ARTl/ENTOF PROMAR K 

'•' ''^^POPTATION Aviation Services 

March 1,2011 •• . ^-f 0^i:RAT10N3 

U.S. Department of Transportatfon '/f] ';AR - ^ A I!" 1 5 

Docket Management System, 

400 7th Street, SV^., Room PL 401 

Washington, DC 20591-0001 

Subject: Request for Exemption from the provisions of Title 14 CFR Section 91.109(a) and (b) (3) for certain 

Beechcraft airplanes with throw-over control wheels. 

Under the provisions of Title 14 CFR Subpart B, Sections 11.21-1137, Kenneth F. Wittekiend (petitioner), 

requests ar\ exemption from the provisions of Title 14 CFR Section 91.109(a) and (b) (3) of the Federal Aviation 

Regulations (FAR's) to allow him to conduct flight instruction In Beechcraft Bonanza and Debonair airplanes 

equipped with a functioning, single, throw-over control wheel. 

Reason for this petition: 

FAR 91.109(a) prohibits flight instruction, except instrument instruction in single engine airplanes under certain 

conditions, in aircraft without fully functioning dual flight controls. In addition FAR 91.109(b) (3) permits 

simulated instrument flight only in single engine airplanes equipped with a functioning, single, throw-over 

contro\ wheel. These provisions effectively prohibit all flight instruction in Beechcraft single-engine airplanes 

with single throw-over control wheels, and also prohibit simulated instrument flight in these airplanes. 

2. FAR 61.56 requires flight instruction to be performed as part of an flight review. Under current regulations 

this flight review cannot be performed in airplanes with throw-over control wheels; 

3. The provisions of FAR 61.45 (c), have, since 1973, permitted FAA personnel and Designated Pilot Examiners 

to conduct pilot certification flight tests in aircraft not equipped with dual controls. Under the requested 

exemption, the petitioner will operate at a greater level of safety than the minimal level permitted by FAR 

61.45 (c). 

Safety Considerations: 

1. The specific level of control available to a flight instructor in a Beechcraft Bonanza and Debonair airplanes 

equipped with a throw over control wheel is quite good. The control configuration is such that the instructor 

ALWAYS has full use of rudder control in flight. The instructor's access to all engine controls of the aircraft Is 

unaffected by the type of control wheel installed. Full elevator control is continuously available to the 

instructor in either configuration as the center control column of the airplane is easily accessible to the 

instructor in a throw-over configuration. Manipulation of the center control column affords the flight instructor 

full elevator control as the elevator control column is located in the center of the control panel with 

unobstructed access. Aileron control is also within easy reach of the instructor (although in front of the PIC) 

and is more than sufficient to allow any additional control inputs necessary during flight; 

P.O. Box 460 

Bumet,TX 78611-0460 

(830)385.1593 

(512) 756.0574 fax 

www.promarkaviation.net 
U.S. Department of Transportation, March 1, 2011 - Page 2 

2. The Beechcraft Pilot Proficiency Program (BPPP) has had exemption No. 7571 from 91.109 for many 

years. To the petitioner's knowledge and belief, the BPPP have never experienced an incident or 

accident related to the conduct of training in an airplane with a throw-over control wheel; 

3. Therefore, in view of the facts presented above and the experience of the FAA and other groups to 

date, it is reasonable to conclude that flight safety will not be compromised by granting this exemption 

request. 

The interests of the public are served by this exemption \n the following ways: 

1. The primary purpose of this requested exemption is to encourage pilots of Beechcraft aircraft with 

throw-over control wheels to seek currency and instrument proficiency training to ensure their 

proficiency, currency, and overall safety; 

2. By allowing pilots to train in their own aircraft rather than renting an aircraft with fully functioning 

dual controls, such pilots are more likely to seek needed training in both visual and instrument flight; 

3. Additional pilot training and proficiency flights made possible by this exemption will result in more 

proficient pilots; 

4. The petitioner believes that it is in the public interest that the availability of recurrent pilot training be 

maximized, consistent with acceptable safety practices. Maximizing such training should result in safer 

pilot practices with a corresponding reduction in the likelihood of aviation acddenU. 

Identifiable costs of the exemption to the public and to society: None 

Regulatory burden of the exemption: None. 

Effect of this exemption on of the quality of the natural and social environments: None 

The following operational conditions are proposed for the requested exemption: 

1. Operations under the exemption will be limited to: 

a. Performing the flight review required by 14 CFR Section 61.56 (a); 

b. Conducting the training necessary to accomplish one or more phases of an FAA sponsored pilot 

proficiency program provided for in section 61.56 (a) ("Wings" program); 

c. Conducting instrument flight training under simulated and actual conditions to meet the requirements 

of 61.67 (c) (1) and (d) and other requirements; 

2. Operations will be limited to Beechcraft Bonanza and Debonair airplanes equipped with functioning 

dual rudder pedals and a functioning, single, throw-over control wheel; 

3. Pilots receiving training will possess a private or higher pilot license with the appropriate ratings for 

the airplane flown, and a current medical certificate, and will be fully qualified to serve as PIC for the 

entire flight; 
U.S. Department of Transportation, March 1, 2011 - Page 3 

4. The petitioner, when acting as an authorized instructor under the provisions of this exemption, will be 

fully qualified to serve as PIC and as flight instructor, as required by FAR 61.67 (c) (1) and (d) and FAR 

61.195(b) and (f). 

Petitioner's pilot qualifications: 

1. Petitioner Kenneth F. Wittekiend, holder of pilot license number 2075544, holds a commercial pilot's 

license with single airplane and instrument ratings, and a flight instructor license for single engine 

airplanes and Instruments. Petitioner has been an active pilot and Flight Instructor since 1976 and has 

total flying time as a pilot of 9652 hours with 6211 as a flight instructor. He currently instructs in 

Beechcraft airplanes with the BPPP (referenced earlier) and is experienced In instructing in Beechcraft 

single control airplanes with a throw-over control wheel under the exemption from FAR 91.109 granted 

to the BPPP; 

2. The granting of this petition will allow the petitioner to provide recurrent and instrument training to 

his pilot clients who own Beechcraft Bonanza and Debonair airplanes with single throw-over controls. 

Summary for the Federal Register: 

Petitioner: Mr. Kenneth F. Wittekiend 

Section of 14 CFR Affected: 14 CFR 91.109(a) and (b)(3). 

Description of Relief Sought: To permit Mr. Wittekiend to conduct certain flight instruction and 

instrument flights to meet the recent experience, flight review, and instrument experience requirements 

in certain Beechcraft airplanes equipped with a functioning throw-over control wheel in place of 

functioning dual controls. 

Thank you for prompt consideration of this request. 

Sincere 

Kenneth F. Wittekiend