Originally Posted by
rickair7777
Yes the pax pay indirectly for empty legs, but that doesn't stop you from operating them under 91. 135 is only required if the pax or cargo are onboard.
Amazing that these local guys have so much latitude to make up their own rules. I suspect he was former military with no GA experience at all.
And sometimes inspectors are just wrong.
I was once in a conference we requested in response to a Letter of Investigation. At first I thought the two Inspectors were playing "good cop-bad cop" until it dawned on me that they really disagreed with each other on the substance of whether certain conduct was a violation. It was an interesting dynamic to watch and we ultimately left when I decided that we weren't getting anywhere and were better off letting them sort it out without us.
Don't be surprised at the latitude. Ultimately interpretation is for the FAA attorneys, the NTSB and the Courts. But the guys on the front line, whether it be FAA or your local police officer, interpret the rules every day. While some of these guys may be into power and abuse their authority, most are just trying to do their jobs the best they can.