I have a friend that has been doing this for many years. It probably
helps that he has over 20,000 hours and has held his 135 certificate,
accident free, for 20 years. I don't think the FAA is the biggest
thing to overcome, there are some canned 135 ops manuals you can get.
What may ultimately kill my friend's 135 operation is the drug
requirements. He currently pays to have his main IA receive regular,
FAA approved, drug screening. However, every other mechanic that works
on the plane needs the same, including the avionics shop. I was down
at the avionics shop and they said they are considering dropping their
drug testing program for their 135 customers (only my friend now).
Their concern is that if they are missing one poster on their employee
posting board the FAA can fine them $35,000. They said that would put
them out of business and its just not worth it for a couple 135
customers.

-Robert, CFII


All repair stations have to have a drug testing 'policy' in place to keep the station certified. Isn't the avionics shop
a repair station?