI. FAA yanked his license. Google the name Hal Harris; the NTSB has some public-facing docs about it.
 
Another Question

All this talk of LODI and renting RVs. I have a question. If I own an RV and want training in MY RV, is it legal to pay a CFI to train me in it?
 
I believe I got scammed by someone, and i doubt he would show it to me for that reason. Trying to get in the back door. I will try your suggestion, thanks.

They're kept on file at the issuing FSDO. If you know which one that is, I imagine they'd send you a copy (for a fee, no doubt). But why not just ask the owner of the airplane to see it, if you're contemplating renting his EAB? I'm always amazed that pilots who have never met me, seldom ask to see my cfi certificate. I could be some nut who just walked in off the street (some probably say I am -:) ). I take no offense at being asked to show someone my certificate.

Shoot, if you want to see mine, I'll bring it home next time I'm at the hangar (it stays in the plane, with the OpLimits); I'll scan it and send you a copy. As I recall there's like half a dozen pages!
 
LODA

It is interesting how relatively few of the LODAs on this list are RVs with the number of RVs that are flying. The guy who did my transition training is on the list but no one else is close to KC. I was very fortunate to get to fly with him a few years ago.

John
RV-8
 
It is interesting how relatively few of the LODAs on this list are RVs with the number of RVs that are flying. The guy who did my transition training is on the list but no one else is close to KC. I was very fortunate to get to fly with him a few years ago.

John
RV-8

And, some (like myself) who have a LODA are not actively using it. Reason: the cost of insuring the airplane and myself for "dual given" exceeds the income, since I am restricted to transition training only. IMHO the very same insurance companies that demand training-before-insuring are the same ones who charge outrageous extra premiums for those doing this training. (The real issue is that no one is set up to insure 10 to 20 hours of dual a year. The policies are written for FBOs.)
BTW, ANYONE who owns an RV may apply for the LODA. You do not need to be a CFI (but the application asks for a list of CFIs who will be allowed to rent your airplane).
 
I'm late to this conversation, but my LODA has the same restrictions that Bob Turner mentions. Transition training only. No Flight Reviews, Instrument Proficiency, High Performance endorsement, etc. I am also no longer providing transition training in my airplane due to the insurance costs that Bob mentions.
 
So a CFI RV owner can give instruction in his plane without a LODA if they don't charge for the use of the airplane. I believe they can charge for their time though. How much could they realistically charge per hour seeing that auto mechanics commonly charge $100 per hour? I would think $60-$100 per hour would not be unreasonable.
 
So a CFI RV owner can give instruction in his plane without a LODA if they don't charge for the use of the airplane. I believe they can charge for their time though. How much could they realistically charge per hour seeing that auto mechanics commonly charge $100 per hour? I would think $60-$100 per hour would not be unreasonable.

The rulings that come out of courts often surprise me. But in this case, my opinion is that the FAA lawyers would rip this arguement to shreds. The airplane is being used to generate compensation for its owner, the cfi. Now, if you separate the two - you have an owner, not the cfi, who will genuinely let you borrow his plane for free - then you can legally pay the cfi. Same as if you are the owner.
BTW, actual cost numbers from when I was doing transition training in my -10: gas, $50/hr; insurance (just extra cost for giving dual), $400 per person (or $80/hr if 5 hours were needed); wear and tear on brakes, tires, ....??. So you see that your suggested ?rate? doesn?t come close to covering costs.
 
I have a LODA (authorization from the FAA) to do transition training in the RV-14. Last year I went thru the process. I'm sure that there is at least a SMALL chance that some people would have different results than I did, but, in my case doing a Flight Review in the RV-14 not all all do-able.

As part of my authorization I cannot even give transition training unless the pilot ALREADY has a current "BFR". If I were to charge someone, even for my time, (who was not doing transition training) that would be considered using an experimental for commercial purposes, which is expressly illegal. Insurance wise, to be PIC in the plane they have to meet my insurances' requirements, and they are fairly high so many pilots would not (for non-transition training this is), otherwise in theory I could give the airplane for free and my time for free and do a flight review if the person was covered. But I would never extend myself that way due to the insurance requirements. I can, however, do a BFR for anyone who I'd be willing to do this for, such as family, or named-insured friends.

My advice would be if you need a Flight Review, just go get the flight review and get it over with. Don't worry about the "RV" part of it. Use that time to go fly some airplane type you've never flown before, and make it fun, perhaps. Go get some retract time and combine a BFR with some instruction. Time in varied makes and models is valuable to you as a pilot. Then, once you're current, go call up an RV pilot who may or may not be a CFI and let them give you some stick time. Don't expect them to let you land it. I learned the hard way doing demo flights in my RV-10 that even people with 5000 hours can be a risk, so I won't let most people land it. The worst landing my RV-10 ever had was by a 5000 hour pilot...and I was stupid enough to let him try a 2nd time.

But whatever you do, don't try to skirt the commercial laws. If it gets out, it not only gets you in trouble but gives our whole experimental amateur-built type a little more of a black eye that we just don't need.

Regarding the insurance for having a LODA, it's big dollars. I would have to say that in general, it's not worth it as a CFI to even offer the training unless you're just dying to give away your life's free time to strangers who are coming to you to possibly damage your plane so that they don't damage their own. The only reason I got the LODA was to support the RV-14 community. It's definitely a way to lose money though. I could easily get the LODA for my RV-10 as well, but I decided I didn't need to have multiple ways for myself to spend more money in a year than I'd get back, and risk damage to my pride and joy at the same time.


On a separate note, if you OWN your own RV, and you want to get flight training in it, it's completely legal for you to pay the CFI for his time and get training. That is far more attractive to me. It would even be POSSIBLE for someone to buy an RV and learn to fly in their RV. The big catch there would be getting the insurance if you don't already have the private cert and required amount of time to get the insurance. There are insurers out there that will require 250 hours just to insure a pilot in an RV. There are some who will insure you with zero hours, but at a very high rate. I'm currently paying the latter for my daughter.
 
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To anyone nearing their first flight, stick time with someone in any RV, even if they aren't a CFI is far better than doing it totally cold turkey, but I would recommend that be used only as a last resort.

As Tim himself mentioned, landings need to be learned, and you will only learn by doing. That requires someone that is willing to allow you to try (actually doing landings) and has the abilities to help you through the process.

Landing technique is the majority of the focus during transition training

The value of using an experienced instructor like Tim or any of the others can't be over emphasized. I have been using Mike Seager for flight reviews and other specific training for over 20 years and I still learn new things about flying these airplanes when he and I fly together.

With all of the time and money that gets put into building an RV, don't short circuit the process at the end by not being as prepared as you possibly can be.
 
In case anyone else is trying to get a copy of someones LODA, my request to the FSDO was returned today, saying I needed to resubmit it on a FOIA request form!
Sometimes the silliness of the FAA can get to me. Rather than simply email it to me, now we have to employ a whole fleet of people that handle FOIA requests. Maybe privatizing is not such a bad idea after all.
 
In case anyone else is trying to get a copy of someones LODA, my request to the FSDO was returned today, saying I needed to resubmit it on a FOIA request form!
Sometimes the silliness of the FAA can get to me. Rather than simply email it to me, now we have to employ a whole fleet of people that handle FOIA requests. Maybe privatizing is not such a bad idea after all.

Why do you think someone's FAA records should be publicly available in the first place? It bothers me that they make public my aircraft registration info, including home address, as well. No state driver's license bureau does that with vehicle licenses. Not sure why airman records should be any different, in that they should not just be "out there" for anyone to access. Just my opinion, of course....
 
private

I believe you can make some of the FAA records private, and not have everything available in the public database. Most flight attendants do this.
 
Why do you think someone's FAA records should be publicly available in the first place? It bothers me that they make public my aircraft registration info, including home address, as well. No state driver's license bureau does that with vehicle licenses. Not sure why airman records should be any different, in that they should not just be "out there" for anyone to access. Just my opinion, of course....

I asked the FAA once. They said:

"Are records are public for safety."

Yes, "are". :rolleyes:

I don't see how "safety" is enhanced by making this stuff public.
 
I do. A few years back I got a letter from the FAA informing me that the last three annuals on my Cherokee were performed by a person hired and acting as an IA by the local airport, who did not even have a mechanics license!
To me it is safer to have annuals and maintenance by a licensed repairman. I certainly have no problems whatever with having my credentials made available to people that might be harmed by my dishonesty. Should I be?

I asked the FAA once. They said:

"Are records are public for safety."

Yes, "are". :rolleyes:

I don't see how "safety" is enhanced by making this stuff public.
 
I do. A few years back I got a letter from the FAA informing me that the last three annuals on my Cherokee were performed by a person hired and acting as an IA by the local airport, who did not even have a mechanics license!
To me it is safer to have annuals and maintenance by a licensed repairman. I certainly have no problems whatever with having my credentials made available to people that might be harmed by my dishonesty. Should I be?

How is knowing the home address of the owner of an aircraft increasing safety?
 
Yes, that's why I highlighted Airmen Certificate in both the Title and Body of my post. As another poster said, "you can make some of the FAA records private".

But I agree, I think that Aircraft Owners should be able to keep their information private also.

I know...I wasn't arguing with you.

I guess it'll take something similar to the case where the murderer tracked down that actress' address from her auto license, which led to states making that info private, before the FAA will change.
 
This struck me as odd, not being able to give a BFR in your plane.
I recently sent for a copy of a LODA for someone I knew, and found NO REFERENCE whatever to a BFR requirement nor any prohibition against giving a BFR. Is this normal practice, or does it just strike each FSDO differently each day of the week?

I have a LODA (authorization from the FAA) to do transition training in the RV-14. Last year I went thru the process. I'm sure that there is at least a SMALL chance that some people would have different results than I did, but, in my case doing a Flight Review in the RV-14 not all all do-able.

As part of my authorization I cannot even give transition training unless the pilot ALREADY has a current "BFR".
 
This struck me as odd, not being able to give a BFR in your plane.
I recently sent for a copy of a LODA for someone I knew, and found NO REFERENCE whatever to a BFR requirement nor any prohibition against giving a BFR. Is this normal practice, or does it just strike each FSDO differently each day of the week?

I have a LODA (authorization from the FAA) to do transition training in the RV-14. Last year I went thru the process. I'm sure that there is at least a SMALL chance that some people would have different results than I did, but, in my case doing a Flight Review in the RV-14 not all all do-able.

As part of my authorization I cannot even give transition training unless the pilot ALREADY has a current "BFR".
The FAA?s position is quite clear: an EAB airplane may not be used for compensation. They will issue a waiver (LODA) specifically for transition training only because it cannot realistically be done in anything other than an RV. Every LODA I?ve seen says ?transition training only?. Now there is the question, ?If during transition training we satisfactorly accomplish all the elements of a Flight Review, may I (as a cfi) endorse the pilot?s logbook as Flight Review given?? My LODA says ?no?. This strikes me as unusually strict. But I guess if it was otherwise, people would cheat - e.g., ask for/offer transition training when all they really wanted was a Flight Review. Just to be clear, a LODA is needed for the EAB to be used for compensation. You may get and pay for a Flight Review in your EAB, the presumption being that you don?t rent the plane from yourself.
 
Interesting. To make a discussion, the words "for transition training only" certainly does not infer to me that you could not use your plane for pleasure or sightseeing or personal travel - or giving a flight review. The one I received however had the statement that the plane can make "No demonstration flights are allowed". I am not even sure what a "demonstration flight" consists of.

This struck me as odd, not being able to give a BFR in your plane.
I recently sent for a copy of a LODA for someone I knew, and found NO REFERENCE whatever to a BFR requirement nor any prohibition against giving a BFR. Is this normal practice, or does it just strike each FSDO differently each day of the week?


The FAA?s position is quite clear: an EAB airplane may not be used for compensation. They will issue a waiver (LODA) specifically for transition training only because it cannot realistically be done in anything other than an RV. Every LODA I?ve seen says ?transition training only?. Now there is the question, ?If during transition training we satisfactorly accomplish all the elements of a Flight Review, may I (as a cfi) endorse the pilot?s logbook as Flight Review given?? My LODA says ?no?. This strikes me as unusually strict. But I guess if it was otherwise, people would cheat - e.g., ask for/offer transition training when all they really wanted was a Flight Review. Just to be clear, a LODA is needed for the EAB to be used for compensation. You may get and pay for a Flight Review in your EAB, the presumption being that you don?t rent the plane from yourself.
 
The waiver (LODA) is for using the airplane for compensation. You don?t need the waiver if no compensation is involved, like personal travel. No waiver is needed if you get a Flight Review for free. But a CFI cannot furnish his airplane ?for free? and charge for his services - the airplane is clearly tied to him being compensated.
 
Thank you to everyone in advance. I am new here and just bought my first RV last week.

I am an active CFI with no LODA (yet...maybe)

Can I offer flight training with me, and my plane, if no money changes hands?

ie: a young person spending time with me to suppliment their private, a few approaches with a friend to get current, etc.

Or...does anyone know if, because a Comm is required to have a CFI, that ALL training is considered "commercial" regardless of money changing hands?

Thx,

Hoody
 
Thank you to everyone in advance. I am new here and just bought my first RV last week.

I am an active CFI with no LODA (yet...maybe)

Can I offer flight training with me, and my plane, if no money changes hands?

ie: a young person spending time with me to suppliment their private, a few approaches with a friend to get current, etc.

Or...does anyone know if, because a Comm is required to have a CFI, that ALL training is considered "commercial" regardless of money changing hands?

Thx,

Hoody
As long as you pay your pro rata share of the expenses, you are not flying for hire, so you can do it.
 
Airshow performer use of EAB aircraft

I've always wondered at the regs that will not allow the needed training in EAB but allow some airshow pilots to make a living using their EAB aircraft.
Anyone got any ideas?
 
The FAA’s position is quite clear: an EAB airplane may not be used for compensation.

I've always wondered at the regs that will not allow the needed training in EAB but allow some airshow pilots to make a living using their EAB aircraft.
Anyone got any ideas?

I get the primary training vs transition training and LODA stuff. However, I'm not sold on the total no compensation bit outside of the training issues.

Can someone point me to where it says you can't be compensated for performing other, non-training tasks with an E-AB aircraft?
I get 91.319 states:
(a) No person may operate an aircraft that has an experimental certificate—
(1) For other than the purpose for which the certificate was issued; or
(2) Carrying persons or property for compensation or hire.

And my OPLIMS, issued under the older FAA order 8130.2G (current version is 2J IIRC) has the same verbiage as 91.319 (a) (2). I'm also prohibited by my OPLIMS from glider towing, banner towing, or intentional parachute jumping.

But what about skywriting or aerial photography? Why couldn't a pilot flying their own E-AB be compensated (ie paid) for those activities? There's no carriage of persons or property.
 
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I get the primary training vs transition training and LODA stuff. However, I'm not sold on the total no compensation bit outside of the training issues.

Can someone point me to where it says you can't be compensated for performing other, non-training tasks with an E-AB aircraft?
I get 91.319 states:
(a) No person may operate an aircraft that has an experimental certificate?
(1) For other than the purpose for which the certificate was issued; or
(2) Carrying persons or property for compensation or hire.

And my OPLIMS, issued under the older FAA order 8130.2G (current version is 2J IIRC) has the same verbiage as 91.319 (a) (2). I'm also prohibited by my OPLIMS from glider towing, banner towing, or intentional parachute jumping.

But what about skywriting or aerial photography? Why couldn't a pilot flying their own E-AB be compensated (ie paid) for those activities? There's no carriage of persons or property.

When reading a document in the context of "legal" meaning, single specific words can mean a lot (even if the person reading it doesn't understand the relevance).

In that context, ask your self why does it say compensation and hire? Wouldn't just one suffice?

Apparently not.

So now you need to find out what the FAA means by those two terms.

Unfortunately, in this case, the writer (FAA legal dept) gets to define the terms, not the person reading them. The FAA has been very clear in the past regarding what their definition is.
 
When reading a document in the context of "legal" meaning, single specific words can mean a lot (even if the person reading it doesn't understand the relevance).

In that context, ask your self why does it say compensation and hire? Wouldn't just one suffice?

Apparently not.

So now you need to find out what the FAA means by those two terms.

Unfortunately, in this case, the writer (FAA legal dept) gets to define the terms, not the person reading them. The FAA has been very clear in the past regarding what their definition is.

Umm, because they don't mean the same thing? In any event, the way the paragraph is worded to me implies that the compensation and hire prohibition applies to the carriage, and only the carriage, of persons or property. Otherwise if you wanted to prohibit all activities for compensation or hire why not just leave "persons" and "property" out altogether? But they didn't so they made the prohibited activities specific and not general.

I also have no plan to ask the FAA anything. I simply want to know is there a reference that applies the compensation prohibition beyond what's stated in 91.319 such as a reg or FAA General Counsel ruling and not for anyone to try an provide an interpretation of 91.319, legal or not.

NOTE: This if for my edification only -- I have absolutely no desire or need to fly for compensation in any aircraft, regardless of its certification.
 
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