COMMUTER FLT CREW ISSUED CITATION FOR VIOLATION OF FEDERAL AVIATION REG.

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IFR FROM SJU TO STX WITH 19 PAX; CAPT AT THE CONTROLS. CLRED FROM ENRTE ALT OF 7000 TO 2300'; RPTED ACFT IN SIGHT ABOUT 15 MI NW OF LANDFALL AT STX. CLRED FOR VISUAL APCH; NO TFC OBSERVED AND TO CONTACT STX TWR. CLRED TO LAND BY STX TWR; NO RPTED TFC. AT ABOUT 2500' MSL AND 5 MI W OF LANDFALL; THE F/O ASKED MY PERMISSION TO OFFER THE SPARE HEADSET TO A PAX IN THE FORWARD OBSERVER SEAT. (CABIN CONFIGN: 19 SEATS; NO RESERVED JUMPSEAT; ALL FLTS ENCOURAGED TO HAVE COCKPIT DOORS OPEN FOR CABIN SURVEILLANCE.) THE F/O ALERTED HIM TO APCHING POINTS OF INTEREST ON WESTERN STX THAT THEY HAD DISCUSSED DURING THE BOARDING. PAX'S WIFE THEN EXTENDED A SMALL AUTOFOCUS CAMERA AND ASKED ME TO PHOTOGRAPH THEM. F/O TOOK THE CONTROLS WHILE I OBLIGED. I RESUMED CONTROL AND DSCNT; LNDG W/O FURTHER COM FROM TWR OR WITH PAX. AMONG THE PAX WAS AN FAA INSPECTOR; NOT IDENTIFIED TO ME; WHO LATER SUBMITTED A CITATION FOR INFRACTION OF FAR 135.100. ALTHOUGH WE HAD TEMPORARILY LEVELED OFF DURING THE DSCNT; AND WERE VMC W/O KNOWN OR OBSERVED TFC RPTED BY THE CERAP AND TWR; THE ACFT WAS NOT IN CRUISE FLT AND I PERMITTED AS WELL AS ENGAGED IN ACTIVITIES NOT RELATED TO PROPER CONDUCT OF FLT. WHILE THE OPEN COCKPIT DID NOT CAUSE THE INFRACTION CITED; IT DOES REQUIRE EXTRA VIGILANCE--NOT AFFORDED IN THIS INSTANCE--TO KEEP CABIN DISTRS AT BAY AND TO PREVENT THE APPEARANCE OF UNSAFE PRACTICE. CONJECTURE: IS A PART 135 PLT WHO CRUISES AT 1500' AND DESCRIBES POINTS OF INTEREST TO PAX WHILE MODIFYING ALT FOR TERRAIN AND CLOUD AVOIDANCE EXEMPT FROM PENALTY OR CERTIFICATE ACTION; WHILE A PART 135 PLT IN THE SAME AIRSPACE AND DOING THE SAME THING BUT IN THE DSCNT PHASE IS NOT EXEMPT? HOW DO WE FACTOR PLT DISCRETION INTO THE EQUATION?