### 0512212014 16:16

Docket Management Fatility U.S. Department ofTransportation 1200 NewJersey Avenue SE West Building Ground Floor Room W12-140 Washington, D.C. 20590 Reference: No. ·FAA-2014-Dt07
To Whom It May Concern: 

### P.0011002



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5/22/2014·

I am writing in support ofthe Petition for Exemption, Dock.et Number FAA-2014-0107, wherein the

. Petitionerseeks relieffrorn certain requirements of

### Interalia §121.436 ofTitle 14, Code ofFederal Regulations. The recently enacted regulation requires·co-pilots (second in command) hired orpromoted 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 cargo provides essential services in a unique environment. There are ho 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 the petitioner does not seek relieffrom the requirement that all pilots must possess airline transport licenses. This mandate will not represent an Increase· In safety, rather a_lower standard ofsafety as the more critical 

### andtechnically demanding captain's maneuvers will now be required ofthe second in comr:nand candidate. Historically, training In aircraft ratherthan 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**assumptio~** made that all airline training was accomplished In asimulator. The simulator represents 

### asafe and relatively low cost training environment. The cost oftraining a pilot in aflight simulator is on the order of$14,000.00. The cost of training the same pilot forthe type rating course in the airplane is nearly ten times that, and represents acost that the petitionerwill have to pass along to us as the customer.

### 05122/2014 16:17

We are deeply concerned that this cost will drive the petitioner to withdraw from several markets, leaving non-certificated and/orfewer safe operators. Their alternative Is to Increase the cost, making · arctic operations impractical for Industry and subsistence unaffordable for native communities. 

### P.002/002

The §121 aircarrier 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 14CFR 121.436 represents continued service at the highest standard ofsafety. 

### In the interest ofair

### 5afety and viable**logisti~s** options for rural communities, 

### 1 am In favor ofsupporting the Petition for Exemption, Docket NurnbetFAA-2014-0107.

Procurement Lead PRllogistics, Inc. 421 W. 1stAvenue, Suite 250 Anchorage, AK 99501