The most consistent accepted and past practice has been to utilize the planning process to determine whether or not you can “plan” to complete the entire HAAO which includes patient drop-off and a subsequent reposition flight back-to-base and then complete all associated tasks related to your Part 135 assignment, and until which time you are free from all restraint, work, or duty. This is just one of the items that we will be seeking an FAA legal interpretation on related to this new policy/directive.
....It is the unions opinion that for planning purposes the flight assignment should consist of flight legs to complete pick-up, drop-off, and the subsequent reposition (return-to-base) legs; closing the loop and meeting requirements under the FAR’s and within the definition of an HAAO and also meets the scope and intent of realistic planning.