Originally Posted by
Flyhayes
Sounds to me as if the FAA is treating you like a crew member and that they are trying to determine the validity of you operating in such a function.
And as for the FAA's authority to "require the making of arrangements",you need to understand that the FAA is in a very unique position whereas they create, interpret and enforce their own rules. Trying to argue with the FAA as one might argue in a civil court will most likely not work and may even backfire.
You hit that nail on the head!
That is exactly what they're doing. I also know that the pilots bill of rights is nothing like what it appears to be.
While your description of the rule making , interpreting and enforcing is a bit ambiguous, it pretty much sums up the situation. Take for instance the wording of their request. If I didn't produce the material they improperly requested, they would consider that a violation. It would take a lot of time and effort (and money) before it got before the NTSB judge who would then have to rule in my favor however, then it would be dismissed and the FAA would issue a new request which would be properly worded. So...I'll do now what I'll end up having to do anyway and produce that material for their inspection.