September 13, 2013

U.S. Department ofTransportation Docket Management System 1200 New Jersey Avenue, SE West Building Ground Floor, Room W12-140 Washington, DC 20590

Dear Sir orMadam: _._l :

RhinelanderFlying Service Inc., a FARPart 135 and Part 91.147 operator, requests an exemption from the requirement ofhaving multiple drug and alcohol testing programs as mandated by 14 CFR Part 120.117(a).

In orderto accomplish the requirements ofF AR Part 120 and that of49 CFR Part 40, we are requesting that both ofthese programs be consolidated and covered under our 14 CFR Part 135 Anti-drug (ADP) and Alcohol Misuse Prevention Program (AMPP) for**administration~** RhinelanderFlying Service and Wausau Flying Service is a small company, underthe same management and operating as one entity, with less than 10 full orparttime pilot and mechanic employees located at the Rhinelander and Wausau, Wisconsin airports. At this time, we are required to have two separateDesignated Employee Representatives (DER's) to administer two separateFAA mandated Drug and Alcohol testing programs for a total ofeight pilots and mechanics••.three ofwhich are on the 91.147 testing program •••most of these employees are parttime only. Theplanes and pilots are shared between the two companies and under one insurance policy. Only the current drug/alcohol program doesn't
run as a shared management program. Thus, this requires us to maintain different data management systems to keep the information separate (and confidential) between the two programs. This has become a cumbersome process for us and the MedicalReview Officer (MRO), not to mention the additional cost involved.

Our company employs several pilots and aircraftwhich are used for both Part 135 and 91.147 Scenic Flight Air Tours. The problem arises from how they accomplish their different roles while employed at one company. The 135 pilots must operate an Air Tour flight as a 135 flight while a 91.147 Scenic pilot can operatethe same aircraftwithoutthe extra burden of 135 rules and regulations, resulting in less costto us and the public. The maintenance ruJes differfrom a 135 maintained aircraftthan one underPart91. I am not sure ifthe mechanics must be under two drug programs to maintain a dual use (135 and 91.147) aircraft. All ofour mechanics are on the 135 Drug/Alcohol testing program. We could decrease cost to the public, our clients, for the servicewe render by avoiding redundanttesting programs.

### According to FARPart 120.103 and .203, the purpose ofthis rule is to establish a program designed to help prevent accidents and injuries resulting from the use ofprohibited drugs and misuse ofalcohol by employees who perform safety sensitive functions atRhinelander Flying Service. By allowing us to screen ouremployees under one comprehensive Drug and Alcohol Testing Program, we will be in a betterposition to catch mistakes in screening for unwanted substances ratherthan spending wasteful time administering multiple redundant programs. Forthis, and for the other reasons discussed above, I believe we will be able to provide a much saferenvironment to the general public.

Thankyou for your consideration in this matter. Please let me know if

### you have any further questions.

Charles Turner President RhinelanderFlying Service 715-365-3456 aviation\a),newnorth.net