0512212014 16:16 

Docket Management Fatility 

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-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 . 

Petitioner seeks relief frorn 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 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 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 

the petitioner does not seek relief from the requirement that all pilots must possess airline transport 

licenses. 

This mandate will not represent an Increase· In safety, rather a _lower standard of safety as the more 

critical and technically demanding captain's maneuvers will now be required of the second in comr:nand 

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 assumptio~ 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 course in the airplane is nearly ten times that, and represents 

a cost that the petitioner will 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/or fewer 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 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 5afety and viable logisti~s options for rural communities, 1 am In favor of supporting 

the Petition for Exemption, Docket NurnbetFAA-2014-0107. 

Procurement Lead 

PRllogistics, Inc. 

421 W. 1st Avenue, Suite 250 

Anchorage, AK 99501