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

# FAX i- 

## t·

# l
1 • } 

### Date: 1

### 05/22/2014 

# IPages 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 ofTransportation 1200 New JerseyAvenue 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 ofthe Petition for Exemption, Docket Number FAA-2014-0107, wherein the Petitioner, EvertsAir, seeks relief from certain requirementsof

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

### hired or promotedtothat position after 

### 31 July 2013 to be certified as captains (pilot in command) with respect totheaircraft 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 aunique environment. There are no simulatortraining devrces for 

### several of

### the aircraftthey operate, including 

### the DC-6 and C-46. Thus, aH training must be conducted in the airplanes, in flight. It is noteworthythat Everts Air does not seek relief from the requirementthat all pilots must possess alrHne transport licenses. This 

### mandate 

### will not 

### result in an 

### increased level 

### of

### safety, rather a lower

### standard 

### ofsafety 

### as the 

### more critical and technically demanding 

### captain's maneuvers

## wm now be required ofthe 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 thatall airline training was**accomplrs~ed** in asimulator. The simulator represents asafe and relatively low cost training environment. The cost oftraining 

### a pilot in 

### aftight simulator rs 

### on the order of$14,000;00. The cost of trainingthe**sa~e** pilotfor the type rating course in 

### the airplane is nearlyten times 

### that, and represents acost that Everts Afr will have topass along to us as the customer. We are deeply ¢oncerned thatthis cost will drive the petitionertowithdraw 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 petitioner1sposition that trainingto the level thatwas in place before the enaqtment of14 CFR 121.436 represents continued service 

### atthe hfghest standard ofsafety. In the interest

### Qfairsafety and viable logistics options for rural communities, we are fn favor of supporting the Petition for Exemption 1 Docket Number FAA-2014-0107.

. .

Charles**Trowbri~ge** General Manag$r Nyac Mining Company 1634 W. 13th**Av~nue** Anchorage AK 99501