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

, i s requesting an exemption to 14 CFR Part 120.109(a) Pre

employment 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 Hawthorn e 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 u nder one of these subsidiary certificates to operations under the Sterling certificate. Therefore, the transition is in effect an “intra

company” transition which does not really involve a new employment of the affected personnel. Requiring additional “p re

- 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 reli ef 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 author ized 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 414.744.0547All employees that are currently performing safety

- sensitiv e 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 exempti on 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 per sonnel 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,

Rober t J. Rufli Director of Flight Operation Landmark Aircraft Management & Charter

Office: 847

- 775

- 7809

Mobile: 248

- 459

- 0777