To: Pege 1 ot 2 2014-05-20 21:07:42 (GMT)



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## 03 From: Keeter Brown

P.O. Box 111165 Anchorage, Alaska 99511 (907)344-6431

Docket Management Facility May20, 2014 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 MayConcern: We are writing in support ofthe Petition for Exemption, Docket Number FM-2014-0107, wherein the Petitioner, Everts Air, seeks relieffrom certain requirements of

### interalia §121.436 ofTitle 14, Code of Federal Regulations. The recently enacted regulation requires co-pilots (second in command) hired or promoted to that position after31 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 after01 January 2016. The petitioner, Tatonduk Outfitters, Ltd., d/b/a Everts Air provides essential services in a unique environment. There are no simulatortraining devices for several ofthe aircraftthey operate, includingthe DC-6 and C-46. Thus, all training must be conducted in the airplanes, in flight. It is noteworthythat Everts Air does notseek relieffrom the requirement that all pilots must possess airline transport licenses. This mandate will not result in an increased level of safety, rathera lowerstandard ofsafety as the more critical and technically demanding captain's maneuvers will now be required ofthe second in command candidate. Historically, training in aircraft ratherthan 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 oftraining a pilot in aflight simulator is on the orderof $14,000.00. The cost oftraining the same pilot forthe type rating course in the airplane is nearlyten times that, and represents a cost that Everts Air will have to pass alongto us as the customer. We are deeply concerned that this cost will drive the petitionerto withdrawfrom several markets, leaving noncertificated and/orfewer safe operators. Their alternative is to increase the cost, making arctic operations impractical for industry, including aviation, thus increasing the cost ofliving in rural communities. The §121 aircarrier has proven to be the safest supplychain for business, industryand residential needs in outlying areas. We agree with the petitioner's position thattraining to the level that was in place before the enactment of 14 CFR 121.436 represents continued service atthe highest standard ofsafety.To: Pege :2 of.:? :2014-05-:20 :21 :07:4:2 (GMT) From: Keeter Brown

In the interest ofairsafety and viable logistics optionsfor rural communities, we are in favor ofsupporting the Petition for Exemption, Docket Number FAA-2014-0107. Sincerely,

.Mark Terry General Manager Discovery Drilling Inc.**r):'·Tt:rnp·.'?"?ll8'.~6.l~·.l.dnc**