Kevin Greenfield

3300 North Shore Drive

Anchorage, AK 99502

5/21/2014

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. FAA-2014-0107

To Whom It May Concern:

I am writing in 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 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 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 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. 

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.

We are a remote Placer mining company. Almost everything we ship is by air in DC6s. This will have a 

major impact on our cost in almost every part of our business. Again we strongly support the Petition 

for Exemption, Docket Number FAA-2014-0107.

Sincerely,

Kevin Greenfield

Vice President

Taiga Mining Company,

907 349-4644