November 4, 2015 

U.S Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room W12-140 

Washington, DC 20590 

Snohomish Flying Service, INC. 

9900 Airport Way, Harvey Field (S43) 

Snohomish, WA 98296 

Phone: (360) 568-1541 **Fax: (360) 568-6034 

www.snohomishflying.com 

Subject: Request for renewal of exemption No. 10558 from Part 120 of Title 14, Code of Federal 

Regulations (14CFR) to the extent necessary to allow Snohomish Flying Service (SFS) to 

continue to cover its safety-sensitive employees under one drug and ale hoi testing program. 

Dear Sir, 

This letter represents a formal request on behalf of Snohomish Flying S rvice for renewal of its 

exemption from Part 120 ofTitle 14, Code ofFederal Regulations (14CFR) to the extent 

necessary to continue to cover its safety-sensitive employees under one drug and alcohol testing 

program for its part 135 operations and commercial air tour operations a defined under 14 CFR 

91.147 

Snohomish Flying Service located at Harvey Field (S43) in Snohomish, WA is approved by 

FAA as a part 141 flight school, part 135 commercial operator and part 91.147 air tour operator. 

The Safety Sensitive Employee are common to all operations and all per onnel responsible for 

part 135 and part 91.147 air tour operations are direct employees of Snohomish Flying Service. 

SFS operations are conducted from a common principal base of operations, main operations 

base and main maintenance base. All aircraft, flight crew and mainten nee facilities are 

located at the same facility at Harvey Field. Thus it is logical and cost effective that all 

personnel should fall under a common drug and alcohol program. 

Employees of Snohomish Flying are subject to the drug and alcohol reg lations at all times 

while conducting operations under part 135 or part 91.147. The drug and alcohol program is 
implemented under the same auspices of the SFS part 13 5 operation, not under part 91 . 

Combining the drug and alcohol program for part 135 and part 91.147 eliminates redundancy 

and enhances efficiency. It is far more effective and accurate to administer and maintain records 

for a single program that applies equally across the board at the higher standard to all safetysensitive employees. 

The public would benefit in the sense that the flight schedule would be 1 ss likely to be 

negatively impacted by more frequent random drug testing from two separate programs for the 

same individuals. SFS would experience a reduction in paper work and a lessor burden on office 

and administrative staff while still attaining the same high standard and desired result. 

Our current exemption expired on July 31 , 2014. SFS has a valid part 135 certificate but has not 

employed 135 pilots or conducted 135 operations since June 17, 2013 . Safety sensitive 

employees engaged in 14 CFR 91 .14 7 operations continue to be tested at the higher standard in 

accordance with the drug plan approved in the SFS part 135 operation specifications. Our desire 

is to secure renewal of the exemption so that safety sensitive employees engaged in part 135 and 

part 91.14 7 operations can continue to be tested under one drug program. We will await your 

response before activating a pilot under the part 135 operations to ensur that it continues to be 

acceptable under exemption to test all safety sensitive employees under one drug program. 

I appreciate your attention to this matter and please do not hesitate to contact me should you 

require additional information or supporting documentation. 

Sincerely, 

SNOHOMISH FLYING SERVICE INC.