January 24, 2013

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 W12140

Washington, DC 20590

Story Airways, 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, Story Airways, 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:

David Story 

Substance Prevention/Abuse Program Manager

Story Airways, LLC.

2722 Perimeter Rd Suite 110, 

North Las Vegas, NV 89032

702-686-4943

david@storyairways.com

(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:

Story Airways, 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

five pilots. 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:

All of Story Airways, LLC. employees in safety sensitive positions have been screened for illicit drug

use in full compliance with the requirements in 14 C.F.R. 120. Accordingly, Story Airways, LLC. has

met the public interest in ensuring that illicit drug users are detected and prevented from performing

a safety sensitive position. Requiring Story Airways, LLC. 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 Story Airways, 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.

Story Airways, 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.

None

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

include your reasons.

Story Airways currently does not operate outside the U.S.

Respectfully submitted,

David Story 

President

Story Airways, LLC.