May 30,2012
U.S Department ofTransportation Docket Management System 1200NewJersey 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**

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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 testingprogram to satisfy the requirements ofboth ourpart 135 operation and scenic.**~our** operator as defined under 14**CF~** 91.147
Snohomish Flying Service located at Harvey Field in Snohomish, WA is approved by the FAA as a part 141-flight school, part 135 commercial operator andpart 91-air touroperator. The management, flight personnel and mechanics are commonto all operations and thus it makes sense that all personnel should fall under a commondrug and alcohol program. All personnel responsible for part 135 and air tour operations are direct employees ofSnohomish Flying Service and are cross trained and eligible to operate under both 14 CFR 135 and 14 CFR 119. Bothoperations operate from a commonprincipal base ofoperations, 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 ourpart 135 ops spec, GIQA307E and letterofauthorization as a airtour operator, GIQJNMO1 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 programfor 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 wouldbe less likely to be negatively impacted by more frequent random drugtesting from two separate programs for the same individuals. Boththe public and SFS would likely experience less frustration, reduction in paperwork and a lowerburdento office and administrative staff. Safety would be enhanceddue to the fact thatthe same employees operate bothpart 135 and scenic and therefore wouldbe coveredunder a singleprogram. It is easier and more accurate to administer a single programthat is ineffect for all eligible employees. One set ofrecords will be required reducing the likely hood oferrors, omissions and mistakes. Additionally, implementingtwo separate programs would create unnecessary work, reduce efficiency andpotentially add frustration to the public and to SFS employees with no added safetybenefit.

I appreciate your attention to this matter and please do not hesitate to contactme should you require additional information orsupporting documentation.

Peter Swift ChiefPilot- Part 1411135 ops