ph: (907) 291-2339 

fax: (907) 291-2333 

summitctok@aol.com 

ph: (907) 563-5675 

fax: (907) 563-5685 

scs@scsalaska.com 

ph: (907) 458-7747 

fax: (907) 458-7748 

summitcfbks@gmail.com

 Tok Office 

HC 72 Box 850 

Tok, AK 99780 

Anchorage Office 

4500 Business Park Blvd, Ste. C-10 

Anchorage, AK 99503 

Fairbanks Office 

3745 Geist Road, Suite B 

Fairbanks, AK 99709

May 20, 2014 

Docket Management Facility 

U.S. Department of Transportation 

1200 New Jersey Avenue SE 

West Building Ground Floor 

Room W12-140 

Washington, D.C. 20590 

Reference: No. FAA-2014-0107 

To Whom It May Concern: 

Summit Consulting Services, Inc. has managed community sanitation design and 

construction projects in rural Alaska for 20 years. Our operations rely significantly on air freight 

services to mobilize project equipment and materials to numerous jobsites throughout each work 

season. 

We are writing in support of the Petition for Exemption, Docket Number FAA-2014-0107, 

wherein the Petitioner, Everts Air, seeks relief from certain requirements of inter alia §121.436 

of Title 14, Code of Federal Regulations. The recently enacted regulation requires co-pilots 

(second in command) hired or promoted to that position after 31 July 2013 to be certified as 

captains (pilot in command) with respect to the aircraft type rating. This regulation will also 

require all pilots serving as second in command to be certified in this manner after 01 January 

2016. 

The petitioner, Tatonduk Outfitters, Ltd., d/b/a Everts Air provides essential services in a 

unique environment. There are no simulator training devices for several of the aircraft they 

operate, including the DC-6 and C-46. Thus, all training must be conducted in the airplanes, in 

flight. It is noteworthy that Everts Air does not seek relief from the requirement that all pilots 

must possess airline transport licenses. 

This mandate will not result in an increased level of safety, rather a lower standard of safety 

as the more critical and technically demanding captain’s maneuvers will now be required of the 

second in command candidate. Historically, training in aircraft rather than simulators has proven 

dangerous, particularly in training lesser experienced pilots in emergency and abnormal 

procedures and maneuvers. This element represents an increased risk. 

When this rule was promulgated by Congress, there was an assumption made that all airline 

training was accomplished in a simulator. The simulator represents a safe and relatively low cost 

training environment. The cost of training a pilot in a flight simulator is on the order of $14,000. 

The cost of training the same pilot for the type rating course in the airplane is nearly ten times 

that, and represents a cost that Everts Air will have to pass along to us as the customer. 
Tok Office Phone: (907) 291-2339 Page 2 Tok Office Fax: (907) 291-2333 

We are deeply concerned that this cost will drive the petitioner to withdraw from several 

markets, leaving non-certificated and/or fewer safe operators. Their alternative is to increase the 

cost, making arctic operations impractical for industry, including aviation, thus increasing the 

cost of living in rural communities. 

The §121 air carrier has proven to be the safest supply chain for business, industry and 

residential needs in outlying areas. We agree with the petitioner’s position that training to the 

level that was in place before the enactment of 14 CFR 121.436 represents continued service at 

the highest standard of safety. 

In the interest of air safety and viable logistics options for rural communities, we are in favor 

of supporting the Petition for Exemption, Docket Number FAA-2014-0107. 

Sincerely, 

David A. Cramer, Principal