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 Exempt ion, 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 Regul ations. T he recently enacted regulation requires co - pilots (second in command) hire d 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 sever al of the aircraft they operate, including the DC - 6 and C -46. Thus, a ll training must be conducted in the airplanes, in flight. It is noteworth y that Everts Air does not seek relief from the requirement that all pilots must possess airline transport licen ses. This mandate will not result in a n increase d 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 ca ndidate. Historically, training in aircr aft 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 C ongress, there was an assu mption 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 m arket s, 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 com munities. 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 continu ed service at the highest standard of safety. I n the interest of air safety and viable logistics options for rural communities , we are in favor of supporting the Petition for Exempti on, 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 Exempti on, Docket Number FAA- 2014 - 0107. Sincerely, Kevin Greenfield Vice President Taiga Mining Company, 907 349 -4644