### From:LAKLOEY INC 907488 4067 05/20/2014 17:40 #344 P.001/002

1216RangeViewRoad 

# Lakloey,Inc NorthPole,Alaska99705-5389 GeneralContractor

Docket Management Facility U.S. Department of Transportation 1200 New JerseyAvenue SE West Building Ground Floor Room W12-140 Washington, D.C. 20590 Reference: No. FAA-2014-0107 To Whom It May Concern: Phone(907)488-9745 Fax(907)488-4067 E-mail:vezey@lakloey.com
5/20/2014

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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 

### interalia §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**~··** ' : ·r

### From:LAKLOEY INC 907488 4067 05/20/2014 17:40 #344 P.002/002

ina simulator. The simulatorrepresents a safe and relativelylow cost training environment. The cost of traininga pilot ina flight simulator is on the orderof $14,000.00. The cost of training the same pilot for the type rating course in the airplane is nearlyten times that, and represents a cost that Everts Air will have to pass along tous as the customer. We are deeply concerned that this cost will drive the petitionerto withdraw from severalmarkets, leavingnoncertificated and/or fewer safe operators. Their alternative is t·o increase the cost, making arctic operations impractical for industry, includingaviation, thus increasingthe cost of living in rural communities. The §121 air carrierhas proven to be the s·afest supply chain for business, industryand residential needs in outlying areas. We agree with the petitioner's position that trainingto the level that was inplacebefore the enactment of 14 CFR 121.436 represents continued service at the highest standardof safety. In the interest of air safetyandviable logistics options for rural communities, we a.re in favor of supportingthe Petition for Exemption, Docket Number FAA-2014-0107.

AllenVeze Secretary-Tr