...the FAA stated that, with the exception of goodwill, 1 the definition of "compensation or hire" is the same as that interpreted in the aviation regulations. Specifically, "compensation may include any form of payment, including payment of operating costs such as fuel, a tax deduction if a flight is for charity, payment by a third-pmiy, any non-monetary exchange for carrying a person for free (for example, the operator receives free advertising., parts~ or rnaintenance, and the like), or any exchange of value including the bartering of goods or services in exchange for the transportation.'" Conversely, winning prize money, adve1iising revenue from logos, and flying space flight participants for free are allowed under§ 437.91. !d. Blue Origin will not receive any fonn of compensation as discussed above for flying the Kindles, and therefore will not violate§ 437.91.2 Although it is not providing compensation to Blue Origin, An1azon is a customer. Section 440.3 defines customer as any person who "has placed property on board the payload for launch, reentry, or payload services .... " 14 C.F.R. § 440.3. Amazon meets the definition of customer because it is placing property on board the payload. However, the FAA contemplated non-paying customers for permitted operators. This is demonstrated by the requirement that a permittee execute a waiver of claims with its customers. Specifically, part 440 requires permittees to implement a reciprocal waiver of claims with each of its customers. See 14 C.P.R. 440.17(b); see also 14 C.P.R. 440 appendix C (providing a template of a waiver of claims and assumption of responsibility for permitted activities with one customer).
1 - Definition of Goodwill - Although carrying goods on board its vehicle without receiving compensation may generate goodwill, the FAA does not consider goodwill compensation
