Post Office Box 630/ 27 Airport Lane

Lake Placid, NY 12946 November 3, 2011 US Department of Transportation Docket Management Sy stem 1200 New Jersey

Avenue, SE West Building Ground Floor, Room W12

- 140 Washington, DC 20590
To Whom It May

Concern:
Please review and accept the following petition for an exemption. (a) Company

name and contact details: Lake Placid Airway s, Inc dba Adirondack Fl yi ng Service Post Office Box 630/ 27 Airport Lane Lake Placid, NY 12946 Telephone 518.523.2473 Fax 518.523.1905 E mail: info@flyan yw here.com

(b) The s pecific section or sections of 14 CFR from which we seek exemption: We are seeking an exemption from part 121, appendices I and J of Title 14, Code of Federal Regulations (14 CFR). The proposed exemption if granted wo uld permit L ake Placid Airway s, In c to cover its safet y - sensitive employees under one testing program. (c) The extent of the relief we seek and the reason we seek the relief: We are se eking relief of the regulation to the extent that we operate and maint ain a single Antidrug and Alcohol Misuse Prevention Program for both P art 135 ( BPYA568C ) , our air carrier operation , and Part 91.147 (LKPJ568C) , our air tour operation’s safet y - sensitive employees . We seek such relief to eliminate the redundancy and waste involved with having two separate programs as a majority

of our eligible employ ees fall under both headings, Part 91.147 and Part 135. The redundancy

is cost prohibitive for our business in that single individuals are being tested twice the necessary per centage. The redundancy of testing would occur with 5 of the 7 employees. This double testing costs financially and w ith time away

from on site work and does not increase safet y. The Lake Placid Airway s, Inc designated emplo yer representatives will adequatel y manage all personnel under one drug and alcohol testing program and still meet the FAA’s requirements.(d) The reasons wh y granting the request would be in the public interest:

The public would benefit as a whole from our sing le Antidrug and Alc ohol Misuse Prevention Program as it would be upholding the standard of safet y set b y the regulations. The public would be assured that the testing though combined into one program would continue to prevent accident and injuries that result from the use o f prohibited drugs and misuse of alcohol by an y employee who performs a safety

- sensitive function for our part 135 and part 91.147 operations . Under one testing program each safety

- sensitive employ ee will still be subject to drug and alcohol testing in ac cordance with appendices I and J of part 121. (e) The reason why

granting the exemption would not adversel y affect safety, or how the exemption would provide a level of safet y a least equal to that provided b y the rule from which yo u seek exemption: By granting the exemption Lak e Placid Airway s, Inc will still be upholding the standard of safet y the regulation is seeking as each safet y - sensitive employee will still be subject to drug and alcohol testing in accordance with appendices I and J of part 121

. (f) A summary

we can publish in the Federal Register: We seek exemption from regulation Part 121, appendices I and J of Title 14, describing in detail that the drug and alcohol testing program is designed to prevent accidents and injuries that result from the use of prohibited drugs and the misuse of alcohol b y an y emplo ye e who performs safet y - sensitive functions for a part 119 certificate holder with authority to operate under parts 121 and/or 135 or an operator as defined in 91.147. L ake Placid Airw ay s, Inc is petitioning the FAA for an exemption from the regulatory requirements to implement and maintain two separate drug and alcohol testing programs for its part 135 air carrier operation and part 91 air tour operation. Lake Placid Airway s, Inc has a total of 7 safet y - sensitive employees, the majorit y of employees, five of which operate under both the part 135 operation and the part 91.147 operation. The five redundant employ ees have the possibility of being randomly

tested for both operations at th e same time. Lake Placid Airways, Inc states that this is a financial hardship to a small company

of its size. L ake Placid Airway s, Inc designated emplo ye r representative is capable and able to adequately manage all personnel under one antidrug and a lcoh ol m isuse p revention p rogram
. (g) An y additional information, views or arguments available to support our request: Inaddition we submit the cop y of Exemption No9703 granted to Solid Edge Aviation, LL C as support for our request. This exemption request by Solid Edge does not differ from our request in circumstance and reason. (h) If we want to exercise the privileges of the exemption outside of the United States: Not applicable to the regulationWe appreciate your time and attention to this matter

.

Sincerel y:

Kimberly Mahaney Lake Placid Airway s, Inc dba Adirondack Fl yi ng Service
enclosure