Is this part 91??

[Headwind]

NBAA? Read FAR 91-501. You must be a jet or have gross over 12,500 to qualify unless you are an NBAA member. Light twins, even King Air B-200 don't qualify. If the Doctor's want to operate this as a fractional operation in a light twin then they must be NBAA members.
NBAA has a waver for their members. If several Doctors own the aircraft and are billed for the use of the aircraft it sounds like this is the best way to go.
Sounds like the lawyer has done this before. I have. If I were you I would listen to the lawyer and talk with someone at NBAA and then go to FSDO with a plan.

HEADWIND

 

[The Natural]

Why does everyone want to bring the FSDO into this?

I got an idea, call 911 and tell them about the next time you think you smell marijuana in your living room.
Ask them nicely not to look under the couch because thats where you have your
unregistered gun which is next to the your gambling earnings that you failed
to claim, and to overlook the the dead hooker.

Fly for the owners, maybe friends & family that they will not charge AT ALL. Explain to them part 135 and the consequences. done.

 

[Lead Sled]

NBAA? Read FAR 91-501. You must be a jet or have gross over 12,500 to qualify unless you are an NBAA member. Light twins, even King Air B-200 don't qualify. If the Doctor's want to operate this as a fractional operation in a light twin then they must be NBAA members.
NBAA has a waver for their members. If several Doctors own the aircraft and are billed for the use of the aircraft it sounds like this is the best way to go.
Sounds like the lawyer has done this before. I have. If I were you I would listen to the lawyer and talk with someone at NBAA and then go to FSDO with a plan.

I seem to remember that the fractional regs didn't "kick in" unless you were operating some minimum number of aircraft. If that's true then what you said wouldn't necessarily apply. Additionally, on the surface, it appears as though they would only qualify as associate NBAA members.

'Sled

 

[Headwind]

Associate member? Why? If the doctors form an LLC to own and operate the aircraft they can join NBAA as a business member and operate under 91-501 with the NBAA waiver. Under 91-501 the LLC can bill each owner for his trips. No one can use the aircraft other than the owners. The LLC will give asset protection to the members from damage the others members may cause. The LLC does not "hold out" and is not in business for any reason other than to operate this aircraft for it's owners.
All the NBAA waiver does is allow a member with a light twin to take advantage of FAR 91-501, which the FAA designed for operators of jets.
You may not need to contact the FSDO. If a leese is used the leese must be approved by your FSDO, but the LLC should have an "operating agreement" for owners and no leese needed. The operating agreement spells out who manages the LLC, who are the owners, and who has operational control.

HEADWIND