Helicopter Commute Service,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(b) and 11.81, Helicopter Commute Service,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:

Chris McNeill 

Substance Prevention/Abuse Program Helicopter Commute Service,LLC 

60 Henshaw Ave

New Jersey 07081

chris@helicommute.net

(b) The specific sections of 14 C.F.R. from which an exemption is sought:

120.1Applicability.

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 

operators as defined in 14 CFR 91.147.

(c) The extent of relief sought, and the reason for the relief sought:

Helicopter CommuteService,LLC is under both Part 91.147 and Part 135. At this time, 

any pilot who is flying/maintaining under Part 135 is already enrolled in a drug and 

alcohol testing program and 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. Being required to 

operate two separate programs is a financial and administrative hardship to our 

company.

(d) The reasons why granting this request is in the public interest:

 Helicopter Commute Service,LLC in safety sensitive positions have been screened for 

illicit drug use in full compliance with the requirements in 14 C.F.R. 120. Accordingly, 

Helicopter Commute Service,LLC has met the public interest in ensuring that illicit drug 

users are detected and prevented from performing a safety sensitive position. Requiring 

Helicopter Commute Service,LLC Inc. 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 of 

14 C.F.R. 120.
(e) The reasons 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 of the employees who 

have performed safety sensitive functions for Helicopter Commute Service,LLC 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 the U.S. 

military; and all operators as defined in 14 CFR 91.147.

Helicopter CommuteService,LLC 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.

In our recent Audit the Inspector was not aware that we had two programs when he 

was notified in the inspection we were a 135 operator also, it was suggested by the 

inspector to become a Dual Operator to condense the paper work for better clearer FAA 

inspections of all the paper work required to be in compliance.

(h) If you want to exercise the privileges of your exemptions outside the United States, 

you must include your reasons.

Helicopter CommuteService,LLC currently does not operate outside the U.S. 

Respectfully submitted,

Chris McNeill

Owner/Member

Helicopter Commute Service, LLC