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.taigaventur es.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 Pet ition 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 recentl y enacted regulation requires co
- pilots (second in comm and) hired or promoted to that position after 31 July 2013 to be certified as captains (pilot in command) with respect to the aircraft ty pe rating. This regulation will also require all pilots serving as second in command to be certified in this manner aft er 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 saf et y, rather a lower standard of safet y as the more critical and technicall y demanding captain’s maneuvers will now be required of the second in command candidate. Historically , training in aircraft rather than simulators has proven dangerous, particularl y in training lesser experienced pilots in emergency

and abnormal procedures and maneuvers. This element represents an increased risk. When this rule was promulgated b y Congress, there was an assumption made that all airline training was accomplished in a s imulator. The simulator represents a safe and relativel y 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 ype 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
- ye ar logistics services company providing among other projec ts, support to FEMA disaster relief camps in remote locations, we routinel y 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 outl ying 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 safe ty . 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. Sincerel y,
Bruce Bridwell General Manager Taiga Ventures, Inc admin@taigaventures.com
Ron Norman Operations Manager Taiga Ventures, Inc. contracting@taigaventures.com