From: Rebekah Gormish Fax: (866) 669-9623 To: Fax: +1 (202) 493-2251 Page 1 of 3 0512212014 B:S2 

FAX 1i- t· l • } Date: 1 05/22/2014 

I Pages including cover sheet: J3 

To: From: Rebekah Gormish 

NYAC Mining Co. 

1634 W. 13th Ave. 

Anchorage 

AK 99501 

Phone Phone (866) 669-9623 * 101 

Fax Number +1 (202) 493-2251 Fax Number (866) 669-9623 

NOTE: 

Please see the attached petition on behalf of Everts Air. Nyac is a 

small mining company in Alaska which employs 50 people from across the 

United States. Living and doing business in Alaska presents many 

challenges since many villages and job sites are not accessible by 

road. Tatonduk Outfitters d/b/a Everts Air Fuel and Everts Air Cargo 

is essential, and anything that increases their operational costs 

would impact a great number of people and businesses across the state. 

We urge you to take this matter under serious consideration and grant 

the exemption for Everts Air. 

Send and receive faxes wi~h RingCentral, www.ringcent~al.com 
From: Rebekah Gormish Fax: (866) 669-9623 

Docket Management Facility 

U.S. Department of Transportation 

1200 New Jersey Avenue SE 

West Building Ground Floor 

Room W12-140 

Washington, D.C. 20590 

Reference: No. fM-2014-0107 

To Whom It May Concern: 

To: Fax: +1 (202) 493-2251 Page 2 of 3 0512212014 8:52 

5/20/2014 

We are writing lh support of the Petition for Exemption, Docket Number FAA-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 wm 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 devrces for several of the aircraft they operate, including 

the DC-6 and C-46. Thus, aH 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 alrHne 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 wm now be required of the second in command 

candidate. Historica.lly, training in aircraft rather than simulators has proven dangerous1 particularly in 

training lesser experienced pilots in emergency and abnormal procedures and maneuvers. This element 

represents an increased risk. 
From: Rebekah Gormish Fax: (866) 669-9623 To: Fax: +1 (202) 493-2251 Page 3 of 3 0512212014 8:52 

When this rule y.~as promulgated by Congress, there was an assumption made that all airline training 

was accomplrs~ed in a simulator. The simulator represents a safe and relatively low cost training 

environment. The cost of training a pilot in a ftight simulator rs on the order of $14,000;00. The cost of 

training the sa~e pilot for the type rating course in the airplane is nearly ten times that, and represents 

a cost that Everts Afr will have to pass along to us as the customer. 

We are deeply ¢oncerned that this cost will drive the petitioner to withdraw from several markets, 

leaving non-certificated 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 Hving 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 petitioner1s position that training to the level that was in place 

before the enaqtment of 14 CFR 121.436 represents continued service at the hfghest standard of safety. 

In the interest Qf air safety and viable logistics options for rural communities, we are fn favor of 

supporting the Petition for Exemption1 Docket Number FAA-2014-0107. . . 

Charles Trowbri~ge 

General Manag$r 

Nyac Mining Company 

1634 W. 13th Av~nue 

Anchorage AK 99501