i^PmRTMENTOF 

Heli Xpress. LLC -iANSPORWlON 

^m^^ ^ ^ :KET OPERATIONS 

lOOWymanct 

Wmston Salem, NC 27106 

Phone:336-768-9126 / 'D GCI ?2 P 2= I 8 

Helixpress@gmail.com 

I am seeking an exemption, modification or relief to Titie 14 of the Code of Federal Regulations (CFR) 

Part 120. It lays out the regulatory Drug and Alcohol requirements for 135 VFR flights and part 91.147 

sightseeing. I have both a 135 and a 91.147 operating certificate. 

The extent of relief I seek is in the requirement for every certificate to have a separate drug and 

alcohol program for all of ttie safety sensiti^ve jobs of the company. I feel that tfiis rule shoukJ be 

combined/waived for one of my operating certificates, as I am tf)e only employee. I do have an 

avionics mechanic and a mechanical mecfianic in tfie random pool with me as they are in safety 

sensitive jobs. I seek an exemption or waiver for this rule with the stipulation that my mechanics v^o 

work on the aircraft and myself must remain with one of the drug and alcohol testing programs. 

The reason I seek relief from this rule is as follows: My company, Heli Xpress, LLC has two operating 

certificates. Because of this, the company is requred to have 2 Orug and Alcohol testing programs. 

This is excessive. To have 3 people in 2 different random drug testing pools does not make it any 

more random for drug tests. It negatively impacts txith my company and the 3 safety sensitive 

persons. To have double random tests takes 2 times as much money and cost to operate, and 2 times 

the time required to administer random tests and papenwork. Each safety sensitive person is already 

covered by one drug and alcohol program. There is no need for two. Botti Drug and alcohol programs 

cover the requirements for the FAJR's. Having two programs covers everything two times. 

My request would benefit the public because it woukJ reduce the burden of my company and the Drug 

and Alcohol Division inspection requiremeiits. The Drug and Ateohol Division must inspect each 

operating certificates program at random. We have double coverage right now which would mean the 

Division sending 4 inspectors to do an inspiection that 2 coukJ perform. 

The exemption would not adversely affect safely and would provkle a level of safety at least equal to 

the existing rule because 135 Drug and Alcohol operations and 91.147 operations are governed by the 

same part, Part 120. Both must adhere to Ittie same requirements. Therefore having one program for 

both operating certificates still meets the requirements for both a 91.147 and a 135 operating 

certificate. 

The summary that can be published in the Federal Register: 

Title 14 of ttie Code of Federal Regulations (CFR) Part 120. The company has two operating 

certificates for different operations and ttierefore is required to have a drug and alcohol program for 

each operating certificate. All of the employees and safety sensitive personnel perform the same jobs 

in both certificates and are covered by one drug and ateohoi program for one certificate. There is no 

need for two drug and alcohol programs. 

Jared L Watkins 
Gmaii - RESPONSE: 2 certificates, 1 program Page 1 of 2 

\h. ^ LT J -^ 11 Jared Watkins <wfuavenger@gmaii.com> 

RESPONSE: 2 certificates, 1 program 

vicky.dunne@raa.gov <vicky.dunne@faa.gov> Mon, Sep 27, 2010 at 4:16 PM 

To: Jared <jared@heli-xpress.conp> 

Co: Carolina.Martinez@faa.gov 

Dear Mr. \/Vatkins: 

As Carolina Martinez explained, seeking an exennption is available to you. 

Your petition must be filed in accordance with the FAA's requirements 

established under 14 CFR § 11.61-11.101, using the following guidelines: 

(1) Your exemption request should be submitted 120 days before you need 

the exemption to take effect. 

(2) The exemption request must include the following information in your 

petition: 

(a) Company Name and mailing address and, if you wish, other contact 

information such as a fax number, telephone number, or e-mail 

address; 

(b) The specific section or sections of 14 CFR from which you seek an 

exemption; 

(c) The extent of relief you seek, and the reason you seek the 

relief; 

(d) The reasons why granting your request would be in the public 

interest; that is, how it woukJ t)enefit the public as a whole; 

(e) The reasons why granting the exemption would not adversely affect 

safety, or how the exemption woukl provide a level of safety at least 

equal to that provided by the mie firom which you seek the exemption; 

(f) A summary we can publish in the Federal Register, stating the 

regulation which you seek the exemption and brief description of the 

nature of the exemption; 

(g) Any additional information, views or arguments available to 

support your request; and 

(h) If you want to exercise the privileges of your exemption outside 

the United States, you must include your reasons. 

Please send your exemption request, in writing, to: 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE. 

West Building Ground Floor, Room W12-140 

Washington, DC 20590 

You may also submit your exemption request electronically to the FAA 

through the Intemet, using the Docket Management System Wteb site at this 

Internet address: http://www.requiations.qov. The exemption procedures are 

set forth under the FAA's regulation for general rulemaking procedures (14 

CFR part 11), which may be found at www.faa.gov. 

If you need help submitting your exemption or have any questions, please 

contact Tyneka Thomas at (202) 267-7626. Ms. Thomas worths in the Office of 

Rulemaking, who is responsible for the exemption process. 

https://mail.google.com/mail/?ui=2&ik=48ebl06104&view=pt&search=inbox&msgr=12b5... 10/7/2010 
Gmail - RESPONSE: 2 certificates, 1 program Page 2 of2 

I hope this is helpful. Please feel free to contact me directly if you have 

any further questions. 

Sincerely, 

Vicky Dunne 

Program Policy Branch Manager 

Dmg Abatement Division 

ofc: 202-267-8442 

fax: 202-267-5200 

Dmg Abatement's Web site: 

http://wvtfw.faa.qov/about/office org/headquarters offices/avs/offices/aam/drug alcof>ol/ 

The Drug Abatement Division strives to provkle quality service. I invite 

you to complete a feedback fonnn at 

http://wvtfw.faa.qov/abQut/office org/headquarters offices/avs/stakeholder feedback/aam/aam800/. 

Your feedback is essential in helping us to continually improve. Thank 

you. 

From: Jared <iared(g)heli-xpress.com> 

To: Vicky Dunne/AWA/F/\A@FAA 

Date: 09/27/2010 04:07 PM 

Subject: 2 certificates, 1 program 

Sent by: wfuavenger@qmail.com 

Ms. Dunne, 

Carolina Martinez stopped by recently to inspect my 135 dmg and alcohol 

program and recommended I contact you. 

I have a 91.147 and a 135.1 wouM like to combine both companies drug and 

alcohol programs as they are both the same and it is just me and my one 

company, Heli Xpress. I would like to combine the programs to reduce the 

burden of myself and the FAA. 

Please advise me with the next steps to take. 

Jared Watkins 

336-768-9126 

https://mail .google.com/mail/?ui-2&ik=48eb 106104&view=pt&search=inbox&msg= 12b5... 10/7/2010