Commercial operation question

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Kirk Bauer

Filing Flight Plan
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Kirk
I know the best answer is to go pay an expert, but right now I'm just spitballing on whether or not I can combine my interest in SCUBA and flying into a business. I'd like to at least direct my informal research without having to consult a professional.

Specifically, as a PADI Divemaster and soon-to-be-private-pilot, I thought it would be neat to buy a plane and offer SCUBA packages that would include travel on my plane, hotel, and me leading the dives, etc.

Based on this article I think that doing such a thing with just a private pilot's license is a "no go": https://www.avweb.com/aviation-news...ess-flying-and-the-compensation-or-hire-rule/. Specifically, the FAA might not (or definitely won't) consider the flying incidental to the business.

My question is: what would it take to make this sort of thing legal? If I had a commercial license and performed 100hr maintenance would that be sufficient? Or am I looking at a single-pilot Part 135 operation?
 
Don't forget that Scuba and flying don't always go together. If you've been scuba diving for X hours, you can't go up in an airplane (lower air pressure can trigger bends) for a while.



Divers Alert Network (DAN)
  • After single no-decompression dives, a minimum pre-flight surface interval of 12 hours is suggested.
  • After multiple no-decompression dives per day or multiple days of diving, a minimum pre-flight surface interval of 18 hours is suggested.
  • For dives requiring decompression stops, there is little experimental or published evidence on which to base a recommendation; for decompression diving, a pre-flight surface interval substantially longer than 18 hours appears prudent.
 
Yes, definitely flying after diving would be taken into account. Most likely the last dive would be a single dive in the morning with departure the following morning.

With a small plane over a place like Florida there is definitely an opportunity to keep the altitude low but there isn't any science on exactly what that impact would be. But in a business I can't see any reason to push the limits.
 
In all respect, I suggest that you contact an aviation Attorney regarding the 135 aspect. My little town has a couple. Should be one in your area.

Bravo WDD. he just posted the best reply so far. As a PADI Dive master you no doubt know this. Can it be insured? I often transported Saturation divers by helicopter. Outbound? Any altitude will play. Higher the better. Good fuel burn. The divers were still "dirty" after they came out of "sat". The Diving Superintendant made sure that five hundred feet was my max inbound altitude. He rode with us to make sure.

Just asking, Planning VFR and IFR flights?
 
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I figure it would best if I had an instrument rating and a suitable aircraft.

I hear that a single-pilot 135 is much easier than a multi-pilot one, but I'm guessing it is a lot of effort and cost to get that done.
 
This comes up regarding Alaska and guides/lodges with aircraft. Here's one of many "letters" addressing that issue:
https://www.govinfo.gov/content/pkg/FR-1998-01-02/html/97-34164.htm

Not an aviation attorney, but, for sure you'd need a 135 certificate.
Even a simple single-pilot 135 operation takes quite a bit of effort to obtain. And, further, you are still bound by the limitations and minimums of Part 135, most notably, PIC minimums, 500 hours for VFR, 1200 for IFR.
Could it be done (under 135)? Sure, but my guess is that it just wouldn't prove to be economically viable, with insurance, required training, etc. A better idea might be to work with already existing 135 operators to come up with a package deal of some sort. Of course, I realize, that doesn't help you pay for a plane of your own, or even allow you to fly their aircraft (unless you were fully qualified and trained as an employee/pilot).
 
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A Part 135 manual, even a "single" pilot is VERY time-consuming. Not only to originally write (I've done two) but to maintain. Most chief pilots sit behind a desk.
 
Kirk Bauer said:
I know the best answer is to go pay an expert, but right now I'm just spitballing on whether or not I can combine my interest in SCUBA and flying into a business. I'd like to at least direct my informal research without having to consult a professional.

Specifically, as a PADI Divemaster and soon-to-be-private-pilot, I thought it would be neat to buy a plane and offer SCUBA packages that would include travel on my plane, hotel, and me leading the dives, etc.

Based on this article I think that doing such a thing with just a private pilot's license is a "no go": https://www.avweb.com/aviation-news...ess-flying-and-the-compensation-or-hire-rule/. Specifically, the FAA might not (or definitely won't) consider the flying incidental to the business.

My question is: what would it take to make this sort of thing legal? If I had a commercial license and performed 100hr maintenance would that be sufficient? Or am I looking at a single-pilot Part 135 operation?
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Don't forget the 12/18 hr thing or whatever the computer says.. unless you plan to just fly at 1K AGL or under

**I've had the same idea mind you, but the way to make this really viable would be to ditch the 12/18 hr recommendation. Imagine being able to dive multiple distant dive sites in one day. Once you introduce hotels and delays for decompression it sort of nullifies the need for the speed of an airplane

Plus with tanks, gear, etc., you have a lot of weight concerns. Even a caravan would be very limited in how much you can actually bring, and the fees you'd have to charge to make it worthwhile would not attract many divers. Around San Diego $100-$200 gets you a full day of diving on a boat to kelp beds, wrecks, etc. I can't imagine many would want to spend what, 10X that..?

I am not sure you can combine the two..
 
Jim Carpenter said:
This comes up regarding Alaska and guides/lodges with aircraft. Here's one of many "letters" addressing that issue:
Click to expand...
FYI: There has not been an issue with Part 135 vs Alaska guide operations since 2000. Shortly after the 1997 notice you linked was posted there was a lawsuit filed against the FAA in reference to that notice. Long story short, Congress got involved and passed a federal law in 2000 allowing Alaskan guide pilots to fly paying customers into the bush under Part 91 per conditions stated in the law's text. Unfortunately, by design and title, it only applies to ALASKA GUIDE PILOTS.
 
Bell206 said:
FYI: There has not been an issue with Part 135 vs Alaska guide operations since 2000. Shortly after the 1997 notice you linked was posted there was a lawsuit filed against the FAA in reference to that notice. Long story short, Congress got involved and passed a federal law in 2000 allowing Alaskan guide pilots to fly paying customers into the bush under Part 91 per conditions stated in the law's text. Unfortunately, by design and title, it only applies to ALASKA GUIDE PILOTS.
Click to expand...

If I remember right, I believe there was a guy in Louisiana that got into hot water using his seaplane to transport clients of his fishing tour business.
 
@Jim Carpenter, well this may be a 5-10 year plan, if I need part 135, 1200 hours for VFR, etc. Thanks everybody for the advice so far.

@Tantalum I live in Atlanta, so the concept would be to fly down say to the Keys with just personal gear, and then utilize a local dive operation for the tanks, etc. The alternative is an inconvenient commercial flight or a very long drive, since there is minimal local diving. I was thinking perhaps $2-3k per person for flight, hotel, and a few days of diving in the Keys might be attractive. I was thinking perhaps an economical piston, like the DA62, could fit me plus up to 4 divers and personal gear. I haven't fully run the numbers on weight yet.
 
How about you owning and renting the gear to the clients. It would save lots of weight in transportation. Just some numbers when I hauled folks to and from.

I carried welders to construction sites. They averaged 300 pounds for personal baggage, gear/tools and "meat". Divers were even more. They averaged out at least to 400 pounds per hard hat diver. I could make most destinations with minimum fuel and carry about 2300 pounds of payload. There were also the tenders that had to go too. Just do the math. The 600 pound baggage compartment was maxed out. Of course, all of the twelve passenger seats could not be filled with butts. That's where the overflow from the baggage compartment went.

As suggested, it makes sense for you run the dive op and contract out the transportation. Good luck.
 
Kirk Bauer said:
I was thinking perhaps $2-3k per person for flight, hotel, and a few days of diving in the Keys might be attractive. I was thinking perhaps an economical piston, like the DA62, could fit me plus up to 4 divers and personal gear. I haven't fully run the numbers on weight yet.
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As a Scuba diver myself, I usually go on dive trips with a dive shop out of Vegas. The last one I did (January 2019) was 7 days in Cozumel with Lodging, two dives a day for 5 days, and food/beverage (including alcohol for drinkers) at the hotel for $800 per person/double occupancy plus flight. My flight in First Class was $800 round trip which covered my extra bags with my gear. So I was in for $1600 total including all the hotel food/beverage I wanted. Just giving you prices for comparison.
 
Kirk Bauer said:
@Jim Carpenter, well this may be a 5-10 year plan, if I need part 135, 1200 hours for VFR, etc. Thanks everybody for the advice so far.

@Tantalum I live in Atlanta, so the concept would be to fly down say to the Keys with just personal gear, and then utilize a local dive operation for the tanks, etc. The alternative is an inconvenient commercial flight or a very long drive, since there is minimal local diving. I was thinking perhaps $2-3k per person for flight, hotel, and a few days of diving in the Keys might be attractive. I was thinking perhaps an economical piston, like the DA62, could fit me plus up to 4 divers and personal gear. I haven't fully run the numbers on weight yet.
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With you being in Atlanta that changes the dynamic a little bit.. still I think the value proposition is limited. You might be able to set this up as a boutique service and experience for a limited handful of clients but if you look at the costs and prices I'm not sure there would be an advantage for someone to fly in a DA62 vs just book a commercial ticket and their own equipment and lodging.. the DA62 is nice, but with the 180 knot true AirSpeed Cruise and it's still being a piston airplane you would still have some weather considerations and there wouldn't really be much of a time advantage for folks.. you can probably snag a round trip ticket for one or two hundred bucks from Atlanta to most places in Florida

There could be some novelty to flying private however the da62 while certainly a very nice plane is still generally small aircraft.. with 600 Mi between Atlanta and Palm Beach Florida you're talking about a solid 4-Hour trip in a small airplane period you will likely need to make a fuel stop and bathroom stop. I don't know why somebody would choose that over a 1-hour Southwest flight for a fraction of the cost

Sorry, just giving you are realistic idea of the obstacles you'd have to overcome

someone could fly from New York to San Diego on a commercial flight and book a boat down to Mexico for a few days of diving for under a $1,000

it's an alluring prospect but I don't think you can actually combine diving and aviation


--
when I originally had this idea I was thinking of either a caravan on floats or finding one of the used flying boats sitting on the market for cheap.. pick people up somewhere, say a group of eight period and spend the day doing short flights at 1,000 ft or under to various different dive destinations. There would be a cool novelty to flying in a classic flying boat and you'd be able to get from one dive site to another in 20 minutes as opposed to a 3-hour boat ride.. leave Long Beach 6 in the morning, from the same place Howard Hughes flew the spruce goose, and in one day you could dive catalina, La Jolla shores, the Yukon wreck, and even the Coronado Islands and back.. if you keep the dives not too deep and a solid half an hour to an hour between them there wouldn't be much decompression issue and you could squeeze in five or six dives
 
Bell206 said:
FYI: There has not been an issue with Part 135 vs Alaska guide operations since 2000. Shortly after the 1997 notice you linked was posted there was a lawsuit filed against the FAA in reference to that notice. Long story short, Congress got involved and passed a federal law in 2000 allowing Alaskan guide pilots to fly paying customers into the bush under Part 91 per conditions stated in the law's text. Unfortunately, by design and title, it only applies to ALASKA GUIDE PILOTS.
Click to expand...

Bell206, thanks for the update info.
 
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