interstate avtatum m(^ 

F.A.A. APPROVED FLIGHT SCHOOL • COMPLETE MAINTENANCE / PARTS • . i • , 

AIR TAXI / EXECUTIVE CHARTER • AIR FREIGHT • AIRCRAFT RENTAL I LEASING 

• ^ "r: - A - f o 

ROBERTSON FIELD • JOHNSON AVENUE • PLAtNVILLE. CT 06062 • TEL (860) 747-5519 • 1-800-573-5519 • FAX (860) 747-5939 

U.S. Department of Transportation September 21, 2011 

Docket Management System 

1200 New Jersey Avenue, SE 

West Building Ground Floor, Room W12-140 RE; Part 120 Title 14 CFR 

Washington, DC 20590 Exemption No. 9930 

To Whom It May Concern: 

Our company, Interstate Aviation, currently conducts both our part 135 and part 91.147 air tour 

operations Drug Testing Programs combined under FAA Exemption No. 9930 which W\\\ expire at 

the end of this month, 9/30/11 (copy attached). 

We are a small, family-owned business with usually no more than 20 employees in a safetysensitive position at any given time. We currently have 14 total employees covered in our drug 

testing program for Part 135 and Part 91.147, combined. At this time, five pilots and three 

mechanics fall into both the Part 135 and Part 91.147 categories. In order to relieve the 

redundancy of paperwork and testing, 1 am seeking continued relief from the regulatory drug and 

alcohol testing requirements of 14 CFR part 120 {Part 135 and Part 91.147) and petition for an 

extension of our current exemption in accordance with the FAA's requirements established under 

14 CFR 11.61-11.101. I strongly feel that covering both operations under one testing program will 

in no way have an adverse affect on the safety of either of our operations as all safety sensitive 

employees will continue to be diligently monitored and tested under the regulations as required but 

at the same time, combining programs will greatly reduce the amount of duplicity. 

If there are any further questions or concerns in this matter please contact me at: 

Interstate Aviation, Inc, 

62 Johnson Avenue 

Plainville, CT 06062 

800-573-5519 or 860-747-5519 PH 

860-589-1853 FX 

flyiailynnOJaol.com 

Sinpfifely, 

Lynfl Michaud 

ADPM 

interstate Aviation, Inc. 
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US. Department 

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800 independence Ave . S W 

Washinglon D C 20591 

September 9, 2009 

Exemption No. 9930 

Regulator/ Docket No. FAA-2009-0746 

Ms. Lynn Michaud 

Interstate Aviation, Inc. 

62 Johnson Avenue 

Plainville, CT 06062 

Dear Ms. Michaud: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter dated August 3, 2009, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Interstate Aviation, Inc. (Interstate Aviation), for an exemption from part 120 of 

Title 14, Code of Federal Regulations (14 CFR). That exemption, if granted, would allow 

Interstate Aviation» which is operating under separate parts of the regulation, to cover its 

safety-sensitive employees uhder one testing program. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

urUh»^Frf1rTnl ffrjatrr h"rnirr the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to Interstate Aviation. 

The FAA has issued a grant of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption No. 9103 (copy enclosed), the FAA 

found that in this petitioner's case, § 91J47air tour operations by Solid Edge were closely 

cortilected to Solid Edge's part 135 operations and that combining two testing programs into 

one would be in the public interest and maintain an equivalent level of safety to that provided 

by the current regulations. Under one testing program, the pilots would still be subject to drug 

and alcohol testing in accordance with appendices I and J of part 121. Furthermore, the 

removal of duplicate testing would eliminate an unnecessary financial burden on Solid Edge. 

AAM-09-360-E 
Further, the F.\A found it unnecessary to burden the petitioner by requiring them to conduct 

two separate testing programs when one testing program would suffice to ensure the level of 

safety required by the rules. 

Having reviewed your reasons for requesting an exemption, I find that— 

• they do not differ materially from those presented by the petitioner in the enclosed grant of 

exemption; 

• the reasons stated by the FAA for granting the enclosed exemption also apply to the 

situation you present; and 

• a grant of exemption is in the public interest. 

Our Decision 

Under the authority contained in 49 U.S.C. 40113 and 44701, which the FAA Administrator 

has delegated to me, I hereby grant Interstate Aviation, Inc.. an exemption from 14 CFR part 

120, subparts D and E to the extent necessary to allow Interstate Aviation which is operating 

under separate parts of the regulation, to cover its safety-sensitive employees under one testing 

program, subject to the conditions and limitations described below. 

Conditions and Limitations 

1. Employees of Interstate Aviation are subject to the drug and alcohol regulations at 

all times while conducting operations under part 135 or part 91. 

2. The drug and alcohol testing program must be implemented under the auspices of 

the Interstate Aviation part 135 operation, not under part 91. 

This exemption terminates on September 30, 2011, unless sooner superseded or rescinded. 

Sincerely, 

Dr. Frederick E. Tilton, M.D. 

Federal Air Surgeon 

Enclosures