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

COPPER RIVER SEAFOODS· Main Admlnlstratlva Office 1118 East5"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 ofTransportation 1200 New Jersey Avenue SE West Building Ground Floor Room W12-140 Washington, D.C. 20590

Reference: No. FAA-2014-0107

To Whom 

### ItMay Concern: 5/22/2014.

We are writing in support ofthe Petition for Exemption, DocketNumberFAA-2014- 

### J>

0107, wherein the Petitioner, Everts Air, seeks relieffrom certain requirements ofinter 

### alia §121.436 ofTitle 14, Code ofFederal Regulations. The recently enacted regulation requires co-pilots (second in command) hired orpromoted to that position after 31 July

· 2013 to be certified as captains (pilot in command) with respectto 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 simulatortraining devices for several ofthe aircraft theyoperate, 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 relieffrom the requirement that all pilots must possess airline transport licenses. This mandate will not result in an increased level ofsafety, rather a lower standard of safety as the more critical and technically demanding captain's maneuvers will now be required ofthe second in command candidate. Historically, training in aircraft rather than· simulators has proven dangerous, particularly 

### in training lesserexperienced pilots in emergency and abnormal procedures and maneuvers. This element represents an increased risk.

·Whenthis rule was promulgated by Congress, there was an assumption made that all airline training was accomplished in a simulator. The simulatorrepresents a safe and relatively low costtraining environment. The cost oftraining a pilot in a flight simulator is on the order of$14,000.00. The cost oftraining the same pilot for the t)ipe rating
course in theairplane is nearly ten times that, and represents a costthat Everts Air will have to pass along to us as the customer.

ANCHORAGE PLANT 1400 East 1" Avenue ·Am:horuge,AK99501

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 1/2907-222-0348 11:51:29 p.m. 05-22-2014



### We are deeply concerned that this cost will drive the petitionerto withdraw from several markets, leaving**non~certificated** 

### and/orfewer safe operators. Their alternative is to increase the cost, making arctic opemtions impmctical for industry, including aviation, thus increasing the cost ofliving in-rural communities.

The §

### 121 air carrierhas 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 atthe highest standard ofsafety. · In the interest ofair safety and viable logistics options for rural communities, we are in favor ofsupporting the Petition for Exemption, DocketNumber F AA-20**14~0**

### 107.

ANCHORAGE PLANT 1400 East1'1Avenue·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,AK99574 · Phone: (907)424..;1721 · (888)62%-1197 Fax: (907)424-7435 212