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May 4, 2023 at 15:54 comment added randomhead @Kenn, I'm not claiming that this definitely was or wasn't a violation of 91.111—just pointing OP to a potentially-relevant regulation.
May 4, 2023 at 15:42 comment added Kenn Sebesta I think a weakness in this approach is the lack of demonstrable collision hazard. It wasn't luck which kept a collision from happening, it was proper care and operation. Reasonable minds might disagree on how close you have to get before crossing that line to "hazard", but I would suspect that for any punitive administrative action to hold there would have to be some component of the operation which was not in the pilot's control. For instance, if it were gusty, the wings were rocking back and forth, and it was just luck that they didn't make contact.
May 4, 2023 at 15:38 comment added randomhead That's a fair point. But I would say that if a Part 135 or even Part 91K aircraft has ever or could ever use that ramp, then it is a part of the airport used for air commerce. (And that's without trying to parse whether "used for air commerce" describes the part of the airport specifically, or the entire airport in general!)
May 4, 2023 at 15:25 comment added user22445 The only issue I see with respect to 91.13(b) is that the aircraft have to have been operated on a part of the airport used for "air commerce", the definition of which may make its application difficult to associate with the aircraft involved in the OP's question.
May 4, 2023 at 14:51 history edited randomhead CC BY-SA 4.0
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May 4, 2023 at 14:34 history edited randomhead CC BY-SA 4.0
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May 4, 2023 at 14:28 history edited randomhead CC BY-SA 4.0
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May 4, 2023 at 14:23 history answered randomhead CC BY-SA 4.0