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 Petition 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. 120. 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 functions 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 of 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 or 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:

Air Ventures Hawaii does not operate outside the U.S.

Respectfully Submitted,

William Zeffiro

Member

Air Ventures Hawaii