From:LAKLOEY INC 907 488 4067 05/20/2014 17:40 #344 P.001/002 

1216 Range View Road Lakloey, Inc 

North Pole, Alaska 99705-5389 General Contractor 

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: 

Phone (907) 488-9745 

Fax (907) 488-4067 

E-mail: vezey@lakloey.com 

5/20/2014 

l'"'·. 

f .. :.• 

j·o,.._.) 

"'"'>..;: '' 

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 

~·· ' : ·r 
From:LAKLOEY INC 907 488 4067 05/20/2014 17:40 #344 P.002/002 

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 

$14,000.00. 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. 

We are deeply concerned that this cost will drive the 

petitioner to withdraw from several markets, leaving noncertificated and/or fewer safe operators. Their 

alternative is t·o 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 s·afest 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 a.re in favor of supporting the 

Petition for Exemption, Docket Number FAA-2014-0107. 

Allen Veze 

Secretary-Tr