Erin B. Marston 

4109 Tazlina Avenue 

Anchorage, Alaska 99517 

(907) 242-9901 

November 7, 2015 

CERTIFIED MAIL- RETURN RECEIPT REQUESTED 

Mr. Kerry B. Long 

Federal Aviation Administration 

Alaska Region 

222 West 7th A venue, # 14 

Anchorage, Alaska 99513 

U.S. Department of Transportation 

Docket Operations, M-30 

West Building ground floor, 

Room W12-140 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Re: Iditarod Air Force- Request for extension of Exemption No. 9810 

Dear Mr. Long: 

I am writing on behalf of the Iditarod Air Force to request a two year extension of 

Exemption No. 9810 which the Iditarod Air Force has been operating under for over seven years. 

Please accept this letter as a request on behalf of the IAF and on behalf of the Iditarod Trail 

Committee to extend Exemption No. 9810 (Regulatory Docket No. FAA-2008-1246) for an 

additional two years, until April 30, 2018. I have been designated the representative of the 

Iditarod Air Force ("IAF") relating to the exemption and would appreciate receiving future 

correspondence concerning this matter. 

Pursuant to 14 CFR Part 11, and in particular 14 CFR § 11.81, I am providing the FAA 

with the following information. I am also providing a copy of the February 25, 2014 letter 

granting an extension ofthe exemption until April30, 2016. 

(a) Your name and mailing address and, if you wish, other contact information 

such as a fax number, telephone number, or e-mail address. 

Erin B. Marston 

4109 Tazlina Avenue 
Mr. Kerry B. Long & U.S. Department of Transportation 

Page 2 of4 

November 7, 2015 

Anchorage, Alaska 99517 

(907) 248-4954 

(907) 242-9901 

marston@alaska.net 

(b) The specific section or sections of 14 CFR from which you seek an exemption. 

14 CFR § 61.113(a) and 14 CFR § 119.21(a)(l). 

(c) The extent ofreliefyou seek, and the reason you seek the relief. 

We seek the same terms and conditions as stated in Exemption No. 9810, excepting that 

we request the expiration date be extended to April 30, 2018. The reasons are also the same as 

set out in our November 6, 2008 and January 7, 2009 petition, and at pages 1-5 of the FAA's 

Exemption No. 9810. An extension is appropriate as the Iditarod Air Force has continued to 

operate in compliance with the exemption and has established a history of safe operations and 

excellent cooperation with the FAA. 

(d) The reasons why granting your request would be in the public interest; that 

is, how it would benefit the public as a whole. 

The reasons why granting the extension would be in the public's interest are the same as 

stated by the FAA at pages 4-5 of its Exemption No. 9810. We agree with the FAA's analysis, 

and nothing has changed factually that would in turn alter that analysis. Rather than repeat that 

analysis, a copy of Exemption No. 9810 is attached hereto. 

(e) The reasons why granting the exemption would not adversely affect safety, or 

how the exemption would provide a level of safety at least equal to that provided by the 

rule from which you seek the exemption. 

Here too, the IAF continues to agree with the analysis set forth by the FAA, at pages 4-5 

of Exemption No. 9810, regarding the IAF's operations being at least as safe (and in the IAF's 

mind, far safer) than operations would be without the exemption. Nothing has changed factually 

in this respect, either, that would alter that analysis. In fact, the last seven years of history has 

demonstrated the overall safe operations that have been accomplished under the IAF' s policies 

and procedures in conjunction with the FAA guidance. 

(f) A summary we can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek. 
Mr. Kerry B. Long & U.S. Department of Transportation 

Page 3 of4 

November 7, 2015 

"A two year extension of Exemption No. 9810 is sought by the lditarod Trail 

Committee and the 'Iditarod Air Force' as to 14 CFR 61.113(a) and 14 CFR 119.21(a)(1), for the 

Iditarod Air Force to continue flying support under 14 CFR Part 91 for the 1,100 mile Iditarod 

dog race in Alaska. Exemptions have been granted for the 2008, 2009, 2010, 2011, 2012, 2013, 

2014 and 2015 races. The exemption would permit the volunteer pilots to continue accepting 

gas, oil, insurance, food and minimal housing during the race, including the pre- and post-race 

staging efforts." 

(g) Any additional information, views or arguments available to support your 

request. 

The prior petition and Exemption set forth the information, views, and arguments in 

support of the Exemption. The seven year history of compliance by the IAF with the conditions 

and terms of the Exemption, including the February 28, 2010 deadline to submit IAF operational 

control procedures, the October 30, 2010 deadline to submit a flight training program, the 

October 30, 2011 deadline for submittal of a letter of compliance and the October 30, 2011 

deadline for a general operations manual, all reflect positively on the IAF's ability to operate 

professionally and safely. The IAF has an excellent working relationship with its principle 

operations inspectors, as well as the rest of the regional FAA. Granting a two year extension to 

the exemption will allow the IAF to continue its safe operations, with the oversight of its 

principle operations inspector. 

The Iditarod, the "Last Great Race" is a professionally operated long distance sled dog 

race that attracts dog teams from around the world. Run through the vast expanses of Alaska, the 

logistics of the race require air support, support that the IAF provides. Costs associated with 

operation of the IAF, including fuel and insurance are one of the major expenses of the race. In 

order to budget for these costs, and to insure that air support will be available, the IAF and the 

Iditarod Trail Committee needs the stability of an extension of at least two years that will allow 

the race to make long term plans and budgeting decisions relating to air support. This stability is 

crucial to the survival of the race. 

(h) If you want to exercise the privileges of your exemption outside the United 

States, the reason why you need to do so. 

No, the IAF does not wish to exercise the privileges of the exemption outside the U.S. 

Thank you. I welcome your calls, as well as those from anyone else at the FAA. 

Very truly yours, 

8;._6.H.~ Erin B. Marston 
Mr. Kerry B. Long & U.S. Department of Transportation 

Page 4 of4 

November 7, 2015 

Enclosure 

cc: Mr. Clint Wease (Alaska Region, Flight Standards Division Manager) (w/encl.) 

Mr. Ken A. Thomas (Anchorage FSDO Manager) (w/encl.) 

Mr. Howard Martin (FAA Regional Counsel) (w/encl.) 

Mr. Stan Hooley (Executive Director, lditarod Trail Committee) (w/encl.) 

Mr. Bert Hanson (Chief Pilot, lditarod Air Force) (w/encl.)