### 05/20/2014 18:49 FAX

Docket Management 

### Facility U.S. Department ofTransportation 1200 NewJersey Avenue 

### SE West Building Ground Floor Room**Wl2~140** Washington, 

### D.C. 20590 Reference: No. FAA-2014-Q107 To Whom It MayConcern: 

### 141001

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5/20/2014

We are writing in support ofthe Petition for Exemption, Docket Number FAA-2014-0107, wherein the Petitioner, Everts Air, seeks relleffrom certain requirements of

### Interolio §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 aircrafttype 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 simulatortrainingdevicesforseveral ofthe aircraftthey operate, Including the DC-6 and C-46. Thus, all training must be conducted in the airplanes, in flight. It is noteworthythat Everts Airdoes not seek relieffrom the requirement that all**pilc;:~ts** must possess airlinetransport licenses. This mandate will not result In an Increased level ofsafety, rather a lower standard ofsafety as the more critical and technically demanding captain's maneuvers will now be required ofthe second in command candidate. HistoriCally, training inaircraft rather than simulators has proven dangerous, particularly in training lesser experienced pilots in emergencyand 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 asafe and relatively low cost training environment. The cost oftraining a pilot 

### in a flight simulator Is on the order of**$14,000~00.** The cost of



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### 05/20/2014 18:49 FAX

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### !\ . 002

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### training the same pilotforthe type rating course in the airplane Is nearly

## te~ times that, and repres 

## i' ts acost that Everts Air will have to pass along 

## to us as the customer. ,; 

### We are deeply concerned thatthis cost 

### wiU drive the petitioner to withdra"Y from several markets,

## -~ leaving non-certificated and/or fewer safe operators. Their alternative is to Increase the cost, makl arctic operations impractical for industry, including aviation, thus increasing the cost ofliving in rura:· communities. The §121 air carrier has proven to be the safest supply chain for business, industry and residential n in outlying areas. We agree with the petitioner's position that training to the level thatwas in place

## ~ before the enactment of 14 

### CFill21.436 represents continued service at the highest standard ofsaf In the interest ofair safety a'nd viable logistics options for rural communities, we are in favor of supporting the Petition for Exemption, Docket Number FAA-2014-0107. Sincerely,

David Delong, Director Venetie/Arctic Village Housing Organization POB83566 Fairbanks, Ak 99708

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