Wisconsin Aviation, Inc. 3606 Corben Court Madison, WI 53704 608.268.5000



### January 17, 2014

U.S. Department ofTransportation Docket Operations, M-30 West Building Ground Floor Room W12-140 1200 NewJersey Avenue, SE Washington, DC 20590

Docket# FAA-2010-0456

To Whom It May Concern:

Wisconsin Aviation, Inc., an FAR Part 135, Part 145, and Part 91.147 operator, requests an extension ofexemption number 10060 relieving us from the requirement of having multiple drug arid ·alcohol testing progra·ms as'trri:mdated. by 14 CFR Part 120.117(a). 

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### in orderto·accomplish the requirements of FAR Part 120·and that of49 c·FR Part 40, we are requesting that all three programs continue to be directed to a'nd covered urider our14 CFR Part 135 Anti-Drug (ADP) and AlCohol Misuse Prevention Program (AMPP} fotadminfstration.

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### Withoutthis exemption ifis extremely bur<lensome a·nd ofte·n impossible to,administerthree programs with three differe'nt DERs iri one small corhpany, while· keeping the information · separated. The result becomes a cumbersome process for us, the MRO, and the 'FAA: This arrangement has created a movingtarget because ofvarying interpretations ofthe applicable regulations, additional opportunitiesfor mistakes in applying and documentingtesting, and increased cost because ofduplicitoustesting ofstaffthatfunctions in more than one program.

Our company employs several pilots, mechanics, and aircraft which "crossover'' and are used on
more than one certificate. The problem arises from howthey accomplish their different·roles while employed at one company, ·one·example'ofthis-was highlighted d'urihg

# apast inspection ofourdrug and alcohol testing program. During the inspection, we were told by one inspector that a 91.147 drug-tested mechanic could only work on an "AirTour" aircraft. When asked the question ifan aircraft is used for more than one program (i.e.,

# an airplane is used for both Part 135 and 91.147) which applies to us, 

### whiCh mechanic could work

### cin that aircraft? We were given a different answer; which was that either'program's mechanics could perform · . maintenance on that aircraft. The conflicting information still leaves me wondering who is really authorized

### towork onthe aforementioned aircraft. '



# -----------------------------------------------------------------------------------We also are required by FAR to keep the test results and other information "confidential" between "companies," even though Wisconsin Aviation is only one company. Because ofthe close innerworkings ofour organization, we find thatwe are making extensive "workarounds" in orderto keep this information separate. Employees often work in more than one certificate program, and as a company with a human resources department consisting ofone person, it makes separating this information impossible. Additionally, it makes itvery difficultto disseminate records to other air carriers, through the FAA required Pilot Record Improvement Act of 1996 (PRIA), afteran employee leaves our company for outside employment.

Ironically, the Management Information System (MIS) reports, which are generated to report data to the FAA aboutthe effectiveness and trends in the substance testing programs, only apply when 50 or more employees are tested in each program. Per FAR Part 120.119(a)(2), we currently cannot provide this information; however, ifour programs are combined, the resulting increase in the numberofemployees in the test pool would require us to submitthe report, for all its derived benefits.
According to FAR Part 120.103 and .203, thepurpose ofthis rule was to establish a program designated to help prevent accidents and injuries resulting from the use of prohibited drugs and misuse ofalcohol by employees who perform safety-sensitive functions in aviation. By allowing
us to screen ourstaff under one comprehensive drug and alcohol testing program, we will continue to be in a better position to catch mistakes in screening for unwanted substances ratherthan spending wasteful time administering multiple redundant programs. For this, and forthe other reasons discussed above, I believe we will be able to provide a much safer environmentfor the public.

We appreciate your consideration in this matter. Please let me know ifyou have any further questions.
Sincerely,

# ~ Grant E. Goetsch VP Flight Operations Wisconsin Aviation, Inc. Dane County Regional Airport 3606 Corben Court Madison, WI 53704-2573 Phone: 608.268.5015 Fax: 608.268.5037 GrantG@WisAv.com