Oh, and yes I advertised as an aerial photographer, and yes I cleared the whole thing with my local FAA FSDO before I flew my first mission. Local interpretations can very so I recommend checking in with your FSDO first.
My interpretation is a commercial rating is required.
I find it interesting that you relied on a government employee to protect you from the government!
Nothing sends a chill down my spine faster than the statement
"I'm from the government and I'm here to help"
John KLWM
John,
I work with the FAA every day as a normal part of my job. In my experience they are helpful, and professional. As a normal course I would agree with you in having a healthy mistrust of government (more and more these days). However, over my years working with the FAA I have found that for the most part they are like us. People who love aviation and wanted to work in the field, or to continue working in it. They are pilots, air traffic controllers, aviation mechanics etc... They are perfectly willing to give you advice and tell you ways of doing things that will keep you out of trouble (Saves them paperwork).
I find it interesting that anyone would consider starting an business related to aviation WITHOUT meeting with the your local FAA representatives BEFORE you start. As you can see from this thread there is a lot of confusion over what you can and cannot do as a Photographer with an airplane. The FARs are not always clear and sometimes they contradict themselves. So for me it was logical to run it buy the FAA before I did anything that could be questioned.
I am not going to sit here and tell everyone how to run an Aerial Photography business with a PPL, nor am I going to tell everyone they should. But it can be done safely and legally. I've done it.
There are limitations and some jobs I had to turn down. Photographers wanted to hire me to take them up, clients wanted to hire me to take them up... I couldn't do it. They could not hire me as a pilot in any way and they could not hire my airplane. They could only hire a Photographer and buy photographs. They could tell me what kinds of photographs they wanted to buy and what they wanted photographed. The methods involved are up to the photographer.
I recommend that anyone interested in doing this, do their own research and run your business plan buy the FAA -before- you do it. Get it in writing, letter or email will work.
As far as interpretation is concerned. You will find that the different regional offices can vary greatly on their interpretations of the FARs and ACs, (maybe not on this particular topic) Also, regulations and interpretations change over time. So check first.
My $0.02 take it or leave it.
