POR T TOWNSEND AI R, LLC Jef ferson Co. Int'l Airport 191 Airport Rd Port To wnsend, W

A 98368 360
- 385
- 7770 360
- 385
- 7797
- fax Docket Management Facility U.S. Department of T

ransportation 1200 New Jersey

Av enue S.E. Room W12
- 140 Wa shington, DC 20590 PETI TI ON FOR EXEMPTI ON Name and Mailing Address: Port To wnsend Air , LLC 191 Airport Rd. Port To wnsend, W

A 98368 Contact: Jodi Hallinan

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- 7770 j odi@fly portttownsend.com Specific Exemption: Ti tle 14 CFR 120, Subpart A, D, E Extent of Relief: Port To wnsend Air , LLC operates under an F AA Part 135 Drug Abatement Program in accordance with T itle 14 CFR Part 120. Port To wnsend Air , LLC has applied and received a Letter of Authorization to operate some of our flight operations under T itle 14 CFR Part 91.147 Operations certificate. As the Ti tle 14 CFR Part 91 operation requires a separate Drug and Alcohol Program from the Part 13 5 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 T ownsend Air, LLC has been approved by the F AA to operate under a Part 135 ru les 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 compan y and the F

AA having to regulate, monitor, audit, and perform the duties of two identical programs are passed either directl y or indirectly to the public in the form of fees or taxes. Second, safet y is our number one concern. W

e have a zero

- tolerance policy for drug and alcohol abuse. As one compan y that operate two F AA certificates, we have an obligation to the public to not put any one into a safety

- sensitive position that has violated our policy

as a single company

. Reasons Why Exemption W ould Not Adversel y Affec t Safety : Port To wnsend Air , LLC is currently operating under an F AA 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 adversel y aff ect 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. S ummary : Port To wnsend Air, LLC is seeking to petition for exemption Ti tle 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 w hich 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. Granti ng our request for an exemption will benefit the public in terms of monetary

saving and safet y. In addition, operating one Drug and Alcohol Program underneath the other program will not adversely af fect safety

, but improve it as the goal is to keep the pu blic safe. Thank y ou for y our time and consideration, Bartley J. Hallinan, Member Port To wnsend Air , LLC