Interstate HelicoDters 

5809 Philip J. Rhoads, Hangar #4 - ^ Bethany, OK 73008 405.440.1053 

February 24,2010 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE. 

West Building Ground Floor, Room WJ^-HO 

Washington, DC 20590 CT) 

RE: Request for Exemption under 14 FAR CFR partl20 and explained in 14 CFR §11.61-11.101. 

To Whom It May Concern: 

Please accept this letter as Interstate HelicopttTs Inc. (IHI) formal petition for exemption in accordance 

with FAA's requirements established underl4 CFR § 11.61-11.101, per this petition IHI is requesting 

relief by allowing our Drug and Alcohol testing to be combined under part 135 operation. IHI is located at 

5809 Philip J Rhoads Ave. Hangar 4, Bethany OK 73008. Our office telephone number is 405.440.1053, 

fax 405.440.0115. Our email address isjjcopter@aol.com. 

Drug and alcohol testing regulations, found in 14 CFR part 120 require that part 119 certificate holders 

with the authority to operate under parts 121 or 135 and air tour operators as defined in §91.147 must 

implement a Drug and Alcohol testing program. It has been explained to me that the FAA's interpretation 

of this requirement is that because it does not specifically state the two parts can be combined the FAA is 

interpreting it so that each operator will be re<^uired to implement separate and distinct testing programs. 

It is from this requirement that IHI is seeking relief and exemption. EHI requests the ability to cover both 

operations with one testing program with this exemption. 

By offering us this relief it will enable us to keep or costs competitive (small business relief). This relief 

will allow us to continue to offer a variety of services within our community and continue to employ 

helicopter operators at this business location. This will also allow for competition within Oklahoma City 

area. 

We submit that there is no adverse affect to tltie community as a whole or to an individual(s) who engage 

our services under our part 119 operating under 121 or 135 or 91 §147 air tour operators. This is the case 

because each of our personnel is actively covered under a Drug and Alcohol testing program meeting all 

of FAA's requirements. To have two separate and distinct programs would in effect duplicate the amount 

of testing necessary per 14 FAR part 120 and burden IHI with unnecessary costs without providing any 

additional protective benefits to the community at whole or to individuals who actively seek our services. 

V. 
In summary 14 CFR part 120 requires that eacih part 119 certificate holder with the authority to operate 

under parts 121 or 13 5, and air tour operators as defined in §91.147 must implement a Drug and Alcohol 

testing program. IHI is currently in compliance with this requirement. IHI has been made aware that the 

FAA's interpretation is that since the regulations do not specifically state that the Drug and Alcohol 

programs may be combined there must be two separate and distinct testing programs in existence. IHI 

covers the exact same pool of employees in each of its operations and tiierefore we believe we are 

meeting the intent of existing FAA regulations which would enable us to be eligible to be considered for 

an exemption and allow us to combine both operations under one testing program. We are fully 

compliant wdth the intent of the regulations which is to protect public as a whole and individually. 

Requiring us to implement two separate and distinct drug and alcohol programs would limit profitability 

and jeopardize our ability to continue offering Christmas tours, and a small samplmg of other tours 

throughout the year which would not be in the best interests of the Oklahoma City community. In 

addition, by operating two programs it would in effect duplicate our compliance with the requirements for 

Drug and Alcohol testing under 14 CRF part 120. 

We respectfiilly submit our petifion andfhahl: you for your tiiiie^dconsideralioh. ~ 

Smcerely, 

Kathy Blankenship 

Interstate Helicopters Inc. 

405 440 1053