There’s a lot of confusion in aviation circles about Private Carriage, so here’s a clear explanation.

Private Carriage is a form of carriage, and you must hold a Part 119 air operator certificate to conduct it. Noncommon Carriage is also a certificated activity. Basically, anything with the word “carriage” is something you need an operator certificate to do — period.

You cannot conduct Private Carriage or Noncommon Carriage under Part 91. Both are defined under On-Demand Operations in Part 110, and they fall outside the scope of general aviation.

What You Can Do Under Part 91

What you can do as a commercial pilot under Part 91 is provide pilot services. That means you are simply hired as the pilot, flying someone else’s aircraft, under their operational control. This is not considered “carriage” in the legal sense, even if it feels private or selective in everyday language. It’s just general aviation under Part 91.

Why People Get Confused

One reason people get confused is because the term Private Carriage sounds like it just means “private flying” in the everyday sense, when in reality it’s a legally defined category of certificated operation. I personally don’t like the term because it invites misunderstanding and makes people think they can run private flights without certification, when that’s not the case.

The Bottom Line

Part 91 + pilot-for-hire can be legal if you’re only providing pilot services and are not exercising operational control or engaging in an activity that otherwise requires certification.

However, it’s important to remember that even these arrangements can become illegal if they cross other regulatory lines, like improper cost-sharing, wet leasing, or violating operational control rules.

Part 91 + transportation-for-hire becomes illegal if you’re acting as the operator without a Part 119 certificate — no matter how small or private your client group is.

Part 119 Flow Chart

Here is a flow chart from FAA Order 8900.1, Volume 3, Chapter 18, Section 2, outlining how commercial operations break down under Part 119. This is an excellent reference for understanding where the different types of carriage and certification requirements fit together:

Part 119 Air Commerce Flow Chart showing the breakdown of Common Carriage, Common Carriage Not Involved, and Exceptions to Part 119, with their respective certificate requirements and regulatory references.
Part 119 Air Commerce Flow Chart — FAA Order 8900.1, Vol. 3, Ch. 18, Sec. 2

References

  • Part 110 Definitions (Private and Noncommon Carriage as subsets of On-Demand Operations): 14 CFR 110.2
  • FAA Order 8900.1, Volume 3, Chapter 18, Section 2 (Part 119 Flow Chart): FAA Dynamic Regulatory System
  • 14 CFR 119.23(b) (Private and Noncommon Carriage require an operations certificate): eCFR §119.23(b)