November 10, 2014

Federal Aviation Administration

Exemption Request by:

Sterling Aviation LLC

5480 South Howell Avenue

Milwaukee, WI 53207

Sterling Aviation LLC a subsidiary of Landmark Aviation, holder of 14 CFR Part 135 

Certificate # DBCA868D, is requesting an exemption to 14 CFR Part 120.109(a) Preemployment drug testing requirements as they may pertain to employees on other 

Landmark subsidiary certificates who are transitioning to the Sterling certificate as noted 

below.

Sterling Aviation LLC is planned to be the surviving certificate in a merger and acquisition plan 

under OpSpec A502 with the following four subsidiaries of Landmark Aviation that hold 14 CFR 

Part 135 Certificates:

• Piedmont Hawthorne Aviation LLC certificate # I5WA933J

• Galvin Flying Service Inc. certificate # HUNA846E

• Midlantic Jet Charters Inc. certificate # EGQA525D

• Daedalus Inc. certificate # DDNA793K

As part of the plan, existing employees who already have been screened pre-employment 

will be transitioned from operations under one of these subsidiary certificates to 

operations under the Sterling certificate. Therefore, the transition is in effect an “intracompany” transition which does not really involve a new employment of the affected 

personnel. Requiring additional “pre-employment” drug screening would be superfluous 

and not cost effective since there is no real lapse between employment for operations 

under one certificate to operations under the Sterling certificate. Accordingly, Sterling 

Aviation LLC is seeking relief from conducting pre-employment drug testing required by 

14 CFR Part 120.109(a) for all flight crewmember employees performing safety-sensitive 

functions as called out in 120.105.(a) and (b) who will be transitioning as part of the 

transition plan authorized under OpSpec A502. This exemption would not in any manner 

pertain to true new hires.

Sterling Aviation LLC, Piedmont Hawthorne Aviation LLC, Galvin Flying Service Inc, 

Midlantic Jet Charters Inc, and Daedalus Inc all are currently testing employees for illicit 

drug use in accordance with 14 CFR Part 120 and will continue to do so until a Single 

Operating Certificate is obtained under OpSpec A502. The exemption would have no 

effect on this.

Charter • Management • Acquisition • Maintenance

5480 South Howell Avenue Milwaukee, WI 53207 ph 414.744.1300 fx 414.744.0547
All employees that are currently performing safety-sensitive functions will be 

continuously subject to an FAA-approved anti-drug and alcohol testing program without 

interruption and will be performing the same safety-sensitive functions for Sterling

Aviation after they transition to Sterling Aviation. The exemption will not affect this.

Sterling Aviation believes that this exemption request is in the public interest and is 

fundamentally the same as Exemption No. 6960 previously issued by the FAA (copy 

attached). Again, the exemption would apply only to those personnel who are existing 

employees under one of the four subsidiary certificates and who will transition to the 

Sterling certificate.

Proposed Federal Register Summary:

Sterling Aviation LLC is seeking exemption from 14CFR Part 120.109(a) only for Flight 

Crewmembers transitioning to the Sterling certificate from the Piedmont Hawthorne 

Aviation LLC, Galvin Flying Service Inc, Midlantic Jet Charters Inc, and Daedalus Inc 

certificates as part of the merger plan authorized by OpSpec A502.

Sincerely,

Robert J. Rufli

Director of Flight Operation

Landmark Aircraft Management & Charter

Office: 847-775-7809

Mobile: 248-459-0777