I'm neither agreeing or disagreeing with your POI's interpretation but HE/SHE is NOT the final authority on this issue. Best check FAA General Counsel's legal opinion on this one.JJET44 said:Yeah,
It is sort of a gray area with the Feds. My company got a difinitive answer from our POI and he stands by the empty legs being p91 with no duty time restrictions. They understand that the repos are paid by the customer but still don't concider it as 135.
With that said my company won't let us go past 14 for safety reasons.