LEAR JET 35 CAPT HAD BEEN NOTIFIED BY FAA THAT SEVERAL FLTS TAKEN MAY BE CONSIDERED FAR PART 135 FLTS EVEN THOUGH THEY WERE CONDUCTED UNDER PART 91.

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I RECEIVED A LETTER LAST WEEK FROM THE FAA NOTIFYING ME I WAS BEING INVESTIGATED FOR NUMEROUS FLTS MADE IN A LEAR 35. MY HUSBAND AND I ARE BOTH PLTS FOR A COMPANY IN MEDFORD; OR CALLED ' COMPANY X' AND 'COMPANY Y.' WE PROVIDE PLT SVCS FOR SEVERAL DIFFERENT COMPANIES THROUGH THE COMPANY Y. IN 04/XA/01 THE COMPANY Y LOST IT'S 135 CERTIFICATE AND WE WERE TOLD BY THE OWNER OF THE COMPANY ALL PLT SVCS WE WERE PERFORMING WERE PART 91 FLTS; I.E.; THEY WERE FOR THE OWNERS OF THE ACFT OR LEGITIMATE LEASE AGREEMENTS WERE ON BOARD THE ACFT FOR THE INDIVIDUALS; WE SAW COPIES OF THE AGREEMENTS; WE WERE FLYING. THE FAA IS NOW STATING THOSE FLTS WERE ACTUALLY CHARTER FLTS AND ARE THREATENING TO SUSPEND THE PLTS CERTIFICATES FOR 6 MONTHS (THERE WERE 8 PLTS INVOLVED ALTOGETHER). WE ARE COOPERATING IN THEIR INVESTIGATION AND HAVE SUBMITTED COPIES OF REQUESTED INFO. SINCE I HAVE JUST FOUND OUT ABOUT THIS IN THE LAST 10 DAYS; I'M HOPING YOU'LL BE ABLE TO GIVE THIS CASE CONSIDERATION. CALLBACK CONVERSATION WITH THE RPTR REVEALED THE FOLLOWING INFO: RPTR STATED THAT THE FAA HAS INDICATED THAT THE RPTR WILL BE ISSUED A LETTER OF WARNING BECAUSE IT APPEARS BECAUSE IT APPEARS THAT THE FLTS WERE IN VIOLATION OF THE REGULATIONS COVERING FLTS FOR HIRE IN AIR COMMERCE; BUT THROUGH HER COOPERATION; THE SANCTION WOULD BE REDUCED TO A WARNING LETTER. HOWEVER; THERE WERE OTHER PLTS; INCLUDING HER EMPLOYER; WHO HAD NOT COOPERATED THAT WOULD BE GIVEN STRONG PLT CERTIFICATE SUSPENSIONS.