### May. 

### 22. 2014 4:39PM 

### No. 6 753 P. 1/2 I



# Fairbanks, Alaska 907-479-8599

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: 

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I am writing in support ofthe Petition for**Exemption~** DocketNumber**FAA-2014~0107,** wherein the Petitioner. 

### Everts Air, seeks relieffrom certain requirements ofinter 

### alia §121.436 ofTitle14, Code ofFederal Regulations. The recently enacted regulation requires co-pilots (second incommand) hired or promoted to

### tha~ position after 3

### i 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 Alaskan envirorunent. There are no simulator training devices for several ofthe aircraft they operate, includjng 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 

### seekrelieffrom the requirement that all pilots must possess airline 

### transport licenses. This mandate

# wm not result inanjncreased level ofsafety, rather a lower standard of safety 

### as the more 

### critical and technically demanding captain's**maneuve~s** 

### willnow be required ofthe second in command candidate. Historically, 

### training in 

### aircraft ratherthan simulators has proven dangerous, 

### particularly intraining lesser e:xperienced pilots 

### in emergency and abnormal procedures and maneuvers. This element represents an increased risk.


### David A. Doudna www.northernsledworks.com.1'

### May. 

### 22. 2014 4:40PM No. 

### 6753 P. 2/2 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 costtraining environment. The cost oftraining apilot in a flight simulator is on the order of$14,000.00. The cost oftraining the same pilot for the type rating
·coUtse in the airplane 

### is nearly ten times 

### that, 

### and represents a cost that Everts Air will have to pass along to 

### all oftheir customers. Since I rely heavily upon Everts Air Cargo to deliver my sleds to not only my Bush Dealers but also individuals in 

### rural Alaska, I am concerned that this additional cost will · drive the petitioner to withdraw from several markets that I do business in, or, as an alternative, be forced to pass this exorbitant cost increase on to 

### me, making arctic operations impractical for my business, thus fotcing 

### me out ofbusiness. 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'sposition that training to 

### the level that was inplace before the enactment of 

### 14 CFR 121.436 represents· continued service atthe highest standard ofsafety. In the interest of

### air safety and viable logistics options for rural communities in Alaska. I am infavor ofsupporting the Petition for Exemption, DocketNumber 

### FAA-2014-0107.

# P~-L- David A. Doudna, President Northem Sled**Works~** Inc. P.O. Box 61171 Fairbanks. AK. 99706

David A. Doudna www.northemsledworks.com