Herman W. Sharp Jr. 

Airline Transport Pilot & Flight Instructor CFII, MEI 

111 Cypress Point Lane 

Minden, LA 71055 

;fTGrTRANS^O 

€TS 

Tel: (318) 371-1010 

E-mail: wavne sharp@bellsouth.net 

April 12, 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, Hemnan W. 

Sharp Jr., (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 tiiis 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) 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 kientrcal in configuratk>n 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 perfomned in airplanes with 

throw-over control wheete; 

3. The provisk)ns 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 exemptton, the petitioner will 

operate at a greater level of safety than the minimal level permitted by FAR 61.45 

(c). 

Safety Conskleratbns: 

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 configuratton is such that the instructor ALWAYS has full use 

of rudder control in flight. The instructor's access to all engine controls of ttie aircraft 
Page 2 

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. Manipulatbn of the center control column affords the flight instructor 

full elevator control as the elevator control column is k)cated 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 alk>w 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 petittoner's knowledge and belief, the BPPP 

_ _ _have never experienced an incklent or acckjent related to the conduct of training in 

*'*^""f*f^ffliptene with a throw-over control wheel; 

3. Therefore, in view of the fects 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 exemptton in the fblk)wing ways: 

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

Beechcraft aircraft with throw-over control wheete 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 exemptk)n will 

result in more proficient pilots; 

4. The petitk>ner believes that it is in the publk; interest that the availability of 

recurrent pik^t training be maximized, consistent with acceptable safety practk»s. 

MaxnmizirHS such training shoukJ result in safer pitot practioes wtth a oonesponding 

reduction in the likelihood of aviation accidents. 

Identifiable costs of the exemptk>n to the publrc and to society: None 

Regulatory burden of the exemption: None. 

Effect of this exemptbn on of the quality of the natural and social environments: 

None 

The following operatk>nal conditrons are proposed for the requested exemption: 

1. Operations under the exemption will be limited to: 

a. PerfonDing 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 provkled for in section 61.56 (a) Clings " 

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; 
Page 3 

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

airpanes equipped with functroning dual rudder pedals and a functioning, single, 

throw-over control wheel; 

3. Pik)ts receiving training will possess a private or higher pilot ik:ense with the 

appropriate ratings for the airplane flown, and a cun'ent medk^al certificate, and will 

be fully qualified to serve as PIC for the entire flight; 

4. The petitksner, when acting as an authorized instructor under the provisk>ns of this 

exemptk)n, 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 Herman W. Sharp Jr., hokler of pitot license number 3156442, hotels an 

Airiine Transport Rating for multi-engine airplane and commercial pik>f s license with 

single and instrument ratings, and a flight instructor lk»nse for single and multiengine airplanes and instruments. Petitioner has been an active pilot and Flight 

Instructor since 1986 and has total flying time as a pik)t of over 4000 hours with 

approximately 1000 as a flight instructor, of which slightly over 50% of each total is in 

multi-engine airplanes. Petittoner owns and flys a Beech Baron B55, and has owned 

2. The granting of this petition will allow the petitbner to provtele 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. Herman W. Sharp Jr. 

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

Description of Relief Sought: To pemnit Mr. Sharp to conduct certain flight instructk>n 

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

experience requirements in certain Beechcraft airplanes equipped with a functk>ning 

throw-over control wheel in place of functkming dual controls. 

Thank yotHbr prompt consideratron of this request. 

/^ce r 

larp Jr.