April 30, 2021

Docket Management Facility US Department of Transportation 1200 New Jersey Avenue, SE West Building Ground Floor Room W12‐40 Washington, DC 20590‐001

ELECTRONIC FILING

Subject: Petition of Exemption for Corvus Inc. (dba Ravn )

Pursuant to 14 CFR Part 11, Corvus Airlines Inc. (dba ), operating certificate 7C7A855N, hereby respectfully submits this petition for an exemption from a portion of 14 CFR part 121, specifically §121.407(a)(1)(ii). Corvus operates 10 De Havilland/Bombardier Dash-8 series 100 (DHC-8-100) aircraft in scheduled passenger operations. Currently, there are no DHC-8-100 simulators available in the United States that are Directive 2 qualified.

Corvus is petitioning to utilize a Dash-8 series 200 (DHC-8-200) simulator to conduct its flight training and checking, which is currently not allowed under the existing rule. Without the relief requested in this petition, risks associated with training and checking in an aircraft will be significantly increased and will have a detrimental effect on the availability of aircraft to the public in the State of Alaska.

With respect to the use of the DHC-8-200 simulator, it is located in Seattle, Washington and operated by Flight Safety International, specifically simulator FAA ID #1242, and is Level D, fully Directive 2 qualified.

Corvus Airlines prays that this petition be granted on an expedited basis. The following information is presented for your consideration.

I. Name and Mailing Address:

Evan Veal, Director of Operations, Corvus Airlines dba Ravn Alaska, 4700 Old International Rd. Anchorage, AK 99502

II. Specific Section of the Regulation from which Relief is Sought:

Relief is sought from §121.407(a)(1)(ii) hereinafter (§121.407). This paragraph requires that a simulator be specific for the variation within a type of aircraft. While the type certificate for all variants is DHC-8, the variants can have differences that may require flight training in another simulator or an aircraft.

4700 Old International Airport Road Anchorage, AK, 99502 www.ravnalaska.com

III. The Extent of Relief Sought and Reasons for this Petition for Exemption:

An exemption is sought to allow Corvus Airlines to train and qualify pilots in the DHC-8-200 simulator and complete Level A differences training to complete their DHC-8-100 training. Specifically, allowing Corvus to utilize the DHC-8-200 simulator to conduct FAR 121 Appendix E training, FAR 121 Appendix F checking required by §121.441, checking in accordance with §121.439 (Recency of Experience), training in accordance with §121.423 (Extended Envelope Training), windshear and Ground Proximity Warning System (GPWS) training, and LOFT training in accordance with §121.409 and FAR 121 Appendix H.

Corvus has researched the availability of DHC 8-100 simulators that will meet the requirements of our FAR 121 training program. Currently there are only 2 FAA approved, fully Directive 2 qualified Dash-8- 100 series simulators available in North America, both located in Canada and operated by CAE. According to the Statement of Qualification (SOQ) provided by CAE, these simulators do not have specific airport visuals, including terrain, for the special Corvus operates to, such as Dutch Harbor and Kodiak.

Flight Safety International has developed specific and detailed visuals for Dutch Harbor and Kodiak, Alaska, giving Corvus Airlines a necessary and valuable training and qualification resource for these special airports. Due to the nature of the terrain and weather conditions at these airports, as well as the special approach qualifications, and considering Corvus is the sole 121 scheduled passenger operating to Dutch Harbor, it is in the interest of public safety to train and qualify flight crews in a simulator which allows for the unique circumstances of these challenging, but important destinations.

Dutch Harbor is a particularly unique airport for operators, even for the State of Alaska. The special Instrument Approach Procedure (IAP) Corvus is approved for requires certain visual terrain cues to be acquired to continue past the missed approach point and requires specific training and authorization. The training currently must be accomplished in the aircraft and does not include the abnormal or emergency procedures that would be available in the FlightSafety DHC-8-200 simulator.

A. Background:

1. §121.407 states in relevant part:

“(a) Each FSTD used to satisfy a training requirement of this part in an approved training program, must meet all of the following requirements: (1) Be specifically approved by the Administrator for -- … (ii) The type airplane and, if applicable, the particular variation within type, for which the training or check is being conducted; and…” (Emphasis added)

2. A proficiency check, required by §121.441, includes takeoffs and landings, instrument departures, arrivals, approaches to minimums with realistic weather conditions, stalls, steep turns, engine failures, taxi conditions in very low visibility conditions and numerous other system failures.

4700 Old International Airport Road Anchorage, AK, 99502 www.ravnalaska.com

3. Extended Envelope Training, required by §121.423, can only be accomplished in a Directive 2 qualified FFS, and requires recovery from full stall and stick pusher activation, recovery from bounced landing, manually controlled slow flight, manually controlled loss of reliable airspeed, and upset recovery maneuvers.

4. Windshear training can only be accomplished in an approved simulator. This training provides FAA approved scenarios that are modeled using actual windshear data encountered in windshear related accidents.

5. Use of a simulator qualified under FAR 121 Appendix H allows an initial or transitioning pilot to facilitate his/her simulator training to line flying, after completing a type rating/proficiency check. This training is referred to as Line Oriented Flight Training (LOFT). A LOFT is conducted in a simulator and it must also provide an opportunity to demonstrate workload management and pilot monitoring skills.

B. The FAA Flight Standardization Board (FSB) Report for the Bombardier DHC-8-100, 200, 300, 400 Series, All Models, Revision 4, dated 11/23/2016, provides the following information regarding the Dash-8 aircraft training and checking:

1. The DHC-8 is assigned the same pilot “Type Rating” to all DHC-8 variations.

2. The Master Differences Requirements (MDR) classifies the DHC-8-100 to 200 series as Level A/A/A.

Training differences level A: “Level A training is that training between related aircraft that can adequately be addressed through self-instruction. Level A training represents a knowledge requirement that, once appropriate information is provided, understanding and compliance can be assumed.”

Checking differences level A: “Level A checking indicates that no check is required at the time of training. A pilot is responsible for knowledge of each related aircraft flown. Difference items should be included as an integral part of subsequent recurrent proficiency checks.”

Currency level A: “Level A currency is considered common to each related aircraft. Thus, assessment or tracking of currency for separate related aircraft is not necessary or applicable. Maintenance of currency in any one related aircraft or combination of related aircraft will suffice for any other related aircraft. (Emphasis added)

With the differences between the DHC-8-100 and DHC-8-200 all being Level A, a pilot could complete all training and checking in an DHC-8-200 simulator then complete self-instruction to be qualified to fly the DHC-8-100 aircraft.

Additionally, the differences between the DHC-8-100 aircraft and the FlightSafety DHC-8-200 simulator are very minimal, limited to the EFIS displays on the simulator.

4700 Old International Airport Road Anchorage, AK, 99502 www.ravnalaska.com

Corvus has discovered the DHC-8-100 simulators available are not sufficient to meet our training and checking requirements. Because the rule only allows a simulator to be approved for the type and series aircraft being operated (DHC-8-100) Corvus cannot use the DHC-8-200 simulator unless an exemption is obtained. This is because the DHC-8-100 and DHC-8-200 are a variation within a type. This appears to be an unintended consequence of the related aircraft rules by not at least allowing a deviation clause for cases where the differences between variations within a common type certificated aircraft are minimal.

IV. Public Interest/Benefit:

Unalaska (Dutch Harbor) Airport (PADU) and Kodiak Airport (PADQ) both have very challenging weather and terrain characteristics, qualifying them as Special Airports requiring special aircrew training and qualification. Simulator FAA ID # 1242 currently has detailed terrain visuals for PADU and PADQ, allowing training and qualifications to be accomplished in the simulator, including abnormal and emergency procedures, providing a much higher level of proficiency for flight crews. It would be in the public interest for Corvus flight crews to conduct training and checking in a simulator that replicates in detail the unique and challenging airports Corvus Airlines operates to, thus greatly increasing safety for the public.

FlightSafety has incorporated the enhanced and specific visuals for PADU into simulator FAA ID # 1242 at the request of Corvus Airlines after, and partially in response to, the October 17, 2019 Penair accident at Dutch Harbor. Having these safety enhancements removed as an unintended consequence of unrelated regulatory compliance is directly contrary to public safety.

V. Equivalent Level of Safety:

There is no adverse effect on safety since what Corvus is seeking is currently allowed for an air carrier who operates both the DHC-8-100 and DHC-8-200 aircraft. The current FSB does not have any requirements for operating experience differences. An operator of both the DHC-8-100 and DHC-8-200 aircraft has the option to train and qualify its pilots in the DHC-8-200 simulator and the pilot would be allowed to review the Level A differences and subsequently operate the DHC-8-100 aircraft with no further oversight or checking.

VI. Request for Expedited Consideration:

Corvus Airlines is requesting that, as part of this Petition for Exemption request, the public comment phase be waived as per Title 14 CFR Part 11.87(a), (b), and (c), which states:

“The FAA may not publish a summary of your petition for exemption and request comments if you present or we find good cause why we should not delay action on your petition. The factors we consider in deciding not to request comment include: (a) Whether granting your petition would set a precedent. (b) Whether the relief is identical to exemptions granted previously.

4700 Old International Airport Road Anchorage, AK, 99502 www.ravnalaska.com

(c) Whether our delaying action on your petition would affect you adversely…..”

In this case the FAA would be approving a process that is currently allowed for air carriers operating both the DHC-8-100 and DHC-8-200 aircraft types. The only difference is Corvus will not be operating the DHC- 8-200 aircraft. As such Corvus’ proposal is not precedent setting.

There are multiple exemptions granted for 121.407 (a)(1)(ii) currently listed on the Federal Register.

A delay in granting this exemption would require air crews to be trained and qualified in the aircraft and/or a simulator located in a different country without the safety benefits of simulator training specific to Alaska airports. Additionally, due to the current pandemic, travel to and from Canada is difficult and increases COVID exposure and risk compared to a single destination within the United States.

VII. Summary for Federal Register (if deemed required):

Rule from which Corvus Airlines seeks exemption:

“§121.407 Training program: Approval of flight simulation training devices. (a) Each FSTD used to satisfy a training requirement of this part in an approved training program, must meet all of the following requirements: (1) Be specifically approved by the Administrator for -- … (ii) The type airplane and, if applicable, the particular variation within type, for which the training or check is being conducted; and…” (Emphasis added)

Brief description of the exemption:

Corvus Airlines Inc. (dba Ravn Alaska), operating certificate 7C7A855N, hereby petitions the Federal Aviation Administration (FAA), pursuant to 14 C.F.R. Part 11 for relief from Federal Aviation Regulation (FAR) §121.407(a)(1)(ii) to allow training and checking in a Dash-8-200 series simulator and operate the Dash-8-100 series aircraft. This would allow the travelling public to benefit from the enhanced visual and training capabilities of the Dash-8-200 simulator specific to certain airports in Alaska where Corvus is the sole 121 scheduled passenger operator.

VIII. Additional Arguments to Support this Exemption:

Due to the current pandemic, travel to destinations in Canada have been difficult and burdensome for flight crews. The COVID travel requirements for Canada are much stricter and less consistent than travel within the United States, sometimes requiring unreasonable quarantines and documentation on short notice.

Multiple travel legs from the Corvus Airlines main headquarters in Anchorage, Alaska would be required to reach the simulator locations in Canada, increasing the risk of COVID exposure and spread. DHC-8-200 simulator FAA # 1242 is located in Seattle, WA, requiring a single travel leg each way from Anchorage.

4700 Old International Airport Road Anchorage, AK, 99502 www.ravnalaska.com

IX. Operation Outside of the United States:

The privileges of this exemption will not be exercised outside of the United States.

Please contact Evan K. Veal, Director of Operations at (907) 266-8421 or email at [email protected], if you have and questions or need additional information.

Respectfully,

Evan Veal Director of Operations Corvus Airlines, Inc. dba Ravn Alaska cc: Patrick W. Sullivan, Principal Operations Inspector, Denali Certificate Management Office - FAA

4700 Old International Airport Road Anchorage, AK, 99502 www.ravnalaska.com