No, aircraft used for point-to-point transportation are not subject to the transportation rules of the ADA. They are covered by the Air Carrier Access Act, 14 CFR Part 382. (§37.3)
Aircraft used in a “loop” situation, such as a tour of the Grand Canyon, might be considered recreational conveyances and thus may be covered under title III, similar to other recreational conveyances.
Posted by Sheri Abrams, Attorney at Law, www.sheriabrams.com