2/28/2013 

Bartley J. Hallinan 

Port Townsend Air, LLC 

Jefferson Co. International Airport 

191 Airport Rd 

Port Townsend, WA 98368 

US Department ofTransportation 

FAA 

800 Independence Ave SW 

Washington, DC 20591 

RE: Docket No. FAA-2011-0595, Exemption No. 10292 

Dear Dr. Tilton, 

I am writing to ask for an extension of the above Docket Number. Attached is a copy of your letter 

dated 6/17 Ill granting the original exemption. 

Bartley J. Hallina ember 

Port Townsend Ai , LLC 
us_ Department 

of Transportation 

federal Aviation 

Administration 

June 17, 2011 

Mr. Bartley J. Hallinan 

Port Towsend Air, LLC. 

Jefferson Co. International Airport 

191 Airport Rd 

Port Townsend, W A 98368 

Dear Mr. Hallinan: 

Exemption No. 10292 

800 Independence Ave .. SW. 

Washington. D.C. 20591 

Regulatory Docket No. FAA-2011-0595 

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 June 2, 2011, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Port Townsend Air, LLC. (PTA), for an exemption from part 120, subpart A, D, E 

of Title 14, Code of Federal Regulations (14 CFR) to the extent necessary to allow PTA to 

cover its safety-sensitive employees under one testing program while operating under separate 

parts of the regulation. 

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

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to PTA. 

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

those presented in your petition. In Grant ofExemption No. 9703 (copy enclosed), the FAA 

found that Solid Edge's § 91.147 air tour operations were closely connected to its part 135 

operations. The FAA also found that combining the petitioner's two testing programs into 

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

AAM-11-332-E 
provided by the current regulations. Thus, the FAA concluded it was unnecessary to burden 

the petitioner by requiring it to conduct two separate testing programs. 

Having reviewed your reasons for requesting an exemption, I find that2 

• they are similar in all material respects to relief previously requested in the enclosed Grant 

ofExemption No. 9703; 

• the reasons stated by the FAA for granting the enclosed Grant of Exemption No. 9703 

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 Port Townsend Air, LLC. an exemption from 14 CFR part 

120 to the extent necessary to allow PTA to cover its safety-sensitive employees under one 

testing program while operating under separate parts of the regulation, subject to the 

conditions and limitations described below. · 

Conditions and Limitations 

1. Employees of Port Townsend Air 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 program must be implemented under the auspices of the Port 

Townsend Air part 135 operation, not under part 91. 

This exemption terminates on July 31, 2013, unless sooner superseded or rescinded. 

Sincerely, 

Is/ 

Frederick E. Tilton, M.D. 

Federal Air Surgeon 

Enclosure