05/20/2014 18:49 FAX 

Docket Management Facility 

U.S. Department of Transportation 

1200 New Jersey Avenue SE 

West Building Ground Floor 

Room Wl2~140 

Washington, D.C. 20590 

Reference: No. FAA-2014-Q107 

To Whom It May Concern: 

141001 

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5/20/2014 

We are writing in support of the Petition for Exemption, Docket Number FAA-2014-0107, wherein the 

Petitioner, Everts Air, seeks relleffrom certain requirements of Inter olio §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 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 pilc;:~ts 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 

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05/20/2014 18:49 FAX 

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training the same pilot for the type rating course in the airplane Is nearly te~ times that, and rep res i' ts 

a cost that Everts Air will have to pass along to us as the customer. 

,; We are deeply concerned that this 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 of living 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 that was in place ~ 

before the enactment of 14 CFill21.436 represents continued service at the highest standard of saf 

In the interest of air 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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