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

s ummitc f

bks @ g mail.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 ma naged community sanitation design and construction projects in rural Alas ka for 20 years. Our operations rely significantly on air freight services to mobilize project e quipment and materials to numerous jobsites throughout each work

season. We are writing in support of the Petiti on for Exemption, Docket Number FAA-2014-0107, wherein the Petitioner, Everts Air, seek s 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 pr omoted 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 s econd 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 traini ng devices for several of the aircraft they operate, including the DC-6 and C-46. Thus, all tr aining must be conducted in the airplanes, in flight. It is noteworthy that Ever ts 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 cap tain’s maneuvers will now be required of the second in command candidate. Historic ally, training in aircraft rath er than simulators has proven dangerous, particularly in tr aining lesser experienced pilots in emergency and abnormal procedures and maneuvers. This elem ent 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 pilo t in a flight simulator is on the order of $14,000. The cost of training the same pilot for the type ra ting 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.Page 2 Tok Office Phone: (907) 291-2339 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 altern ative is to increase the cost, making arctic operations impractical for in dustry, including aviati on, thus increasing the cost of living in rural communities.
The §121 air carrier has proven to be the safe st supply chain for bus iness, 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 re presents 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