"Greg Esres" wrote in message
...
Pretty much, but 135.1a5 is an exception. It brings a little of
part 135 (just the drug-testing) to bear on sightseeing flights,
irrespective of part 119.

Do you have any evidence that this is true? I don't buy it. Flight
instructors often take people for sight seeing tours, which is
permitted in Part 119. What sort of free lance flight instructor
would have a alcohol testing policy? Doesn't make sense.

If you mean evidence as to what's done in practice, then no, I don't have
any. As I said, I'm only addressing what the regs say, not how the FAA
actually behaves, which I have little knowledge of. FAR 135.1a5, unlike
1a1, does not assert any contingency on part 119; that's my only point here.

Come to think of it, though, I do have one piece of anecdotal evidence, for
whatever it's worth. I've been told by a local flight school that the
reason the flight schools in the area all offer "introductory lessons", but
none offer sightseeing flights, is precisely to circumvent that part of the
regulations that would otherwise impose a drug-testing requirement.

If this were truly the case, the 119 exemption should be removed, and
135.1a5 would limit applicability to the drug testing stuff, and the
result would be the same.

It would be the same result only if there's no other consequence to falling
under part 119. I don't know if that's the case.

--Gary