# eve

5/20/2014 

### Docket Management Facility U.S. Department ofTransportation 1200 New Jersey Avenue SE 

### West Building Ground Floor Room Wl2-140 Washington, 

### D.C. 20590 Reference: 

### No. FAA-2014-0107 To Whom It May Concern: J> ..f? 0 ZJ.)

We are writing 

### in support ofthe Petition for Exemption, Docket Number FAA-2014-0 107, wherein 

### the Petitioner, 

### Everts .Mr, seeks relief

### from certain requirements of

### inter alia §

### 121.436 ofTitle 14, Code ofFederal Regulations. The recently enacted regulation requires co-pilots (second in command) 

### hired or promoted to that position after 31. July 

### 201.3 to be certified as 

### captains (pilot in command) with 

### respect to 

### the aircraft type 

### rating. Th.is regulation 

### will also require all pilots serving as second in command to be 

### certi.fied in

### this mann.er 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 ofthe aircraft they operate, 

### including the DCoo6 and C-46. Thus, 

### all training 

### must be conducted 

### inthe aitplan.es, in flight. 

### It is**n~teworthy** tbatEverts Air does not seek relieffrom the requirement that all p.ilots must possess airline transport licenses. This mandate will not result in an increased level ofsafety, rather a lower 

### standard ofsafety as the more critical and technically demanding captain's maneuvers will now be required ofthe second in command candidate. Historically, training in aircraft rather than simulators has proven dangerous, particularly in training lesser experiencedpilots 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 

### trainJng 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 nearly 

## ten times that, and represents a cost that Everts Air will have to pass along to us as the customer. 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 altemati.ve is to increase the cost, making arctic operations impractical for industry, including aviation, thus increasing the cost ofliving in 

### rural communities.



# .... '.,The 

### §

### 121 

### air carrier bas proven to be the safest 

### supply 

### chain for business, industry and residential needs jn outlying areas. We 

### agree withthe 

### petitioner's position tbat training 

### to the 

### level that 

### was in 

### place before the enactment of 14 CFR 121.436 represents continued service 

### at the**hi~est** standard 

### ofsafety. 

### In the interest ofair 

### safety and viable logistics options for ['U1'$] 

### communities, we 

### are in

### favor of supporting the 

### Petition for 

### Exemption, DocketNumber F AA-2014-0107.

### Sincerely~ -

·-· ··--··· ··-··- ......

### - ..



### Charlene Henry. 

### llrt Chief

# .. .. ·.· ' ,\ ! :. . ·, ' ' 'I I ',: ,• ",', '•

' I :•,' '•: ... " . ' ..

' ' ' ' -**~'** 

## . f:

·- .t.


# ... .'.



## .. . 

## .'

. . . . .. .

. •'

·, .

. · .. 

# . . ' .. ,. '•, I o e**·~-** ' . - .• ' •**-,II.:.~-** .

. 

# ..

. . 

## . 

# ··.·..**Docl~+ ~jtm~** **F4~t(,tq ~·**  

# __**S_ber,~.·L;.BtoJa.rviS,** 

# ,·· : ....

- . . 

## . 

# .·.·'- I!J'*k Wtr±s, Aw:

# CAr~p 

# · .. ··'-•· Jq,e--.: 

# !dB 3**-~~5(** 

# ._.

·. 

## . . .. . ... 

## . . . . . 

### . I .



## . . 

### . i



## . o' 'I 

### . . ' . .

## ~~:: 

# ...

,

## .

.. . . . . 

### . . .

. 

# .,.·

'.

'' ' . !• 'I