March 20, 2012

Via Submission to regulations.Gov (Shell Docket FAA

- 2007

- 0001

- 0001) U.S. Department of Transportation Docket Management Facility 1200 New Jersey Avenue, S.E. West Building, Ground Floor Room W12 140 Washington, DC 20590 Air Ventures Hawaii , LLC P etition for Exemption from 14 C.F.R. Part 120.1(a) as it applies to Part 91.147(d) and Part 135. Pursuant to 14 C.F.R. 11.61 and 11.81, Air Ventures Hawaii, LLC hereby petitions for an exemption to permit it to combine the drug testing programs for its Part 91.147 and Part 135 operations. (A) Contact Information:
William Zeffiro Substance Prevention/Abuse Program Manager Air Ventures Hawaii P.O. Box 3350 Lihue, HI 96766 808

- 284

- 2726 wzeffiro@hotmail.com (B) The Specific sections of 14 C.F.R. from which an exemption is sought: **120.1 Applicability** This part applies to the following persons: (a) All air carriers and operators certificated under part 119 of this chapter authorized to conduct operations under part 121 or part 135 of this chapter, all air traffic control facilities not operated by the FAA or by or under contract to the U.S. military; and all operations as defined in 14 CFR 91.147. (C) The extent of relief sought, and the reason for the relief sought: Air Ventures Hawaii, LLC operates under both Part 91.147 and Part 135. At this time, any pilot who is flying under Part 135 and is already enrolled in a drug and alcohol testing program would also be required to enroll in a separate program to fly under Part 91.147. We are requesting that the two drug and alcohol testing programs be combined because we are an extremely small operation with less than 5 pilots. Being required to operate two separate programs is a financial and administrative hardship to our company. (D ) The reason why granting the request is in the public interest :All of Air Ventures Hawaii, LLC employees is a safety sensitive positions have been screened for

illicit drug use in full compliance with the requirements in 14 C.F.R. 12 0. Accordingly, Air Ventures Hawaii has met the public interest in ensuring that illicit drug users are detected and prevented from performing a safety sensitive position. Requiring Air Ventures Hawaii to duplicate drug testing programs for Part 91.147 and Part 135 is repetitive and is adding unnecessary financial and administrative burden to such a small company. Combining the programs would continue to meet the intent if 14 C.F.R. 120. (E) The reason why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which the exemption is sought : The exemption would not adversely affect safety because all the employees who have performed safety sensitive func tions for Air Ventures Hawaii have been subject to the drug testing requirements as outlined in 14 C.F.R. 120. (F) A summary to be published in the Federal Register stating the rule from which an exemption is sought and a brief description of the nature o f the exemption sought: 14 C.F.R. 120.1 a) All air carriers and operators certificated under part 119 of this chapter authorized to conduct operations under part 121 or part 135 of this chapter, all air traffic control facilities not operated by the FAA o r by or under contract to U.S. military; and all operators as defined in 14 C.F.R. 91.147. Air Ventures Hawaii respectfully requests that we receive an exemption from having two separate drug and alcohol programs and are able to combine the Part 135 and the Part 91.147 drug testing programs. (G) Any additional information, views or arguments available to support your requests.
None (H) If you want to exercise the privileges of your exemptions outside the United States, you must include your reasons:
Ai r Ventures Hawaii does not operate outside the U.S. Respectfully Submitted,

William Zeffiro Member Air Ventures Hawaii