I'm assuming good intent by the OP as the FAA's interpretation of compensation is pretty broad and it has changed over the last few decades.
The way I read this, A, B and C are not separate examples but rather progressive pushes of the rules:
... A) ferry a plane for someone if they don’t accept payment for their time or fuel, or fees, and they don’t log the hours.
In this iteration it sounds like the pilot will be ferrying the plane for someone else, while paying for the fuel and any related fees (tie down etc) with no compensation and no logging of the flight time. Correct?
B) can they accept repayment of expenses not directly related to the flight IE: food, travel to and from the plane, lodging, but NOT fuel for the plane or other flight related expenses.
In this next iteration the difference from A seems to be accepting compensation for your meals and hotel expenses, but not compensation for costs directly spent on the aircraft (fuel, oil, tie down fees, etc). Correct?
C) can they log the time since they paid all expenses of the flight
In this final iteration you seem to be asking if you can log the flight time if you paid all the expenses "for the flight" (although you've proposed two different interpretations of those "flight related" expenses). Correct?
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According to the FAA:
“the key consideration in determining if a private pilot is acting as pilot in command of an aircraft for compensation or hire is whether the pilot’s receipt of something of value is conditioned on the pilot operating the aircraft.”
In this case, you get to fly an airplane, and if you receive any compensation at all toward any of the related expenses, it's compensation.
The "if I don't log the time" distinction between A and C is irrelevant and not productive:
- the FAA won't believe that any more than I do; and
- logged or not it's still experience, and still something of value.
You enjoy flying, right? Experience tends to make you a better pilot, right? Even if not logged that value still exists, so it's the pilots receipt of something of value conditioned on the pilot operating the aircraft.
If the time is logged,it just adds more compensation as you now have hours of experience that can lower insurance rates in general and certainly in type. That would be interpreted as an additional example of a pilot receiving something of value conditioned on operating an aircraft.
The killer in all these examples is that even if you pay all the
direct operating costs and travel expenses, you're still getting to fly an airplane for less than it costs to operate that airplane when the
indirect costs are considered. That's receiving something of value conditioned on operating an aircraft.
For example, let's say I want you to ferry my Citabria somewhere.
- My direct hourly costs are $30 to $36 per hour, depending on fuel costs and burn, if I just count fuel and oil. Let's call it $34 per hour.
- However, my set aside for annual inspections, regular maintenance, eventual engine overhaul and recovering costs adds another $30 per hour in costs (and if I do not set those costs aside, I'm still losing value on my or my estate's eventual resale of the plane).
- Plus I have $325 per month in fixed hangar and insurance expenses that have to be pro-rated across the hours I fly every month. I average 20 hours per month so that's about $16 per hour.
- From a cost per flight hour perspective, the value of a flight hour in my aircraft is about $80 per hour based on flying 20 hours per month.
The $50 per hour you are NOT paying, could be interpreted as compensation for flying my Citabria.
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That said, I don't personally agree with that very narrow interpretation, but then I'm also old school and pre-date much of the current zeal in interpretation of "compensation". Things were just different then.
For example let's say, hypothetically, that a commercial pilot lost oil pressure due to a sudden oil leak in a Seneca on a hot day, had to shut down an engine and could not maintain altitude. Consequently, he had to land on a small grass strip about 50 miles from his home field. A Navajo and second commercial pilot was sent to pick up the pilot and passengers and fly them home. However, the aircraft was still at that field and there was no one available to fly a mechanic out to the Seneca. That A&P was also a multi-engine rated pilot. That A&P found a private pilot hanging out at the airport and had the private pilot fly him to the grass strip in a Cherokee 140. The A&P made a temporary fix to the oil leak and flew the Seneca home and the private pilot flew the Cherokee 140 home as well. That wasn't generally considered to be "compensation" at the time, although the pilot clearly got free flight time.
Let's also say, hypothetically, a private pilot working for an FBO in a maintenance capacity would on occasion, at the request of the FBO owner, on take one of the FBOs Cessna 172s to deliver or pickup one or more cylinders being overhauled by an engine shop about 100 miles away, at no cost to the pilot. That also wasn't considered to be "compensation" as no money was received by the pilot to fly there. The purpose was to transport a cylinder to or from the overhaul shop and care or plane, same thing, the method of transport was incidental. That was closer to the line but also wasn't generally considered to be compensation in that era.
I'm certain none of the above hypothetical examples would pass muster today as times and the FAA's definition of compensation has changed. Once again to underscore it:
“the key consideration in determining if a private pilot is acting as pilot in command of an aircraft for compensation or hire is whether the pilot’s receipt of something of value is conditioned on the pilot operating the aircraft.”
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Your best bet would be to ask the FAA for an interpretation with specific examples upon which they can give an opinion. Offices of General Counsel throughout the federal government do not like to give responses to hypothetical situations since a change in one minor detail may be enough to turn something from "legal" to "illegal". They do not want an opinion letter on a hypothetical to come back and be used as a defence against a violation of the CFRs. Consequently, if there is any doubt or ambiguity about the specific details the answer will be based on their most conservative interpretation, which usually means "no".
There is also value in looking at the very limited exceptions that are allowed:
- Private pilots may seek reimbursement for flight expenses incurred in connection with a business flight as long as the flight is incidental to the pilot’s business and the flight does not carry passengers or cargo for compensation or hire (For example many states will provide an private pilot employee reimbursement at a specific per mile rate if they travel for business purposes using their personal aircraft or a rented aircraft).
- Private pilots may share expenses with passengers provided all of the people on board the aircraft are on board for a common purpose, including the pilot, and the pilot pays his or her pro rata share of the
direct operating costs such as fuel, oil, airport expenditures, or rental fees. Note in this second example that the
indirect costs cannot be pro-rated to the passengers share of the costs.
- glider towing is also an exception where private pilots can fly without monetary compensation but still benefit from the flight time.
This may also be worth your read:
https://www.aopa.org/news-and-media...ompensation-the-faa-knows-it-when-they-see-it
