PORT TOWNSEND AIR, LLC

Jefferson Co. Int'l Airport

191 Airport Rd

Port Townsend, WA 98368

360-385-7770 360-385-7797-fax

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Avenue S.E. Room W12-140

Washington, DC 20590

PETITION FOR EXEMPTION

Name and Mailing Address: Port Townsend Air, LLC

 191 Airport Rd.

 Port Townsend, WA 98368

 Contact: Jodi Hallinan – 360-385-7770

 jodi@flyportttownsend.com

Specific Exemption: Title 14 CFR 120, Subpart A, D, E

Extent of Relief: Port Townsend Air, LLC operates under an FAA Part 135 Drug Abatement Program in 

accordance with Title 14 CFR Part 120. Port Townsend Air, LLC has applied and received a Letter of Authorization 

to operate some of our flight operations under Title 14 CFR Part 91.147 Operations certificate. As the Title 14 CFR 

Part 91 operation requires a separate Drug and Alcohol Program from the Part 135 certificate, we are filing this 

petition for exemption to allow the two certificates to be operated under one drug program under our one company.

Benefit to the Public: Port Townsend Air, LLC has been approved by the FAA to operate under a Part 135 rules and 

Part 91.147 rules which both require their own separate Drug and Alcohol program. By combining the Drug and 

Alcohol Program into one program, the public benefits in at least two ways. First, the costs associated with both 

our company and the FAA having to regulate, monitor, audit, and perform the duties of two identical programs are 

passed either directly or indirectly to the public in the form of fees or taxes. Second, safety is our number one 

concern. We have a zero-tolerance policy for drug and alcohol abuse. As one company that operate two FAA

certificates, we have an obligation to the public to not put anyone into a safety-sensitive position that has violated 

our policy as a single company.

 

Reasons Why Exemption Would Not Adversely Affect Safety: Port Townsend Air, LLC is currently operating under 

an FAA approved Drug Abatement Program under the Part 135 certificate. Placing the Part 91.147 Drug and 

Alcohol Program underneath the Part 135 Drug and Alcohol Program would not adversely affect safety because the 

only thing that would change would be the amount of paperwork involved. The random drug and alcohol testing, 

the pilot training, the supervisor training, the record keeping would still occur, but it would not have to occur twice.

Summary: Port Townsend Air, LLC is seeking to petition for exemption Title 14 CFR 120, Subpart A, D, E which 

states that each certificate holder or operator must have its own Drug and Alcohol Program. The rule, however, does 

not address the situation in which a single company holds two certificates that each require a Drug and Alcohol 

Program. As that is our case, we are requesting that Part 91.147 certificate be able to operate underneath the already

established Part 135 Drug and Alcohol Program. Granting our request for an exemption will benefit the public in 

terms of monetary saving and safety. In addition, operating one Drug and Alcohol Program underneath the other 

program will not adversely affect safety, but improve it as the goal is to keep the public safe.

Thank you for your time and consideration,

Bartley J. Hallinan, Member

Port Townsend Air, LLC