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

Zill4 :;AY 21 A G: 03 

From: Keeter Brown 

P.O. Box 111165 

Anchorage, Alaska 99511 

(907)344-6431 

Docket Management Facility May 20, 2014 

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: 

We are writing in support of the Petition for Exemption, Docket Number FM-2014-0107, wherein the Petitioner, Everts 

Air, 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 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 concerned that this cost will drive the petitioner to withdraw from several markets, leaving noncertificated and/or fewer safe operators. Their alternative 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 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. 
To: Pege :2 of.:? :2014-05-:20 :21 :07:4:2 (GMT) From: Keeter Brown 

In the interest of air safety and viable logistics options for rural communities, we are in favor of supporting the Petition 

for Exemption, Docket Number FAA-2014-0107. 

Sincerely, 

. Mark Terry General Manager 

Discovery Drilling Inc. 

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