August 19 , 2010



### U.S. Department 

### ofTransportation Docket Management System, 400 7th Street, SW. , Room PL 401 Washington, DC 20591-0001 Subject: Request for Exemption from the provisions ofTitie 14 CFR Section 91.109 (a) and (b) (3) for certain Beechcraft airplanes with throw-over control wheels. Under the provisions of Titlel4 CFR Subpart 8 , Sections 11.21-1137, Thomas A. Johnson (petitioner) , requests an exemption from the provisions ofTitle 14 CFR Section 91.109 < a) and (b) (3) 

### ofthe Feder al Aviation Regulations (FAR's) to allo w him t o conduct flight instruction in Beechcraft Bonanza, Debonair, Baron, and TravelAir airplanes equipped 

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

### Reason f or 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) pennits 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 wheels, and also prohibit simulated instrument flight in these a irplanes. The cockpits ofBeechcraft 

### Baron and TravelAir airplanes are virtua1ly identical in configuration and layout to the Beechcraft BonanzalDebonair airplanes; 2. FAR 61.56 requires flight instruction to 

### be performed as part ofan flight review. Under current regulations this 

### flight review cannot 

### be performed in 

### airplanes with throw-over control wheels; 3. The provisions ofFAR 61.45 (c), have, since 1973, pennitted 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 

### pennitted b y FAR 61.45 (c). Safety Considerations :1. The specific level of control available to a flight instructor 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 ofrudder control in flight. The instructor's access to all engine controls ofthe aircraft is unaffected by the type ofcontrol wheel installed. Full elevator control is continuously available to the instructor in either configuration as the center control column ofthe airplane is easily accessible to the instructor in a throw-over configuration

. Manipulation ofthe center control column affords the flight instructor full elevator control as the elevator control column is located in the center ofthe control panel with unobstructed access. Aileron control is also within easy reach ofthe instructor (although in front ofthe 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 petitioner' s knowledge and belief, the BPPP have never experienced an incident or accident related to the conduct oftraining in an airplane with a throw

-over control**wheel~** 3. Therefore, in view ofthe facts presented above and the experience ofthe 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 in the following ways: 1. The primary purpose ofthis requested exemption is to encourage pilots ofBeechcraft 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 saf er pilot practices with a corresponding reduction in the likelihood of aviation accidents. Identifiable costs ofthe exemption to the public and to society: None Regulatory burden ofthe exemption: None

. Effect ofthis exemption on ofthe quality ofthe natural and social environments: NoneThe following operational conditions are proposed for the requested exemption: I. 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; d. Conduct training necessary to meet the requirements of a Commercial Pilots license. 2. Operations will be limited to Beechcraft Bonanza, Debonair, Baron and TravelAir airpanes 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 setve as PIC for the entire flight; 4. The petitioner, when acting as an authorized instructor under the provisions ofthis exemption, will be fully qualified to serve as PIC and as flight instructor, as required by FAR 61.67 (c) (I) and (d) and FAR 61.195 (b) and (i)

. Petitioner's pilot qualifications: 1. Petitioner Thomas A. Johnson, holder ofpilot license number 2678220, holds a commercial pilot's license with single and multi

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

-engine airplanes and instruments. Petitioner has been an active pilot since 1998, Flight Instructor since 2006, has total flying time as a pilot of 1,104 hours with 205 as a flight instructor and has experience as pilot in command of single control and dual control Bonanzas and dual control Barons. 2

. The granting ofthis 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. 

### Thomas A. 

### Johnson. Section of 14 CFR Affected:

- 14 CFR 91.109(a) and (b)(3). 

### Description 

### ofRelief Sought: To pennit Mr. 

### Johnson to conduct certain flight instruction and instrument flights to meet the recent experience, flight review, and instrument or commercial experience requirements in certain Beechcraft airplanes equipped with a functioning throw-over control wheel in place of functioning dual controls. Thank you for prompt consider ation 

### ofthis request. Sincerely:

Thomas A. Johnson Commercial Pilot and Flight Instructor 10156 New Devon St Munster, IN 46321 

### Tel: 708

- 872

- 0085**~ohnson llytj.com**  

### www.llytj.com