Original Message

Ask the FAA for their interpretation. When the nurse and or medic are on board it is considered a Part 135 flight with or without the patient. FAA takes a dim view on calling the empty leg a Part 91 flight. In fact the only time you would call Part 91 is a maintenance flight, ferry flight, or a repositioning flight with only the pilot or maybe mech on board. Some people in this thread have a lot to learn.