Aerial photography

[niknak]

I need to take some aerial photographs of a site in Lincolnshire.
Although the photo's will be used to assist in the decsion making process of an investment in a business venture, they will essentially be for my own use and will not be sold on.

I approached a three flying training organisations at the nearest airport to the site, (I intend to visit the site on the same day I wanted to photograph it), and they all said they were unable to provide an aircraft plus pilot for aerial photography, even though I was quite happy to treat it as a "trial flight" which would take no more than 30 minutes.

I know that they all have suitable aircraft for the purpose and that a few years ago, they all would have had no problem with the request.
Are they misinterpereting the rules of flights for hire and reward, (I haven't checked the ANO!)?

If so, it's bit of a pain, because I now have the limited, and very expensive choice of hiring an aircraft and pilot for a minimum of three hours, (home up to Lincolnshire - 1.2hrs, take the photo's - 0.5hrs, land, go to the meeting, then return home -1.2hrs), or hire a professional photographer to do the same thing for me at even greater cost.

Any constructive information or suggestions appreciated, PM me if you would prefer to do so.
Ta.

[ChrisVJ]

You might see if there is someone within reasonable distance doing baloon photography.

I met a chap in S of France a couple of years ago who does this. Remote contolled camera using video monitor and lifted by a helium baloon (about 12 ft by 8ft dia.)

Sadly much cheaper than commissioned from plane photos and beautiful pictures.
I'm sorry I removed his site from my bookmarks a couple of weeks ago as it had links to other practitioners all over Europe.

[Say again s l o w l y]

A trial flight is an "air experience" flight. Part of the PPL syllabus.

Whilst aerial photography for reward is definately out, I certainly have no issue with people on trial flights taking photo's of their own homes etc. since they are doing it for no financial gain.

There is a large microscope over the activities of aerial photographers at the moment, since there are a large number of cowboy's out there doing it without an AOC.

Schools are notoriously suspicious about things like this and it is probably a case of "not sure, so we won't take the risk for only one flight."

I had it explained to by an CAA Ops inspector recently when I had a query from a student about going to a meeting whilst he was doing Nav training.

"As long as there is some training benefit, why not? It's exactly what he's going to be using his licence for when he's passed. What happens when he's on the ground is an irrelevance as long as the flight itself doesn't form part of the business deal."

Would going off for a trial lesson specifically for the purposes of taking photo's be O.K? Not in my opinion, but if you happened to be doing a trial lesson in a certain area and it happens that you took some pictures for personal use, I can't see a problem.

Unfortunately it sounds as if these photo's will be used as a basis for a business deal, so if you took it to the letter of the law there may well be some financial gain to made from them.
A bit of a narky argument, but you can surely understand why a flying school wouldn't want to risk any chance of a kicking from the CAA over this for a measley 30 mins flying time that might net them £15 at the most.

[aluminium persuader]

Hey niknak!

I'm surprised no-one's offered a "cost-share" flight with you. They get a cheaper hour's flying. you get your pics. Maybe because it's getting near Christmas the clubs are getting booked up with trials.
C'mon guys - someone help an air trafficker out. You might need him one day!

;)

[DubTrub]

Can't you? Which galaxy?

[Good post on fuel tanks & water, btw]

[Phil Space]

"There is a large microscope over the activities of aerial photographers at the moment, since there are a large number of cowboy's out there doing it without an AOC."

Who has the microscope and who is doing the looking?

[Say again s l o w l y]

A certain group of people who work in a large, expensive grey building in the Gatwick area.

[Yorks.ppl]

niknak, depending on when you need to take the pictures I would be happy to fly you FOC to Lincolnshire. obviously you would need to get to yorkshire but from where I fly most of lincolnshire isn't much more than 40 mins away.

[S-Works]

likewise I am at Spanhoe, I will hapilly take you for the flight free of charge and then there is no hire and reward at play.

152 so ideal for photos!

I never need an excuse to go flying!:D

[ANW]

As long as the aircraft is operating on a public transport C of A and is flown by a CPL holder then there is no problem. An AOC is not required for commercially flown aerial photography flights in the UK. The job is classed as 'Aerial Work', and is exempt from the AOC requirement.

[aluminium persuader]

Thanks, DubTrub. And when I find out I'll let you know!

ap
;)

[dwshimoda]

NikNak,

Like others - I'm happy to fly you foc - be fun to have an actual "mission" to do! I'm at Cranfield and have a 172.

DW

[Pierre Argh]

If what you really want is an aerial photograph (and not the experience) there are plenty of methods of obtaining ready-made photos... try www.earth.google.com

... but if this doesn't cover the area in sufficient detail you can buy shots, that would probably be cheaper than paying for a photography trip, from

www.getmapping.com

[PH-UKU]

Hi niknak, I may be up in the frozen north ...... but I'm always looking for some fun trips to do.... just depends on how quickly you need it done.

I've got a souped up 172, good for short strips, and also used to be an ATCO in Lincolnshire .... so a nostalgia trip would be fun.

Where abouts are you an ATCO? Could we do a ScACC liaison visit (me and 10W perhaps) and see if NATS would pick up the mileage :E ?

[Squawk 2650]

ANW I was waiting for someone to say that. I dont know why people think you need an AOC to do survey work??

Sorry, don’t want to take this thread away from the original post.

S
:cool:

[l_reason]

Just for the fun of helping you make a great aerial photograph here are a few hints. I have made a living shooting aerial photos for four years.

- if possible open the window.
- do NOT rest your arm the window frame or door
- set your camera’s shutter speed above 1000th of a second.
- circle the property and take lots of pictures, film or memory card space is much cheaper then a second flight

PT

[smarthawke]

niknak

If you want a pro to do it then there is a totally legal setup at Sibson, Aerographics, telephone 01832-280021.

[niknak]

Thank you all very much for the replies and especially for the offers of from those willing to take me up for nothing.

Unfortunately the venture has proved to be no longer viable and so there is no need for the aerial photographs, but I am very very grateful for the responses.

Thanks again.:ok:

[Hidden Agenda]

Squawk 2650, maybe now we can hi-jack this thread.

You say: “ANW I was waiting for someone to say that. I don’t know why people think you need an AOC to do survey work??”

I am not that up to date on UK regulations but I work in a location that looks to the UK & the CAA for leadership in such matters, hence my interest.

Whilst understanding and agreeing (to a certain extent) with your argument would I be right in thinking that this is only true providing that your organisation does not have an AOC?

In other words if you have an AOC and carryout some passenger transport operations you are the classified as an air transport undertaking and therefore all flights where a passenger is carried, for whatever purposes, is then considered public transport.

The extent to which I agree with your argument stops as soon as the person climbs on board to operate the camera. Does the camera operator not count as a passenger and therefore make the flight public transport assuming reward for the flight is offered or promised.

I would be interested to hear an elaboration of your comments.

[bookworm]

As long as the aircraft is operating on a public transport C of A and is flown by a CPL holder then there is no problem. An AOC is not required for commercially flown aerial photography flights in the UK. The job is classed as 'Aerial Work', and is exempt from the AOC requirement.

I think the problem's over what the payment is for. If the payment is to send a crew off to take aerial photographs for you, then that is without doubt aerial work.

If the payment is to allow you to sit there in the aircraft and take photographs, then you've just become a paying passenger.

If so, it's bit of a pain, because I now have the limited, and very expensive choice of hiring an aircraft and pilot for a minimum of three hours, (home up to Lincolnshire - 1.2hrs, take the photo's - 0.5hrs, land, go to the meeting, then return home -1.2hrs)

Can you not just hire an aircraft from the FTO, fly it yourself, and take an unpaid friend to do the photography?

[Captain101]

Aerial photogrphy does not need an AOC.
Several commercial aerial photography firms have had this confirmed after a CAA investigation, I know of 1 operator who previously had an AOC but has now dropped it in light of the CAA's findings and clarification.

The reason you don't need an AOC is because the profit is from the images only, the aircraft is just a tool to get to the phography site, the same as a businessman being flown to a meeting in his own aircraft does not require an AOC.

However, if the aircraft is chartered to a photographer such that the aircraft itself generates profit, this becomes aerial work and does require an AOC.

Not all passenger carrying flights are public air transport. If the aircraft departs and arrives at the the same point with no intermediate stops and is operated VFR (pleasure flights) the operation is classed as aerial work, it does require an AOC, but these AOC's are much cheaper and easier to obtain.

Say again s l o w l y - some of the most proffesional aerial photography operations around don't have an AOC. Just because they don't have the bit of paper doesn't stop them from implementing the associated SOP's and certainly doesn't make them cowboys.

[homeguard]

Captain101 explains this issue correctly but there is one other thing to say.

If the pilot ia also taking the photos that is OK although we would all agree it is maybe hazardous. However should the photographer be carried as a passenger then the flight may be construed as a passenger carrying flight for the purpose of 'hire and reward' note; 'hire and reward' - payment is not specified. It could be said that being bought dinner is the reward and successful proscecutions have cited just that.

Much better that the Pilot/Photographer takes the photos and takes with them another valid pilot to act as a safety officer who will only take control in the event the the pilot/photographer losses it. In that way it cannot be construed that 'hire and reward' is taking place.

[bookworm]

Not all passenger carrying flights are public air transport. If the aircraft departs and arrives at the the same point with no intermediate stops and is operated VFR (pleasure flights) the operation is classed as aerial work,

Can you cite any UK law to back that up?

[Say again s l o w l y]

Some may be professional, but many are not. I have seen and heard of some outfits that hire a low hours CPL holder to fly solo at low-ish level AND take photographs at the same time.

If that isn't a cowboy operation, then I don't know what is.

[IO540]

being bought dinner is the reward and successful proscecutions have cited just that

Can you provide a reference?

I know a solicitor with access to the legal databases so a case ref will do just fine.

I tell you why I ask: who on earth is going to fly somebody when the "reward" is a dinner? Even a lawn mower strapped to one's back is going to have an operating cost way exceeding the value of a dinner.

Now, if the "reward" was something rather more "personal" ;) that might be a whole different scenario. But if that got you prosecuted, a large percentage of UK's PPL instructors would be in jail :O

[homeguard]

IO540

Sorry I can't provide you with lots of detail.

I believe that the incident was this. The PPL was investigated for flying a Rugby team on a number of occasions. His defence in court was that he did so as a favour but admitted in court that the team paid his hotel and Evening dinner as a thank you for the flight but he did not receive any payment toward the actual cost of the flight. As I remember it this was sufficient for him to be found guilty for receiving a reward given specifically for the flight. Poorly advised by the sound of it. It wasn't held good enough for him to claim that as an owner/operator of an expensive aeroplane that he could afford his own hotel and dinner. The fact was he had received the hospitality wholely or partly for the flight itself. Remember the words within the ANO are 'hire or reward'

[IO540]

homeguard

I am sure there is more to this one.

For starters, who reported him to the CAA? I bet it wasn't one of the rugby players.

I would guess, purely guess (but I've seen something similar happen a few years ago) that the said rugby team contacted a local air taxi firm(s) for a quote. If such a firm (an AOC holder of course) doesn't get the job, they will keep an ear very close to the ground afterwards to see who did get it - this is a VERY small world. But there are plenty of pleasure flight (oooops, I meant to say "trial lesson") operations and if the customer is then seen to be walking up to G-XXXX which belongs to a firm or an individual which everybody knows doesn't have an AOC, the CAA will be told within the hour.

Even so, IMHO it would take a bit more than flying the same bunch of people around on a few occassions. He may have done something else, but it could not be proved. The police used to do this routinely on motoring offences, as I know to my cost.

What happens to the PPL cost sharing scheme? If the flight costs say £100 then 3 passengers can legally buy you a £75 meal. Did he exceed the 3-passenger limit? Was it really a 6-seater? It must have been some 6-seater to carry more than 3 rugby players and enough fuel for a circuit :O

Or was it foreign reg? No cost sharing is allowed in those under the ANO (i.e. in UK airspace). One has to be seriously careful if flying people in an N-reg.

[bookworm]

Remember the words within the ANO are 'hire or reward'

I don't think it undermines what you say homguard, but in fact those words don't appear in the ANO (you may have got them from the FARs). The basic rules are:

157(1)Subject to the provisions of this article and articles 158 to 163, aerial work means any purpose (other than public transport) for which an aircraft is flown if valuable consideration is given or promised in respect of the flight or the purpose of the flight.

157(3)Subject to the provisions of this article and articles 158 to 163, an aircraft in flight shall for the purposes of this Order be deemed to fly for the purposes of public transport:
(a) if valuable consideration is given or promised for the carriage of passengers or cargo in the aircraft on that flight;

155 ‘Valuable consideration’ means any right, interest, profit or benefit, forbearance, detriment, loss or responsibility accruing, given, suffered or undertaken under an agreement, which is of more than a nominal nature;

[IO540]

The "nominal nature" bit is interesting. Is it defined anywhere?

I would say that whether something is "nominal" depends on the income of the recipient.

A lunch ought to be nominal to most people, especially somebody hanging around aviation.

A hotel room perhaps not but it could easily cost the same as a lunch.

This reminds me of the Inland Revenue IHT exemption; one can make unlimited gifts out of one's income. They just have to be small enough to not affect the donor's standard of living.

[DFC]

The problem from a customer's point of view with trying to do aerial photography on a "trial lesson" is that the weather may be suitable for said trial lesson but unsuitable for the photography. You have to fly or pay a canellation fee!

Great for the school!

Regards,

DFC

[Squawk 2650]

Hidden Agenda The reason I wrote this was because most of the aerial photography companies I know of DONT have an AOC. That was an interesting point about hiring the aircraft out but I’m still not entirely sure you need an AOC for that I will have to do some more reading up.

As for the pilot taking the pictures himself as well as flying the aircraft I thought that was totally illegal!!

S
:cool:

[l_reason]

First off I will say I have no idea about the regulations in GB. I am one of those guys that call my self an aerial photographer. I own a small business shooting aerial photos of farms and rural homes for companies that go door to door selling the finished product. I can agree the job I do can be a bit busy at times. The flying part of the job can only take up about 10% of my attention the rest is devoted to getting a great photos, mapping, ATC and looking out for radio towers & traffic. Each summer I shot around 25,000 photos 350-500 a day from 500AGL. As for the legalities of it in Canada we are allowed to use a privately registered aircraft as long as the pilot is alone and compensated for the photography, not the flying. I am no stranger to Transport Canada enforcement due to the my inevitable low flying complaints, they have never had an issues with the way I run my business. My style of flying on the other hand is a different story.

PT

[IO540]

Regardless of anything else, I am sure that a sole pilot taking pics is not illegal.

For a start he might have an autopilot. Pilots who have never had one (the vast majority of PPLs I guess) have no idea how this reduces cockpit workload.

Also he might have a proper camera fitment. I once video'd most of the Spanish coast, flying alone. On autopilot, twiddling the heading bug, and with a camcorder fixed to the window on a custom made bracket. As usual outside the UK, not a single other aircraft to be seen or heard.

With a camera window and a remotely controlled camera one could do great still and video work, flying alone.

What is possibly unsafe (though not illegal as such) is flying an old C152 at 501ft agl in a 60 degree bank while holding a camera against the window :O

[l_reason]

I’ll tell you how most of us shoot low level oblique aerial photography SOLO.
- Usually done from a C-150, or C-152. I own a 1947 Luscombe 8E that I use.
- In a C-150 sit on the right side I have to sit on the left because that’s where the brake pedals are.
- ALWAYS OPEN THE WINDOW.
- tape a remote shutter button to the wheel or stick with a wire long enough to reach the camera.
- hold the camera with your right hand around the lens so its possible to operate the zoom with your ring & pinkie fingers.
- look through the camera sight & snap a photo using remote shutter wire (left hand).
- do everything ethos with your left hand; control plane, throttle, carb heat & PTT.
Don’t forget to keep a good scan going. After a thousand hours of taking photos like this. I have realized that there is only 2 things you NEED to look at on the dash; oil pressure and oil temperature everything ethos you should already know.

IO540
You hit it right on the head “flying an old C152 at 501ft agl in a 60 degree bank while holding a camera” but you forgot the part about the stall horn screaming. ;)

PT

[Squawk 2650]

Does anyone know who I can phone at the CAA to try and clear this up once and for all!!??

S
:cool:

[sierracharlie]

The link

http://www.caa.co.uk/docs/33/SRG_GAD_AERIAL_PHOTO.PDF

contains the following contact for further information

For more information contact the CAA’s General Aviation
Department on 01293 57 3517
E-mail: [email protected]

[spernkey]

I have done this for a living for 20 years and would submit as follows:The photographer counts as "Crew" and not as a paying passenger. We choose to train hours building commercial pilots to help them build hours - it isnt everyone who should become an instructor to notch up a few hours. We always use 2 man crews but have no judgement to make on single man crew operators as there is an argument that the one that gets you will get you even if you have the whole of the airframe crammed with eyes(esp. the low fast stuff).
Further that nowadays with the advent of Digital cameras and the "multiplying" effect there is no need to fly low and slow - all of our stuff is shot upwards of 1800 feet agl where, given the efficiency of the german silencers, you would be hard pressed to hear us either.
It wouldnt surprise me if the powers that be decide that more regulation is necessary as we all feel a lot safer when there is a few more rules don't we? and what would you expect a regulatory body to think is more important 2-300 peoples livlehoods or a few more well meaning rules(read pricing the whole thing out of existance). Fortunately there are, in my experience, quite a few decent people in the CAA who value flying in all it's forms even though(unlike theFAA) they have no remit to actively "Promote" GA. So there is hope.
One last thought - what would all the monthly flying magazines look like with pics. of aircraft parked safely on the ground because the AOC operators would need both the photo ship AND the subject A/C on their hallowed AOC? or if any air-air shots of your own were suddenly decreed as been for "Reward" because you later decide to use them to sell your aircraft at alater date.
There are enuff rules to prosecute tossers with methinks?

[spernkey]

I have done this for a living for 20 years and would submit as follows:The photographer counts as "Crew" and not as a paying passenger. We choose to train hours building commercial pilots to help them build hours - it isnt everyone who should become an instructor to notch up a few hours. We always use 2 man crews but have no judgement to make on single man crew operators as there is an argument that the one that gets you will get you even if you have the whole of the airframe crammed with eyes(esp. the low fast stuff).
Further that nowadays with the advent of Digital cameras and the "multiplying" effect there is no need to fly low and slow - all of our stuff is shot upwards of 1800 feet agl where, given the efficiency of the german silencers, you would be hard pressed to hear us either.
It wouldnt surprise me if the powers that be decide that more regulation is necessary as we all feel a lot safer when there is a few more rules don't we? and what would you expect a regulatory body to think is more important 2-300 peoples livlehoods or a few more well meaning rules(read pricing the whole thing out of existance). Fortunately there are, in my experience, quite a few decent people in the CAA who value flying in all it's forms even though(unlike theFAA) they have no remit to actively "Promote" GA. So there is hope.
One last thought - what would all the monthly flying magazines look like with pics. of aircraft parked safely on the ground because the AOC operators would need both the photo ship AND the subject A/C on their hallowed AOC? or if any air-air shots of your own were suddenly decreed as been for "Reward" because you later decide to use them to sell your aircraft at alater date.
There are enuff rules to prosecute tossers with methinks?

[bookworm]

I have done this for a living for 20 years and would submit as follows:The photographer counts as "Crew" and not as a paying passenger.

I'm sure that's correct if the photographer is employed by or under contract to the aerial photography company. But that's different from niknak paying someone to take him flying so he can take photos.

[spernkey]

Apart from the small matter of "Technical" law can you agree that it still ammounts to the same thing ie 2 consenting adults getting in a plane and pointing a camera for a bit - same risk exposure - same aircraft - the law is an ASS! What we really need is some more stupid rules to tidy up these anomalies caused by the first set of stupid rules!-i think not.
Cynical freinds tell me all this "Hire and reward" stuff was probably brought in to serve the self interest groups stacked around the sausage factory that spits out commercial pilots - i couldn't say one way or the other.

[bookworm]

I think the key is an explicit appreciation of the risk exposure and the measures to mitigate it. The law on PT is there to protect Joe Punter, who has a right to expect a particular level of risk, appropriate to an air transport undertaking. A PPL (CPL, whatever) who wants to take photos from the right seat undoubtedly understands and accepts the risks associated with private flying. Difficult to legislate for that subtlety though, without creating glaring loopholes.

[IO540]

I agree that a "public transport" passenger can be reasonably regarded as having a greater expectation of safety that somebody who is getting a free ride.

One could argue that the above is nonsense; an absolutely negligible % of fatalities could possibly come from the difference between G-reg PT and non-PT maintenance regimes, but I concede that for some reason Joe Public buying a ticket is less expecting to die than one not buying a ticket. If there was a problem then I'd suggest it comes from flying 30 year old wrecks :O

The problem is that the regs which classify a flight as PT extend far far beyond what a reasonable person might regard as such.

One example is rental, which is automatically classed as PT. Even if I rent a plane from my own business (a business which I own 100%) that makes it PT. Renting the same plane to somebody else, for a completely private flight, is also PT.

To that extent I think spernkey is right; the PT regs have been extended right into the gutter to protect the PPL flight training industry (which relies a lot on self fly hire) by creating a level playing field between the schools, and individual owners wishing to recover some of their costs by renting out their planes. Flying schools moan like hell to the CAA over this sort of stuff.

So, such owners are pushed into the artificial device of creating partnerships, sometimes as limited companies to protect the shareholders from each other's actions, all done to avoid what might appear as "rental".

A lot of the ANO, as applying to GA, is really trade and revenue protection, and cannot possibly by the slightest stretch of imagination be based on safety data.

The FAA has no problem with mandatory maintenance being just the Annual (of course in practice one still does regular maintenance as required for the engine and such, but one doesn't have to chuck anything up to £500 at a JAR145 company to change the oil and the filter) and the aircraft can still be rented out (Part 91). They operate a fleet many times bigger than the CAA and if they had a problem they would know about it.

[spernkey]

Here!! here!! IO540 (and far better put than i could) - if the industry wasn't so riddled with self interest ridden parties getting the ear of the authority we might even still have self-improoving BCPL's to work with - but then there might be less debt ridden wannabe's for the training schools/airlines to abuse and that clearly wouldn't do. To my recolection those guys werent falling out of the sky regularly so people of limited intellect like me just get assuming that move had to be serving someones interest - somehow?

[bookworm]

The problem is that the regs which classify a flight as PT extend far far beyond what a reasonable person might regard as such.

One example is rental, which is automatically classed as PT. Even if I rent a plane from my own business (a business which I own 100%) that makes it PT. Renting the same plane to somebody else, for a completely private flight, is also PT.

I think that's a bit of a distortion, IO-540. Rental is classed as PT only for the purposes of airworthiness, and specifically adds only the requirements of

1) a certificate of Maintenance Review
2) a tech log
3) no pilot maintenance
4) certain other restrictions on running parts past their certified life

As a potential renter of aircraft, I don't think that's an unreasonable standard to ask for. Believe me, you wouldn't want to rent something I had changed the oil filter on.

[funfly]

Just had to say how much I enjoyed the postings here by I-reason.
Scares me to death but what a man, surely this is flying in the way that we GA people in the UK will never have the opportunity or nerve to do.
Would make a good magazine article:)

[IO540]

I do believe you Bookworm :O but what's the difference between you (having changed the oil filter yourself, left it loose and not wirelocked it) renting the plane to another pilot, and taking 3 passengers along?

The safety argument would lead a complete ban on passengers, and flying within the gliding distance of any habitation, if any pilot maintenance has been done.

And that is assuming the local JAR145 firm does a better job. It's true but only sometimes :O Of the last half dozen jobs I've had done by fully approved firms, half were done wrong.

The 50hr check on a SEP is really trivial - just a load of inspection (most of which is done on a preflight anyway) and the oil/plugs. The cost of special tools is recouped the very first time they are used. Personally I get an A&P friend to help me but that's largely because getting the cowlings off etc is a 2-man job.

There are so many areas in flying where a pilot has to make a life-critical "executive decision", yet for some reason it is assumed that the same person is unable to determine whether he is or isn't capable of changing the oil.

[bookworm]

I do believe you Bookworm :O but what's the difference between you (having changed the oil filter yourself, left it loose and not wirelocked it) renting the plane to another pilot, and taking 3 passengers along?

That in the latter case, I would be in the aeroplane with the passengers! :)

I'm not saying that the standards are set at the right level. But I am saying that there is a case for allowing private flights (even those with passengers) to operate with a higher level of residual risk than public transport flights, and for aircraft flown by the owner or a small group to be maintained in a way that involves more self-certification than aircraft that are hired out. In other words, I agree with the framework.

[IO540]

I agree with the principle, so long as the PT flights really are public transport flights.

Very little real public transport is done in what one might call "GA" planes.

The only case I can think of is a flying school that I know, obviously an AOC holder, having a Seneca and one day five men and a load of golf clubs turn up for a charter flight from one end of UK to the other. But these are isolated cases. (The fact that a Seneca with 6 men can't carry enough fuel for a circuit is beside the point :O )

So, what does all the other PT related regulation really achieve? It keeps AOC holders happy, for starters.

[Holryn]

Spernkey,

You have mail.