### 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 ofTransportation 

### 1200 NewJersey 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:::"'

0

We are writing in support ofthe Petition for Exemption, DocketNumber

### FAA-2014- 0107, wherein the Petitioner, Everts Air, seeks relieffrom certain requirements of

### inter alia §121.436 ofTitle 

### 14, Code ofFederal Regulations. The recently enacted regulation requires co-pilots (second in command) hired orpromotedto that position after 

### 31 July 

### 2013 to be certified as captains (pilot in command) withrespectto the aircrafttyperating. This regulationwill 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 

### Airprovides essential services in a unique environment. There are no simulator training devices for several ofthe aircraft they operate, including the DC-6 and C-46. Thus, 

### all training mustbe conducted inthe airplanes, in flight. 

### Itis noteworthy that Everts 

### Air does not seek relieffrom the requirement that all pilots must possess airline transport licenses. This mandate will notresult 

### in an increased level ofsafety, rather a lower standard of safety as the more critical and technically demanding captain's maneuvers will nowbe required ofthe second in command candidate. Historically, training in aircraft rather than simulators has proven dangerous, particularly in training lesser experienced pilots in emergency and abnormalprocedures and maneuvers. This elementrepresents an increased 

### risk.
When this rule was promulgated by Congress, there was an assumption made that all airline trainingwas accomplished in a simulator. The simulatorrepresents a safe and relatively lowcosttraining environment. The cost oftraining a pilot 

### in a flight simulator is on the order of

### $14,000.00. The cost oftraining the same pilot for the type rating
course 

### in the airplane is nearlyten times that, and represents a cost thatEverts Air will have to pass along to us as the customer. We are deeply concemedthat this cost

### will drive the petitionerto 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 ofliving 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 inplace before the enactment of 14 CFR 121.436 represents continued service atthe highest standard ofsafety. In the interest ofair safety and viable logistics options for rura,l communities, we are in favor ofsupporting the Petition forExemption, 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.comor on the web at Sampsonsteelco.com
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