eve 

5/20/2014 

Docket Management Facility 

U.S. Department of Transportation 

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: 

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We are writing in support of the Petition for Exemption, Docket Number F AA-2014-0 107, 

wherein the Petitioner, Everts .Mr, seeks relief from 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 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 of the aircraft they operate, 

including the DCoo6 and C-46. Thus, all training must be conducted in the aitplan.es, in flight. It 

is n~teworthy tbat Everts Air does not seek relief from the requirement that all p.ilots 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 

trainJng 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 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 of living 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 with the 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 of safety. In the interest of air safety and viable logistics options for ['U1'$] communities, we are in favor of 

supporting the Petition for Exemption, Docket Number F AA-2014-0107. 

Sincerely~ -

·-· ··--··· ··-··- ...... - .. 

Charlene Henry. llrt Chief 
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