Alaskans serving Alaska and the world since 1979.

2700 S. Cushman Street

Fairbanks, AK 99701

Phone: (907) 452-6631

Fax: (907) 451-8632

taiga@taigaventures.com

www.taigaventures.com

5/20/2014

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:

We are 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 

our unique Alaskan 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.
Alaskans serving Alaska and the world since 1979.

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 doing business in bush and rural Alaska. As a 35-year 

logistics services company providing among other projects, support to FEMA disaster 

relief camps in remote locations, we routinely use Everts’ DC-6s and their other unique 

aircraft to provide safe transport to remote locations no one else can provide. 

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.

Sincerely,

Bruce Bridwell

General Manager 

Taiga Ventures, Inc

admin@taigaventures.com

Ron Norman

Operations Manager

Taiga Ventures, Inc.

contracting@taigaventures.com