commercial privileges

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 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.

"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

I did some scanning of the 14 CFR Preambles, which make it clear that
you're right on this. An excerpt:

-----------snip----------------

The FAA does not agree that some or all commercial sightseeing flights
in airplanes or rotorcraft should be excluded from application of the
rule. Commercial sightseeing operations usually involve members of the
general public who have paid for a ride in an airplane or rotorcraft.
For purposes of the antidrug rule, the FAA has determined that the
safety implications of such operations are comparable to that of other
operations that routinely involve carriage of passengers. These
passengers should be given the protection inherent in other
passenger-carrying operations for compensation or hire that have an
approved antidrug program, without regard to size or scope of the
operations or the number of flights per year a particular operator
might conduct.

-----------snip----------------

Cool, thanks for digging that up.

--Gary

"Greg Esres" wrote in message
...
I did some scanning of the 14 CFR Preambles, which make it clear that
you're right on this. An excerpt:

-----------snip----------------

The FAA does not agree that some or all commercial sightseeing flights
in airplanes or rotorcraft should be excluded from application of the
rule. Commercial sightseeing operations usually involve members of the
general public who have paid for a ride in an airplane or rotorcraft.
For purposes of the antidrug rule, the FAA has determined that the
safety implications of such operations are comparable to that of other
operations that routinely involve carriage of passengers. These
passengers should be given the protection inherent in other
passenger-carrying operations for compensation or hire that have an
approved antidrug program, without regard to size or scope of the
operations or the number of flights per year a particular operator
might conduct.

-----------snip----------------