Maine Scenic Airways, Inc. P.O. Box 1144 Belfast, ME 04915

U.S. Department ofTransportation Docket Operations, M-30 West Building ground floor Room W12-140 1200 NewJersey Avenue, SE Washington, DC 20590 November 2, 2012



### PETITION FOR EXEMPTION EXTENSION

Maine Scenic Airways, Inc. P.O. Box 1144 Belfast, ME 04915 mainescenicairways@myfairpoint.net Telephone: 207 338 4736**z~** 

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Maine Scenic Airways, Inc. is reque$ting an extension ofExemptionNo: 9831 from 14 CFR (FAR Section)

- 121, Appendix ofF AR- I and J ·dockct number ··· · ·**FAA-2009~0131** I· .• I ' •

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. · Maine Scenic Airways, Inc. seeks tobe allowed tocontinue itsFAR 135 operations and FAR91 operations under one drug and alcohol program. Maine Scenic Airways, Inc. is a very small companywith only three pilots onits current drug and alcohol program and has only one airplane involved in these operations. One pilot, the owner/manager and the only full time employee, flies the single pilot FAR 135 operations and FAR91 air tour operations. The othertwo other pilots are part time. Both currently fly the occasional FAR91 air tour. Because ofthe present recession, Maine Scenic Airways, Inc. will continue to operate only one plane for all FAR91 air tour and FAR 135 operations for the foreseeable future. Again,.it does not seem reasonable to expect that implementing two separate and distinct drug and alcohol programs would, giventhe small size ofthe company, enhance safety in any way. Instead, doing so would only increase an already intense paperwork/management burden and impose additional costs upon Maine Scenic Airways, Inc. Granting Maine Scenic Airways, Inc.'s request will help the public. First, it will help keep the.cost ofcharterflights and air tours down. Second, by not imposing needless expense, it will help keep a small flight school/charteroperator/ air tour operator/FBO in business. The FBO at Belfast is also the pro bono assistant airport ,manager and is the only personwho is regularly atthe airport. Maine Scenic Airways, Inc. has**als~** provided parttime employment and flying lessons to local areateenagers. Presently, Maine Scenic Airways, Inc. has two high school studentswho are completingtheir Private Pilots Licenses and will beincludingthat qualification ontheir applications to Embry Riddle Aeronautical University this fall. Three ofMaine Scenic Airways' former flight students are flying for theUnited States AirForce. It would bea sad thing to lose this opportunity for local youth as well as local residents. IfMaine Scenic Airways, Inc. were to close its doors, it is unlikely that another similarbusiness would open up any time soon as many small flight schools and FBOs are struggling and going out ofbusiness. Granting the requested exemption extension would not harm safety as all employeeswho perform safety sensitive functions are on an approved drug program underthe same management. Unless it could bedemonstrated thattwo drug programs operating in parallel are more effective than one, the requirement to have two is redundant and creates an unnecessary burden.

Maine Scenic Airways, Inc. does not wish to exercise the privileges ofthis requested exemption extension outside the United States.

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# :$.' ;eynolds, P sident Maine Scenic Airways, Inc.