m 

no 

John H. Hebbelman Jr. 

Commercial Pilot and Flight Instructor 

715 Hebbelman Lane 

Chinook, Mt. 59523 

Tel & Fax: 406-357-4233 Cell: 406-945-1322 

E-mail: itfly6040f@hotmail.com 

June 20, 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 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, Gerald A. Parker 

(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 irtstruction in singleengine 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 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 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: 
U.S. Department of Transportation, June 20, 2010 - Page 2 

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 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 cofitjrol 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 

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.Add4tiefl«ri-piloHfatning-fmd'profieieney-ftights-nFiadepossibl 

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. 
U.S. Department of Transportation, June 20, 2010 - Page 3 

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 

iQjneet the requirgrDeots of 61,67 (c) (1) and (d). and-fltheLteqjiirements:. . -

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 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 John H. Hebbelman Jr, holder of pilot license number 1549667, 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 1963 and Flight Instructor 

since 1967 and has total flying time as a pilot of 24,269 hours with over 12,000 as a 

flight instructor." He ciirrentlylnstructsinBeechcraftairplanesrand-is-experlenced-rn 

instructing in Beechcraft single control airplanes with a throw-over control wheel 

under the exemption from FAR 91.109 granted to the BPPP. Currently owns a S-35 

N6040F since 1974, A-36 Jetprop N400WW and a F-33A N455D with over 11,927 

hrs in 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: John H. Hebbelman Jr. 
U.S. Department of Transportation, June 20, 2010 - Page 4 

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

Description of Relief Sought: To pemiit Mr. Parker 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. 

Sirjcerely: 

John H. Hebbelman Jr. 
r ^ 

A|^S News: Instruction in Single Control Airplanes Page 1 of 2 

Back, to News list 

Instruction in Single Control Airplanes 

December 18,2006 

Flight Instruction in Single-Control Beechcraft 

updated 12/18/2009 

ABS frequently gets questions about the legality of flight Instruction in airplanes with a single control yoke. Here's the current Federal Air 

Regulation, with emphasis added: 

§91.109 Flight Instruction; Simulated instnmant flight and cartain flight tests. 

(a) No person may operate a civil aircraft...that Is being used for flight Instruction unless that aircraft h«« fully functlonino dual controie. However, Instrument 

fflgtit Instruction may be given in a sinale^ennlne airplane equipped with a single, functioning throwover control wheal in place of fixed, dual controls of the 

elevator and ailerons when— 

(1) The Instnjctor has determined that the flight can be conducted safely; and 

-_».,— (21 Th«-p«rson manipulatlngJbe.Gontrols.has at-leasLa-prtvate pilot«adiflcate with.apprapfietexateBory and class ratings*-^-' — ~ ,...~_- —>—v.-

December 2009 A Notice of Proposed Rulemaking (NPRM) would remove most restrictions on flight instruction, including Flight Reviews, 

in airplanes with throw-over flight controls. ABS supports this proposed change. We have filed comments on your behalf showing this 

support, and requested additional changes to further encourage type-specific flight training and to create consistency betvtreen FARs 61 

and 91. the comment period for this NPRM expired November 30, 2009, and we do not know if/when a change to FAR 91.109 will become 

effective. 

Current restrlctiorts on instruction and evaluation in single-controi airplanes have not changed for many years, and are summarized lielow: 

FAA interpretation, enforcement action and some insurance claims history consistently rule that a Flight Review as required in 61.56 consists 

of "flight instruction," and therefore dual flight controls must be installed. There is no room for interpretation requiring dual controls for any 

other instruction not specifically limited to "instrument" instruction, for example, instruction toward currency requirements, high-performance 

and/or complex endorsements, pilot certificates or ratings, and insurance-mandated checkout instruction (for purposes of meeting insurance 

underwriters' policy stipulations). 

Single-Control Exemptions 

Confirming this interpretation, the FAA provides for exemptions to FAR 91.109(a) permitting flight instmcfion in single-control airplanes under 

certain circumstances. Exemptions require both pilot and instructor be qualified to act as piiot-in-command, precluding some types of 

training, including initial checkouts if the pilot receiving instruction does not already have his/her Complex and High Performance 

endorsements. 

ABS' training partner BPPP, Inc. holds an exemption that allows Instruction In single-control single and multlengine Beechcraft, but only 

when such training is done In a regularly scheduled BPPP event (see vww.bppp.oraV BPPP's exemption is also subject to the requirement 

that both student and instructor be qualified to act as PIC. 

Are you a CFI wanting to provide instruction in a single-control airplane? Use these resources to comply with FAR 91.109 flight instruction 

requirements: 

• FAR 91.109 

• Sample letter requesting an exemption to permit flight instruction in single-control airplanes 

».-Where to apply for a 91.109 exemption . . . .. 

• Sample of a single-control flight Instruction exemption approval letter 

Success in obtaining an exemption seems to hinge on the instructor's experience in Beech aircraft and his/her personal relationship with their 

local FSDO. In some cases these exemptions are valid In multlengine airplanes, in others it Is restricted to single-engine aircraft. 

Instructors Holding Exemptions, and How to Find Them 

CFIs holding exemptions to conduct single-yoke training are encouraged to post contact information in the Flight Instructors conference 

area on the Hangar Flying bulletin board, in the Members Only section ofwvw.bonanza.org. Be certain to indicate you have an exemption to 

provide single-yoke instruction, whether it permits instruction in single- and/or multlengine Beechcraft, and the expiration date of your current 

exemption. 

Pilots seeking Instruction: Please read the "Important: About This Flight Instructor List" before choosing a flight instoictor v\/ho has posted 

his or her information in Hangar Flying. 

FAA Practical Tests (checkrides) in Single-Control Airplanes 

FAR 61.45(e) gives individual pilot examiners authority to decide whether they wish to conduct practical tests in single-control airplanes, 

under these conditions: 

(e) Aircraft with single controls. A practical test may be conducted in an aircraft having a single set of controls, provided the: 

http://www.bonanza.org/News/?id= 186 6/20/2010 
A^S News: Instruction in Single Control Airplanes Page 2 of 2 

(1) Examiner agrees to conduct the test; 

(2) Test does not involve a demonstration of instrument skills; and 

(3) Proficiency of the applicant can be observed by an examiner who is in a position to observe the applicant. 

Ironically, FAR 91.109(a) permits instrument flight instruction in single-control airplanes, but FAR 61.45(e) prohibits an Instrument pilot 

checiirtde In that same airplane. ABS is attempting to get a clarification from the FAA concerning this contradiction. 

Rental Yokes 

Several facilities provide dual yoke rental sen/ices. A rental yoke may be shipped to an aircraft owner and quickly Installed by a certificated 

mechanic (a mechanic's logbook endorsement is required). BE EXTREMELY CAREFUL to check all control movement, trim operafion and 

the proper function of push-to-talk, autopilot disconnect and any other yoke-mounted switches after installing a dual yoke and again when reinstalling the single yoke. 

Although there may be others, ABS knows of the following dual control rental sources. Contact each for price and avajiability. 

Air-Mech 888-282-9010 

CrulseAIr 760-789-8020 

Cygnet 805-528-2376 

Dave Monte 775-792-5282 

Garhawk 800-686-9887 

Lawson Barber 559-675-0183 

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http://www.bonanza.org/News/?id=186 6/20/2010