May 22 14 09:46p GzCorp 

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: 

Gwitchyaa Zhee Corporation 

PO Box 329 

Fort Yukon, AK 99740 

19076623056 p.2 

-' .. --~:-:- c: 

1: 

5/20/2014 

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 31July 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 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, there was an assumption made that all airline training 

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

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 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, 

'~1"~~~~LL'~ CEO, Gwitchyaa Zhee Village Corporation 

907 662. 2.933 

gzcorporation@yahoo.com 
May 22 14 09:46p GzCorp 19076623056 p.1 

FAX 

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Gwitchyaa Zhee Corporation ~ l I '7 

P.O.Box329 'FaxNumber: 1-fJL ZtC(?.Q._,2J6/' 

Fort Yukon, AK 99740 l -:j , ~ Phone: 907-6G2-2933 From: . Fax: 907-66

2

_

3056 

Fax Nu~m~b::er~: ----------

gzcorporatio n@yahoo. com 

COMMENTS: 

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Frannie GZ Corporation CEO