907-222-0348 11:51:12p.m. 05-22-2014 

COPPER RIVER SEAFOODS· 

Main Admlnlstratlva Office 

1118 East 5"i Avenue ·Anchorage, AK 99501 

Phone: (907)522·7806 • (888)622-1197 ·Fax: (907)274-0348 

www.CopperRiverSeafoods.com 

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: 

5/22/2014. 

We are writing in support of the Petition for Exemption, Docket Number FAA-2014-

J> 

0 107, wherein the Petitioner, Everts Air, seeks relief from certain requirements of inter 

alia §121.436 ofTitle 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.Ol January2016. 

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 t)ipe 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. 

ANCHORAGE PLANT 1400 East 1" Avenue ·Am:horuge,AK 99501 

Phone: (907)522-7006 • (880)622·1197 

Fu: (907)222.0348 

CORDOVA PLANT 

P.O. Box 158/300 cannery Row• Cordovu, AK 99574 

Pltone: (907)424-3721 • (8881622-1197 

Fax: (907)424·7435 

1/2 
907-222-0348 11:51:29 p.m. 05-22-2014 

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 opemtions impmctical 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 F AA-20 14~0 107. 

ANCHORAGE PLANT 

1400 East1'1 Avenue· Anchorage, AK 99501 

Phone: (907)522-7806 • (888)622·1197 

Fax: (907J222.0348 · · 

Sincerely, 

Bradley Jenner 

Director- Logistics 

CORDOVA PLANT 

P.O. Box 158/300 cannery Row· Cortlova,AK 99574 · 

Phone: (907)424..;1721 · (888)62%-1197 

Fax: (907)424-7435 

212