### May 22 14 09:46p GzCorp

Docket Management Facility U.S. Department ofTransportation 

### 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: Gwitchyaa Zhee Corporation PO Box 329 FortYukon, AK 99740 

### 19076623056 p.2



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### 5/20/2014

We are writing in support of the Petition for Exemption, Docket Number FAA-2014-0107, whereinthe Petitioner, Everts Air, seeks relieffrom certain requirements of

### interalia 

### §121.436 ofTitle 

### 14, Code of Federal Regulations. The recently enacted regulation requires co-pilots {second in command) hired or promoted to that position after 31July 2013 to be certified as captains (pilot in command) with respect to the aircrafttype 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 simulatortraining devices for several ofthe aircraftthey operate, including the DC-6 and C-46.

### Thus~ all training must be conducted in the airplanes, in flight. It is noteworthythat Everts Airdoes not seek relief from the requirementthat all pilots must possess airline transport licenses. This mandate will not result in an increased level ofsafety; rather a lower standard ofsafety as the more critical and technically

### demandin~ 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, therewas an assumption made that all airline training was accomplished in a simulator. The simulator represents a safe and relatively low costtraining

### May 22 14 09:46p GzCorp 

### 190766i3056 p.3

environment. The cost of training a pilot in a flight simulator is on the order of $14,DOo;oo. The cost of trainingthe same pilot for the type 

### rating course inthe airplane is nearlyten times that, and represents a cost that Everts Airwill have to pass along to us 

### as the customer. We are deeply concerned that this cost 

### will drive the petitionerto 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 thatwas in place before the 

### enactment of 14 CFR 121.436 

### represents continued service 

### at the 

### highest standard of

### safety. 

### In the interest 

### ofair safety 

### and viable logistics options for rural communities, we are in favor of supporting the Petition for 

### Exemption, Docket Number FAA-2014-0107. 

### Sincerely,

# '~1"~~~**~LL'~** CEO, Gwitchyaa Zhee 

### Village Corporation 907 662. 2.933 

### gzcorporation@yahoo.comMay 22 14 09:46p 

### GzCorp 19076623056 

### p.1 

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## c-h. Gwitchyaa Zhee Corporation

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## '7 P.O.Box329 'FaxNumber: 

# 1-fJL ZtC(?.Q._,2J6/' Fort Yukon, AK 99740 

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# ~ Phone: 907-6G2-2933 From:

. 

### Fax: 907-662_ 3056 Fax

## Nu~m~b::er~:---------- gzcorporation@yahoo.com



# COMMENTS:

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Frannie GZ Corporation CEO