AAM-11-294-E 

May 16, 2011 

 Exemption No. 10263 

 Regulatory Docket No. FAA-2011-0459 

Mr. Stephen Richards 

Ridgeline Aviation, Inc. 

3335 Airport Road, Suite C 

Boulder, CO 80301 

Dear Mr. Richards: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter dated April 27, 2011, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Ridgeline Aviation, Inc. (Ridgeline Aviation), for an exemption from part 120 of 

Title 14, Code of Federal Regulations (14 CFR). That exemption, if granted, would allow 

Ridgeline Aviation, which is operating under separate parts of 14 CFR, to cover its safetysensitive employees under one drug testing program. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to Ridgeline Aviation. 

The FAA has issued a grant of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption No. 9703 (copy enclosed), the FAA 

found that Solid Edge’s § 91.147 air tour operations were closely connected to its part 135 

operations. The FAA also found that combining the petitioner’s two testing programs into one 

would be in the public interest and would maintain an equivalent level of safety to that 

provided by the current regulations. Thus, the FAA concluded it was unnecessary to burden 

the petitioner by requiring it to conduct two separate testing programs. 
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Having reviewed your reasons for requesting an exemption, I find that— 

 they are similar in all material respects to relief previously requested in the enclosed Grant 

of Exemption No. 9703; 

 the reasons stated by the FAA for granting the enclosed Grant of Exemption No. 9703 

also apply to the situation you present; and 

 a grant of exemption is in the public interest. 

Our Decision 

Under the authority contained in 49 U.S.C. 40113 and 44701, which the FAA Administrator 

has delegated to me, I hereby grant Ridgeline Aviation, Inc., an exemption from part 120 to 

the extent necessary to allow Ridgeline Aviation, which is operating under separate parts of 

the regulations, to cover its safety-sensitive employees under one testing program, subject to 

the conditions and limitations described below. 

Conditions and Limitations 

1. Employees of Ridgeline Aviation are subject to the drug and alcohol regulations at 

all times while conducting operations under part 135 or part 91. 

2. The drug and alcohol testing program must be implemented under the auspices of 

the Ridgeline Aviation part 135 operation, not under part 91. 

This exemption terminates on May 31, 2013 unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

James R. Fraser, M.D. 

Deputy Federal Air Surgeon 

Enclosure 
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Project No.: AAM-11-294-E 

Project Officer: _______________ 

ARM-104:TTHOMAS:05/0411:Doc# 32385 

ARM-1/100/105:AAM-800 

 

 Statistics: RidgelineAviation.doc, 475 words 

 Original, 04 May 2011 08:45 

 Style Index 33 Good for a Regulation 

 Average Sentence Length 22 Good

 Passive Index 5 Excellent 

MR STEPHEN RICHARDS 

RIDGELINE AVIATION INC 

637 SOUTH BROADWAY B126 

BOULDER CO 80305