"Greg Esres" wrote in message
...
On Tue, 24 Feb 2004 13:58:35 GMT, "Gary Drescher"
wrote:

Can a commercial pilot be hired to rent a plane and fly a journalist on a
local flight for aerial photography, without meeting any operator
requirements? Or does that count as a sightseeing flight, invoking the
part
135 drug-testing rules?


It's not clear to me that the drug testing of Part 135 applies to
sightseeing tours for little airplanes. Part 119 exempts little
airplane sightseeing from Part 135; the implication to me is that the
sightseeing flights in Part 135 must be only for big airplanes. I
could find no letters of interp for this.

It's true that 119.1e2 exempts small-plane local sightseeing flights from
part 119, but I don't see how it exempts them from part 135. It does exempt
them from 135.1a1, which refers back to part 119. But part 135's scope also
includes 135.1a5, which applies specifically to local sightseeing, with no
mention of part 119.

--Gary