August 19, 2010 

U.S. Department of Transportation 

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 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 functioning, single, throw-over 

control wheel. 

Reason for this petition: 

1. FAR 91.109 (a) prohibits flight instruction, except instrument instruction in singleengine 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 airplanes. The cockpits of Beechcraft 

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 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, 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 by 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 AL WAYS 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; 

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 in the following ways: 

1. The primary purpose of this requested exemption is to encourage pilots of Beech craft 

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 accidents. 

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: 

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 of this 

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 of pilot 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 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. Thomas A. Johnson. 

Section of 14 CFR Affected: 

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

Description of Relief 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 consideration of this 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