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 W hom I t 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 requirem ents 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 i t 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 arrangem ent has created a moving target because of varying inte rpretations of the applicable regulations, additional opportunities for mistakes in applying and documenting test ing, and increased cost because of duplicitous testing of staff that functions in more t han 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 thi s 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? W e were given a different answer, which was that either program ’ s mechanic s could perform maintena nce on that aircraft. T he conflicting information still leaves me wondering who is really authorized to work o n the aforementioned aircraft.

Wi sconsin Aviation, Inc. 3606 Corben Court Madison, W I 53704 608.268.5000W e also are required by FAR to keep the test results and other information “c onfidential”

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 . E mployees 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 Reco rd 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 te st 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 a dministering multiple redundant program s. 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 you r consideration in this matter. Please let me know if you have an y 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@W isAv .com