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Discuss on this thread, I'm sure others would be interested.
Better than a FSDO - FAA Legal has a 1995 written opinion that tells us that a commercial is required if you are providing a photography platform for others, but that a commercial certificate is not required if you're doing it yourself. Here is the relevant part:I would like to know if anyone here is actually doing aerial photography (as a business) with just a PPL. FAR 61.113? I believe does not specify that one would need a Comm Tix. I did pose the ? to the local FSDO, and was told that since"flying was incidental to the business" I would not need a comm tix.