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Not wrong. For what you suggest the FAA has

Not wrong. For what you suggest the FAA has  

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Author: said to you to be true, it would have...   Date: 4/9/2019 3:44:03 PM  +0/-0   Show Orig. Msg (this window) Or  In New Window

... required a NPRM, since what you think they are saying (now) is completely diffrent than what they have said all along, and including what they said in the Final Rule to Subpart L.  I have not seen a NPRM, or even a Notice of Draft Letter of Interpretation, which means the FAA isn't chaning the way they have enforced the regulation all this time.   And, according to the Final Rule for Subpart L, FAR 135.267 has not changed at all with the publishing of Subpart L.   All that changed was that a certificate holder was operating under Part 135 if the medical crewmember or patient was on board.   Nothing in the regs saying what you claim.  Nada!

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FAA Rules with Union on Duty Period Issues +4/-0 Imagine That 4/9/2019 1:58:52 PM