May. 22. 2014 4:39PM No. 6 753 P. 1/2 I 

Fairbanks, Alaska 

907-479-8599 

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: 

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I am 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 ofTitle14, Code of Federal Regulations. The recently enacted regulation 

requires co-pilots (second in command) 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 of the 

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 seek relief from the 

requirement that all pilots must possess airline transport licenses. 

This mandate wm not result in an jncreased level of safety, rather a lower standard of 

safety as the more critical and technically demanding captain's maneuve~s will now be 

required of the second in command candidate. Historically, training in aircraft rather than 

simulators has proven dangerous, particularly in training 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 cost training environment. The cost of training a pilot in a flight simulator 

is on the order of $14,000.00. The cost of training 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 of their 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 of business. 

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 in Alaska. I 

am in favor of supporting the Petition for Exemption, Docket Number 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