The company I work for owns an aircraft and uses it to take the owner and some of the employees to meetings.(Part 91) The owner asked me about the legality of letting 2 or 3 of our best clients use the aircraft for their purposes and we would invoice them for the flight time.
I guess it’s similar a Part 135 charter but we wouldn’t “hold out” and wouldn’t do it for anyone other than those clients. I called the FSDO here in houston to ask about it and was told that if we are invoicing the client, who has an expectation of commercial service, we are a charter and therefore need an operating certificate.
Of course I am not about to defy the Feds but this seems contradictory to what I’ve read and been taught. Advisory circular 120-12A defines this operation as private carriage. It is not service available to anyone or even a segment of the public, it’s 3 people, no more. Won’t be more. Does anyone have any experience with this sort of thing?