May. 21. 2014 2:33PM 

Sampson Steel Company Inc. 

Established in 1989 

Alaska's 1st AISC Certified Fabrication Facility 

5/20/2014 

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: 

No. 3005 P. 112 

• ..C:::"' 

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We are writing in support of the Petition for Exemption, Docket Number FAA-2014-

0107, wherein the Petitioner, Everts Air, seeks relieffrom 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 provides essential services in a 

unique environment. There are no 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 Everts Air does not seek relief from the 

requirement that all pilots must possess airline transport licenses. 

This mandate will not result in an increased level of 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 command 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 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 

course in the airplane is nearly ten times that, and represents a cost that Everts Air will 

have to pass along to us as the customer. 

We are deeply concemed that this cost will drive the petitioner to withdraw from several 

markets, leaving non-certificated and/or fewer safe operators. Their altemative is to 

Sampson Steel Company Inc 

1848 N. Post Road, Anchorage Alaska 99501 

Phone (907) .561-5626 Fax (907) 561-5625 

Email; Bmorgan@s_ampsonsteeloo.com or 

on the web at Sampsonsteelco.com 
May. 21. 2014 2:33PM No. 3005 P. 2/2 

increase the cost, making arctic operations impractical for industry, including aviation, 

thus increasing the cost of living in rural communities. 

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 rura,l communities, we are in 

favor of supporting the Petition for Exemption, Docket Number FAA-2014-0107. 

Sampson Steel Company Inc 

1848 N. Post Road, Anchorage Alaska 99501 

Phone (907) 561-5626 Fax (907) 561-5625 

Email; Bmorgan@sampsonsteelco.com or 

on the web at Sampsonsteelco.com 

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