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First, any reference to 135.273 here, or attempt to use it to justify your position is, again, misrepresentation, since 135.273 is for (limited to) FlIGHT ATTENDANTS. Nice try though (are you counting on the ignorance of others regarding that fact?) Nothing the Union cited supporting its claim, apparently, was applicable to 135.267(d). Same stuff you claimed here without proper citations. If the "union" requested and received legal ruling several times on this, it apparently wasn't from the Chief Council's office, since the have not published a single letter of interpretation to support your claim. And if they did provide you with several "letters", they would be applicable to ALL operator's who visit this site too, not just the "union's" limited scope. So, publish those here so the rest of the world can be on the same [secret] page you seem to be on! If you drop the medical crewmembers and patient, you are no longer HAA. Just an average everyday Part 135 operator conducting Part 91 operations. You are mixing FAR 135.267(c) and FAR 117 terms and rules, with FAR 135.267(d). The two are not compatible!

  

 

 

 

 

 

 

 

 

 

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