January 17, 2012

U.S. Department of Transportation

Docket Operations, M-30

West Building Ground Floor

Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Docket # FAA-2010-0456

To Whom It May Concern:

Wisconsin Aviation, Inc., an FAR Part 135, Part 145, and Part 91.147 operator, requests an 

extension of exemption number 10060 relieving us from the requirement of having multiple 

drug and alcohol testing programs as mandated by 14 CFR Part 120.117(a).

In order to accomplish the requirements of FAR Part 120 and that of 49 CFR Part 40, we are 

requesting that all three programs continue to be directed to and covered under our 14 CFR Part 

135 Anti-Drug (ADP) and Alcohol Misuse Prevention Program (AMPP) for administration.

Without this exemption it is extremely burdensome and often impossible to administer three 

programs with three different DERs in one small company, while keeping the information 

separated. The result becomes a cumbersome process for us, the MRO, and the FAA. This 

arrangement has created a moving target because of varying interpretations of the applicable 

regulations, additional opportunities for mistakes in applying and documenting testing, and 

increased cost because of duplicitous testing of staff that functions in more than one program.

Our company employs several pilots, mechanics, and aircraft which “crossover” and are used on 

more than one certificate. The problem arises from how they accomplish their different roles 

while employed at one company. One example of this was highlighted during a past inspection 

of our drug and alcohol testing program. During the inspection, we were told by one inspector 

that a 91.147 drug-tested mechanic could only work on an “Air Tour” aircraft. When asked the 

question if an aircraft is used for more than one program (i.e., an airplane is used for both Part 

135 and 91.147) which applies to us, which mechanic could work on that aircraft? We were 

given a different answer, which was that either program’s mechanics could perform 

maintenance on that aircraft. The conflicting information still leaves me wondering who is really 

authorized to work on the aforementioned aircraft.

Wisconsin Aviation, Inc.

3606 Corben Court

Madison, WI 53704

608.268.5000
We also are required by FAR to keep the test results and other information “confidential” 

between “companies,” even though Wisconsin Aviation is only one company. Because of the 

close inner workings of our organization, we find that we are making extensive “workarounds” 

in order to keep this information separate. Employees often work in more than one certificate 

program, and as a company with a human resources department consisting of one person, it 

makes separating this information impossible. Additionally, it makes it very difficult to 

disseminate records to other air carriers, through the FAA required Pilot Record Improvement 

Act of 1996 (PRIA), after an employee leaves our company for outside employment.

Ironically, the Management Information System (MIS) reports, which are generated to report 

data to the FAA about the effectiveness and trends in the substance testing programs, only 

apply when 50 or more employees are tested in each program. Per FAR Part 120.119(a)(2), we 

currently cannot provide this information; however, if our programs are combined, the resulting

increase in the number of employees in the test pool would require us to submit the report, for 

all its derived benefits.

According to FAR Part 120.103 and .203, the purpose of this rule was to establish a program 

designated to help prevent accidents and injuries resulting from the use of prohibited drugs and 

misuse of alcohol by employees who perform safety-sensitive functions in aviation. By allowing 

us to screen our staff under one comprehensive drug and alcohol testing program, we will 

continue to be in a better position to catch mistakes in screening for unwanted substances 

rather than spending wasteful time administering multiple redundant programs. For this, and 

for the other reasons discussed above, I believe we will be able to provide a much safer 

environment for the public.

We appreciate your consideration in this matter. Please let me know if you have any further 

questions.

Sincerely,

Grant E. Goetsch

VP Flight Operations

Wisconsin Aviation, Inc.

Dane County Regional Airport

3606 Corben Court

Madison, WI 53704-2573

Phone: 608.268.5015

Fax: 608.268.5037

GrantG@WisAv.com