Didn't used to be.

By the way, I tried that very argument with ALPA legal that the RLA didn't apply to us since we were just a staffing company with in-house training. They actually kicked it around for about a week, before deciding not to pursue it, and for one reason. It's the same reason that repudiates the "staffing company" position. The fact is, Envoy holds an FAA Air Carrier Certificate, which makes it an airline, not a staffing company. The fact that the current business model is to fly somebody else's airplanes doesn't mean they cant fly their own, like they used to.