October 29, 2012 Via Submission to Regulations.Gov (Shell Docket FAA-2007-0001-0001) U.S. Department ofTransportation DocketManagement Facility 1200New Jersey Avenue, S.E. West Building, Ground Floor Room W12-140.Washington, D.C. 20590 

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Moyer Aviation, Inc. Petition for Exemption from 14 C.P.R. Part 120.1(a) as it applies to Part 91.147(d) and Part 135. Pursuantto**14C.F~R.** 11.61(b) and 11.81, Moyer Aviation, Inc. hereby petitions for an exemption to permit itto combine the drug testing programs for its Part 91.147 and Part 135 operations. (a)Contact information: Laverne Moyer Substance Prevention/Abuse Program Manager Moyer Aviation, Inc. 3800 Sullivan Trail EastoK·Pa. 18040, · 6i0:-258-04173 ' vem@moyeraviati'oll.com ' : j
(b) The specific sections ofl4.C.F.R. from which an exemption is sought: 120.1**Applic~bilit)r.** . !**~** :
- '·,' Thispart applies to the following persons: (<:!.) All Air Carriers and operators certificated under part 119 ofthis chapter authotized to conductoperations under part 121 orpart 135 ofthis chapter, all air traffic control facilities not operated by the FAA orby orunder contract to the U.S. military, and all operators as defmed in 14 CFR 91.147. © The extent ofreliefsought, and reason for the reliefsought: Moyer Aviation, Inc. operates underboth Part 91.147 and Part 135. Atthis time we have 

### only one pilot onthe part 91.147 program enrolled in our drug and alcohol program. We also ha:ve a 

### dnig 'and alcohol program for our 135 operation.

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·•"' I' .- '**~** ' '.. ' . ,**;·~** . . . I I,_ • I**,~I**We are requesting thatthe two drug and alcohol programs be combined because we are an extremely small operation with less than tenpilots. Beingrequired to operate two separate programs is a financial and administrative hardship to our company. Itwill also eliminate duplicate paperwork. (d) The reasons why granting this request is in the public interest: All ofMoyer Aviation, Inc. employees in safety sensitive positions have been screened for illicit drug use in full compliance withthe requirements in C.P.R. 120. Accordingly, Moyer Aviation, Inc. has metthe public interest in ensuring that illicit drug users are detected and prevented from performing a safety sensitive position. Requiring Moyer Aviation, Inc. to duplicate drug & alcohol testing programs for Part 91.147 and part 135 is repetitive and is adding unnecessary fmancial burdento such a small company. Itwill also save a lot ofunnecessary paperwork for us as well as the FAA. Combining the programs would continue to meet the intent of 14 C.F. R. 120. (e)The reasons why granting the exemption would not adversely affect safety, orhowthe exemption would provide a level ofsafety at least equal to that provided by the rule from whichthe exemption is sought: The exemptionwould not aversely affect safety because all ofthe employees who have performed safety sensitive functions for Moyer Aviation, Inc. have been andwill continue to be subjectto the drug testing requirements as outlined in 14 C.P.R. 120. (f) A summary to be published 

### inthe Federal Register stating the rule from which an exemption is sought and a briefdescription ofthe nature ofthe exemption sought: 14 C.F.R. 120.l(a) All air carriers and operators certificated underpart 119 ofthis chapter authorized to conduct operations under part 121 orpart 135 ofthis chapter, all air traffic control facilities not operated bythe FAA orby orunder contract to the U.S. military, and all operators as defined 14 CFR 91.147. MoyerAviation, Inc. respectfully requests that we receive an exemption from having two separate drug and alcohol programs and are able to combine the Part 135 and the Part 91.147 drug and alcohol testing programs. (g) Any additional information, views or arguments available to supportyourrequests: Inkeeping with the governments paperwork reduction program it would save tax payer money.