I work operations for a flying club in California. We are a noon profit collective created to rent airplanes to our members. The airplanes are owned privately and leased to the club where members rent them for whatever. The club has a rule that any CFI training students must be a member and go on a brief CFI Checkout.
My question is..... Are we required to perform 100hour inspections on aircraft that are used for training?
2 Answer from Attorneys
FAR 91.409(b) provides that no person may operate an aircraft carrying any person (other than a crewmember) for hire, and no person may give flight instruction for hire in an aircraft which that person provides, unless within the preceding 100 hours of time in service the aircraft has received an annual or 100-hour inspection. I was able to find official interpretations of this FAR as applied to your situation. I Googled [100 hour inspection flying club] and came across what purports to be an interpretive letter from an FAA lawyer that says the 100-hour inspection requirement does not apply where the student pilot provides the aircraft. "If a person merely leases or rents an aircraft to another person and does not provide the pilot, that aircraft is not required ... to have a 100-hour inspection. I am unable to determine if this interpretive letter dated from 1984 is genuine, or whether it remains valid. You might want to ask your local FSDO, or have a friend ask them. Remind me to always rent aircraft and instructors from the same entity from now on!