FLC OF SMT CPR ACFT FLYING CARGO IS RAMP CHKED AFTER LNDG IN STT; VI. FAA INSPECTORS DECIDE THEY ARE NOT PART 91 AS CLAIMED BUT ARE PART 135 AND CLAIM THEY ARE UNDER VIOLATION. COMPANY FOLLOW UP EXTRACTS AN APOLOGY FROM FAA HEADQUARTERS IN SAN JUAN AND A NOTICE OF NON VIOLATION.

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I WAS 'RAMP CHKED' BY THE FAA AFTER LNDG IN STT ENRTE FROM SJU. I FLY ONCE A WK FOR A CPR COMPANY UNDER PART 91. THE FAA ASKED ME WHERE MY WT AND BAL MANIFEST WAS AND WHY I HAD NO CARGO NET. I TOLD THEM THAT UNDER FAA PART 91 I AM NOT REQUIRED TO HAVE THEM. THEY THEN TOLD ME THAT I WAS INDEED OPERATING UNDER FAA PART 135 AND THAT I WAS NOT AWARE OF MY COMPANY'S BUSINESS THEREFORE 'YOU ARE UNDER VIOLATION.' I WAS TOLD TO WRITE A RPT THAT DAY STATING WHY I WAS FLYING WITHOUT A CARGO NET AND WT AND BAL MANIFEST AND WHY I WAS 'IGNORANT OF THE LAW.' AFTER RETURNING TO SJU I WAS CONTACTED BY MY EMPLOYER AND WAS GIVEN A NUMBER TO CALL IN SJU WHICH WAS THE FAA HEADQUARTERS. I SPOKE TO THE LEAD FAA INSPECTOR OF PUERTO RICO WHERE HE APOLOGIZED AND TOLD ME NOT TO WORRY; THAT I WAS NOT UNDER VIOLATION; THAT IN FACT THE FAA INSPECTORS THAT 'RAMP CHKED' ME WERE ALL MISINFORMED OF OUR COMPANY'S OP. IN FACT; WE ARE LEGAL AND A PART 91 CPR OP. THEY THEN WROTE A LETTER STATING OUR LEGAL OP WAS NOT IN JEOPARDY (NO APOLOGY WAS ENCLOSED). I BELIEVE THE FAA INSPECTORS THAT 'RAMP CHKED' ME WERE THE PERSONS GUILTY OF WHAT THEY WERE ACCUSING ME OF. THEY WERE READY AND TECHNICALLY GAVE ME A VIOLATION ON THE SPOT FOR WHAT THEY BELIEVED TO BE TRUE. I WAS THE PIC AT THAT TIME; THEREFORE; THERE SHOULD BE A RESPECT FOR MY KNOWLEDGE OF THE COMPANY FOR WHOM I WORK -- AT LEAST UNTIL THEY PROVE ME GUILTY FIRST. THIS IS THE SECOND TIME THE FAA HAS DONE THIS TO MY COMPANY AND TO THE PLTS. BOTH TIMES NEITHER PLT NOR COMPANY BREACHED ANY FAA REG.