May 30,2012 

U.S Department ofTransportation 

Docket Management System 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room Wl2-140 

Washington, DC 

20590 

,, r 

SNOHOMISH FLYING SERVICE, INC. 

9900 Airport Way, Harvey Field (S43) 

Snohomish, W A 98296 

Phone: (360) 568-1541 **Fax: (360) 568-6034 

www.snohomishflying ~com 

0-.....1 

c:::o 

·-

c:: 

z 

I 

r 

Subject: Combine drug and alcohol testing program for compliance with 14 CFR 120.117 and 120.225 

Dear Sir 

This letter is to request the approval to use one approved drug.and alcohol testing program to satisfy the 

requirements of both our part 135 operation and scenic. ~our operator as defined under 14 CF~ 91.147 

Snohomish Flying Service located at Harvey Field in Snohomish, W A is approved by the FAA as a part 

141-flight school, part 13 5 commercial operator and part 91-air tour operator. The management, flight 

personnel and mechanics are common to all operations and thus it makes sense that all personnel should 

fall under a common drug and alcohol program. 

All personnel responsible for part 135 and air tour operations are direct employees of Snohomish Flying 

Service and are cross trained and eligible to operate under both 14 CFR 135 and 14 CFR 119. 

Both operations operate from a common principal base of operations, main operations base and main 

maintenance base. 

All aircraft, flight crew and maintenance facilities are located at the same facility at Harvey Field, S43 

Specifically I am requesting that our current drug and alcohol program that is included in our part 135 

ops spec, GIQA307E and letter of authorization as a air tour operator, GIQJNMO 1 meets the 

requirements of 14 CFR 120.117 and 120.225. 

I am requesting that we do not need to have a separate drug and alcohol program to comply with 

120.117 and 120.225 

We wish to combine and only have one drug and alcohol program for part 135 and scenic (part 

119) to eliminate redundancy and to facilitate efficiency. All SFS employees required to be 

enrolled into the program are also the same individuals operating both Part 135 and Scenic flight 

operations. Combining the program in this situation makes sense. 
The public would benefit in the sense that the flight schedule would be less likely to be 

negatively impacted by more frequent random drug testing from two separate programs for the 

same individuals. Both the public and SFS would likely experience less frustration, reduction in 

paper work and a lower burden to office and administrative staff. 

Safety would be enhanced due to the fact that the same employees operate both part 135 and 

scenic and therefore would be covered under a single program. It is easier and more accurate to 

administer a single program that is in effect for all eligible employees. One set of records will be 

required reducing the likely hood of errors, omissions and mistakes. 

Additionally, implementing two separate programs would create unnecessary work, reduce 

efficiency and potentially add frustration to the public and to SFS employees with no added 

safety benefit. 

I appreciate your attention to this matter and please do not hesitate to contact me should you 

require additional information or supporting documentation. 

Peter Swift 

ChiefPilot- Part 1411135 ops