Paul John Damiano 

Airline Transport Pilot and Instrument Flight Instructor 

28BmceRcl 

Manchester, CT 06040 

Tel: 860 646 3383 Fax: 860 649 4853 Cell: 860 306 3441 

E-mail: pjdbonanza@msn.com 

Feb 13. 2010 . , 

—i 

CO 

U.S. Department of Transportation c , a i 

Docket Management System F«A-2OJO-oje^ 

400 7th Street, SW. .. jj'^ ^ 

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 Title14 CFR Subpart B, Sections 11.21-1137, Paul John Damiano 

(petitioner), requests an 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, Debonair, Baron, and TravelAir airplanes equipped with 

a ftjnctioning, single, throw-over control wheel. 

Reason for this petition: 

1. 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) penriits simulated instrument flight only in single engine 

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

effectively prohibit all flight instruction in Beechcraft Baron and TravelAir twin-engine 

airplanes with single throw-over control ^vheels, and also prohibit simulated instrument flight 

in these airplanes. The cockpits of Beechcraft Baron and TravelAir airplanes are virtually 

identical in configuration and layout to the Beechcraft Bonanza/Debonair 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 speciflc level of control available to a flight instmctor in a Beechcraft Bonanza, 

Debonair, Baron and TravelAir 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 

instmctor 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 unobstmcted 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; 

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

91.109 for many years. To the petitionei''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 fiight safety will not be compromised by 

granting this exemption request. 

The interests of the pubiic are served! by this exemption in 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 fiight; 

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

in more proflcient 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 conresponding reduction in the likelihood of 

aviation accidents. 

Identifiable costs of the exemption to the pubiic 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 instalment fiight training under simulated and actual conditions to 

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

2. Operations will belimited to Beechcraft Bonanza, Debonair, Baron and TravelAir 

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 fiown, and a current medical certificate, and will be fully qualified to 

serve as PIC for the entire flight; 

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 Paul John Damiano, holder of pilot license number 2441777, holds an Airline 

Transport Pilot's license with single and multi-engine airplane and instrument ratings, and 

an instalment flight instructor license for single and multi-engine airplanes. Petitioner has 

been an active pilot and Flight Instructor since 1989 and has total flying time as a pilot of 

2,850 hours, with over 2300 hours operating Beech aircraft. 

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

training to his pilot clients who own Beechcraft Bonanza, Debonair, Baron, and TravelAir 

airplanes with single throw-over controls 

Summary for the Federal Register: 

Petitioner Mr. Paul John Damiano 
Section of 14 CFR Affected: 14 CFR 91.109(a) and (b)(3). 

Description of Relief Sought: To permit Mr. Damiano to conduct certain flight instaiction 

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

experience requirements in certain Beechcraft airplanes equipped with a functioning throwover control wheel in place of functioning dual controls. 

Thank you for prompt consideration of this request. 

Sincerely: 

Paul J. Damiano