November 4, 2015
U.S Department ofTransportation 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 **F ax: (360) 568-6034 www.snohomishflying
.com

Subject: Request for renewal of exemption No. 10558 from Part 120 of T

itle 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 testingprogram. Dear Sir, This letter represents a formal request on behalfof Snohomish Flying S rvice for renewal ofits 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 9 1.147 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 ofoperations, 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 isimplemented under the same auspices ofthe SFS part 135 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 safety

sensitive 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
. 147 operations continue to be tested a t the higher standard in accordance with the drug plan approved in the SFS part 135 operation specifications. Our desire is to secure renewal ofthe exemption so that safety sensitive employees engaged in part 135 and part 91.147 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
.