September 13, 2013 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE 

West Building Ground Floor, Room W12-140 

Washington, DC 20590 

Dear Sir or Madam: 

_._l : 

Rhinelander Flying Service Inc., a FAR Part 135 and Part 91.147 operator, requests an 

exemption from the requirement of having multiple drug and alcohol testing programs as 

mandated by 14 CFR Part 120.117(a). 

In order to accomplish the requirements ofF AR Part 120 and that of 49 CFR Part 40, we 

are requesting that both of these programs be consolidated and covered under our 14 CFR 

Part 135 Anti-drug (ADP) and Alcohol Misuse Prevention Program (AMPP) for 

administration~ 

Rhinelander Flying Service and Wausau Flying Service is a small company, under the same 

management and operating as one entity, with less than 10 full or part time pilot and 

mechanic employees located at the Rhinelander and Wausau, Wisconsin airports. At this 

time, we are required to have two separate Designated Employee Representatives (DER's) 

to administer two separate FAA mandated Drug and Alcohol testing programs for a total 

of eight pilots and mechanics ••. three of which are on the 91.147 testing program ••• most of 

these employees are part time only. The planes 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 Medical Review Officer 

(MRO), not to mention the additional cost involved. 

Our company employs several pilots and aircraft which 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 operate the same aircraft without the 

extra burden of 135 rules and regulations, resulting in less cost to us and the public. The 

maintenance ruJes differ from a 135 maintained aircraft than one under Part 91. I am not 

sure if the mechanics must be under two drug programs to maintain a dual use (135 and 

91.147) aircraft. All of our mechanics are on the 135 Drug/Alcohol testing program. We 

could decrease cost to the public, our clients, for the service we render by avoiding 

redundant testing programs. 
According to FAR Part 120.103 and .203, the purpose of this rule is to establish a program 

designed to help prevent accidents and injuries resulting from the use of prohibited drugs 

and misuse of alcohol by employees who perform safety sensitive functions at Rhinelander 

Flying Service. By allowing us to screen our employees under one comprehensive Drug and 

Alcohol Testing Program, we will be in a better position to catch mistakes in screening for 

unwanted substances rather than spending wasteful time administering multiple redundant 

programs. For this, and for the other reasons discussed above, I believe we will be able to 

provide a much safer environment to the general public. 

Thank you for your consideration in this matter. Please let me know if you have any 

further questions. 

Charles Turner 

President 

Rhinelander Flying Service 

715-365-3456 

aviation\a),newnorth.net