U.S. Department of Transportation 

Docket Operations, M-30 

West Building ground floor. Room W12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590 

Date: July 3,2010 

Subject: Request for Extension of Exemption No. 9778 

This letter is a request for an extension of FAA exemption number 9778. A copy of this exemption 

is enclosed for your convenience. 

The reasons to grant the extension, such as public interest and public benefit, are the same as when 

the exemption was originally granted. These reasons are well outline in the associated petition 

(docket FAA-2007-28418). A copy of this document is also enclosed for your convenience. 

Please note that several pilots have been trained under this exemption. The exemption allowed 

them to use aircraft they own versus renting a retractable gear aircraft. The average cost savings 

was $500 per trainee. Please see the enclosed document labeled "Exhibit A - Complex Training 

Cost Savings" for more information. 

Regarding safety, there have been no accidents, incidents or violations while training with FAA 

exemption 9778. Nor have any of the trainees had an accident, incident or violation since receiving 

their complex endorsements. 

It would be greatly appreciated if a reply in this matter could be received before November 30, 

2010. 

Thank you for your attention in this matter. 

Sincerely, 

Gregg J. Stockman 

Certificate Number 2924400 CFl 

669 Berville Road 

Allenton, Michigan 48002 

Phone: 810-395-4272 

Email: nl 5997(a)gmail.com 
./2089 89:52 2B22675B75 OFFICE OF RULEMWONS PAGE 02 

L^^i"Cr7;-.-.' 

Exemption No. 9778 

UNITED STATES OF AMERICA 

DEPARTMENT OF TOANSPORTATION 

FEDERAL AVIATION ADMINISTRATIQN 

WASHINGTON, DC 20591 

In tiie matter of ^ petidoii of 

GREGG STOCKMAN 

for an exerop&oa from § 61.31(e) 

ofrittel4,Codeof 

Federal R^iulatKHis 

RcgrialMy Docket N*, FAA-2W7.28418 

GRANT OF eXEMPnON 

By letter dated May 29,2007, B^. Giegg Stodanan, 6 ^ Bcndlle Road, Anentoa, 

Miclugaii 48002, petf^ooed the Fedezal Aradiaa Adauoistmioii (FAA) for an exemption 

firom § 61.3K«) of Title 14, Code of Fedoal R^ddatkns (14CFR). Tht psoposed exemption, 

if granted, y/otUd allow Mr. Stockman to use certun fixed gear aajdanes to provide comf^ex 

tiiplane training. 

The petftj<m«r rcqveats rdief frtMi tte Iblfcrwuig regolatini: 

Section 61.31(e) preactibes, in pextineiit par^ that; 

Type rating lequorements, additional traimn^ and audiotiZHtion requirements. 

(e) Additional training required lor operating oMnplex airplanes. (1) Except as provided 

in panffapti (e)(2) of this section, no person may act as jrilot in coaaoaaad of a complex 

aiiplane (an atiplane that has aietcactable landing gear, flt|», and acontcollable pitch 

propeller, or, in ibe case of a acaplanr, fbfs and a contaoVaUe pitch propeller), imless 

the person luB— 

CO Riccdved and logged groimd and fli^tnuning frnn an audioiized 

instructor in a complex atrjdane, or in a £li ^ simulator or flight training 

E-2007^768 
a7/i:3/2009 09:52 2022675075 CFFICE OF RULEHflKING PAGE 03 

device that is representative of a complex airplane, and has been foiind 

proficient in the operation and systems of the aiiplane; and 

(ii) Received a one-time endorsement in the pilot's logbook from an authorized 

instructor \^ o certifies the person is proficient to operate a complex airplane. 

(2) The training and endorsement required by paragraph (eXU of ftis section is not 

required if the person has logged fli^t time as pilot in command of a complex airplane, 

or in a flight simulator or flight training device that is representative of a complex 

airplane prior to August 4,1997. 

The pecitioier supports his request with the following tafonnatfon: 

Mr. Stockman states he is requesting an exemption fiom using retractable gear 

airplanes to provide training and endorsements vmder § 61 -31 (e). In lieu of using 

retractable gear aiiplanes, the petitioner proposes to use certain fixed gear airplanes 

that ore equipped-with the portable training device specified in U.S. Patent 6,638,071. 

Typical fixed gear airplanes to be used in conjunction with this exemption are those 

equipped with flaps and a controllable pitch propeller. 

The petitioner states a prototype of U.S. Patent 6,638,071 was used for some remedial 

pilot training ordered 1^ the local Flight Standards District Office in Januaiy 2001. A 

favorable post training report was received fiom the aviation safety counselor (ASC) 

involved. Mr. Stockman also states that a field approval, FAA fonn 337, was obtained 

for Piper Dakota N2213F to hold the device specified in U.S. Patent 6.638,071. 

The petitioner states that a grant of exemption would improve the quality of flight 

training while also reducing training costs. Mr. Stockman fintfaer stales that an 

exemption would be in the public interest because it would provide an improved 

method of doing training for complex airplanes. Pilot trainees can experience in-flight 

malfunctions involving landing gear circuit breakers and these malfunctions cannot be 

safely replicated when using a retoactable gear airplane. In addition, the pilot trainees 

can be made to experience in-flight malfunctions requiring the changing of landing 

gear indicator bulbs. The petitioner states this maliimction also cannot be safely 

replicated when using a retractable gear airplane. 

Mr. Stockman states that with the above-mentioned training improvements the number 

of gear up landings will potentially be reduced. 

The petitioner states that a grant of exemption would not adversely impact safety 

during flight training because: 

1. Fixed gear airplanes are iuherentiy safer to train in than are retractable gear 

airplanes. 
07/23/2009 09:52 2022675075 OFFICE OF RULEMAKIN6 PAGE 04 

2. Fixed gear airplanes are statistically safer to train in than are retractable 

gear airplanes. 

3. The flight training would still be done with an authorized instructor 

onboard. 

Mr. Stockman fUrdier states that a grant of exemption would not adversely impact 

safety after ttie flight training because: 

1. The pilot trainee would receive all the training provided by the current 

regulations. 

2. The pilot trainee would receive additional training experiences with the 

instructor. 

3. The pilot trainee would still be evaluated by an authorized instructor and 

certified as proficient to operate a complex aiiplane. 

A summaiy of the petition was published in the Federal Register on July 19,2007 

(72 FR 39659). Seventeen comments were received, all of which were in support of the 

petitioner's request for exemption. 

The FAA's analysis is as folhnrs: 

The FAA has considered the petitioner's request and supporting materials and finds that 

a grant of exemption would be in the public interest and maintains a level of safety 

equivalent to that provided by the cmrait regulations that allow for complex airplane 

training in certain flight training devices and flight simulators. The FAA also reviewed 

FAA ASC Thomas J. Kemiedy's assessment during FAA-mandated remedial training 

and the FAA's tq^proval of a major alteration of N2213F using the petitioner's device. 

The FAA recognizes that granting this petition would set a precedent in that the FAA 

would be authorizing simulation training "credit" for tiie use of certain non-complex 

(fixed gear) airplanes that simulate the operations of certain complex (retractable gear) 

airplanes. In the past, simulation training credit for aiiplane-specific flight training has 

been reserved for advanced flight traioing devices (such as Level 6 fli^t training 

device) and flight simulators, with the pilot ultimately demonstrating proficiency in 

specific airplane operations cift^er in the actual airplane or a flight simulation device 

that simulates required airplane operation. The FAA has determined that an adequate 

level of safety can be maintained while allowing the simulation of landing gear in a 

non-complex airplane because landing gear operations have a considerably less 

aerodynamic effect on overall airpUme in-flight operations than do other aspects of a 

complex airplane such as flaps and engine operations. 
07/23/2009 09:52 2022675075 CFFICE OF RULEMAKING PAGE 05 

The FAA*s Decision 

In consideration of the foregoing, I ftndl diat a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. §§ 40113 and 44701, delegated 

to me by tiie Administrator, Mr. Oregg Stockman is granted an exemption fiom 

14 CFR § 61.31(e) to the extent necessary to allow him to use certain fixed gear airplanes 

to provide complex airplane training, subject to the conditions and limitations listed 

below. 

Conditimis and LnnitatioBs 

1. This exemption applies only to Mr. Stockman provicKng flight training or an 

endorsement under § 61.31(e). 

2. This exemption does not apply to flight training pursuant to an airman certificate or 

rating. 

3. The non-complex airplane being used to simulate a complex airplane per Condition 

No. 5 must have a standard type certificate. 

4. The non-complex airplane being used to simulate a complex airplane per Condition 

No. 5 must be equipped with a controllable pitch prc^ller and flaps. 

5. The non-complex airplane make and model being used to simulate a complex airplane 

must be equipped witii the petttioner's device (U.S. Patent 6.638,071) in accordance 

with either the supplemental type ceitificate process per part 21 or in accordance witii 

the major altenstion process per part 43. 

6. Persons receiving training under this grant of exemption per Condition No. I must also 

have a notation in their logbook that all or part of the training was conducted using 

Exemption No. 

This exemption terminates on November 30„ 2010. unless sooner superseded or rescinded. 

Issued in WasMngton, DC, on October 31.2008. 

Sincerely, 

/$/ 

James J. Ballough 

Director, Flight Standards Service 
U.S. Department of Transportation 

Docket Management System 

400 7^^ Street, SW., Room PL 401 

Washington, DC 20591-0001 

Date: May 29,2007 

Subject: Petition for Exemption 

This letter is a petition for an exemption as provided for in 14 CFR 11.61(b). The following text is 

the information required under 14 CFR 11.81 arranged by paragraph letters (a) through (h). 

(a) Petitioner's Name. Address, & Contact Information 

Gregg Stockman 

669 Berville Road 

Allenton, Michigan 48002 

Phone: 810-395-4272 

Email: n 15997(g),gmail.com 

(b) Seeking Relief Under 

14 CFR 61.31(e) 

(c) Extent of Relief: 

Relief is sought to the extent necessiary to allow an alternate method of doing flight training. 

Reasons for Relief: 

To improve the quality of flight training while also reducing flight training costs. 

(d) Public Interest & Public Benefit 

This exemption is in the public's interest because it provides for an improved method of 

doing training for complex airplanes. 

With this exemption pilot trainees can experience in flight malfimctions involving landing 

gear circuit breakers. These malfimctions cannot be safely replicated when using a 

retractable gear airplane. 

Additionally, pilot trainees can be made to experience in flight malfunctions reqviiring the 

changing of a landing gear indicator bulb. This malfunction also caimot be safely replicated 

when using an actual retractable gear airplane. 

With the above-mentioned training improvements the number of gear up landings will 

potentially be reduced. 

This exemption will also benefit the public because of the cost savings associated with 

training in fixed gear airplanes as opposed to retractable gear airplanes. 
(e) Safety and the Exemption 

This exemption would not adversely impact safety during flight training because: 

1. Fixed gear airplanes are inherently safer to train in than are retractable gear airplanes. 

2. Fixed gear airplanes are statistically safer to train in than are retractable gear airplanes. 

3. The flight training would still be done with an authorized instructor onboard. 

This exemption would not adversely impact safety after the flight training because: 

1. The pilot trainee would receive £ill of the training provided by the current regulations. 

2. The pilot trainee would receive additional training experiences with the instructor. 

3. The pilot trainee would still be evaluated by an authorized instructor and certified as 

proficient to operate a complex airj)lane. 

The six items listed above will ultimately insure that an equivalent level of safety is 

maintained under this exemption. 

(f) Simmiarv 

(1) Rule being petitioned for exemption is 14 CFR 61.31(e). It states: 

(e) Additional training required for operating complex airplanes. 

(1) Except as provided in paragraph (e)(2) of this section, no person may act 

as pilot in command of a complex airplane (an airplane that has a retractable 

landing gear, flaps, and a controllable pitch propeller, or, in the case of a 

seaplane, flaps and a controllable pitch propeller), unless the person has— 

(i) Received .md logged ground and flight training from an authorized 

instructor in a complex airplane, or in a flight simulator or flight 

training device that is representative of a complex airplane, and has 

been found proficient in the operation and systems of the airplane; 

and 

(ii) Received a one-time endorsement in the pilot's logbook firom an 

authorized instructor who certifies the person is proficient to operate a 

complex airplane. 

(2) The training and endorsement required by paragraph (e)(1) of this section 

is not required if the person has logged flight time as pilot in command of a 

complex airplane, or in a flight simulator or flight training device that is 

representative of a complex airplane prior to August 4,1997. 
(2) Brief Description of Exemption Requested 

An exemption is requested from using retractable gear airplanes to provide training and 

endorsements under 14 CFR 61.31(e). In lieu of using retractable gear airplanes it is 

proposed to use certain fixed gear siirplanes that are equipped with the portable training 

device specified in U.S. Patent 6,638,071. 

Typical fixed gear airplanes to be used in conjunction with this exemption are those that are 

equipped with flaps and a controllable pitch propeller. 

For your convenience a copy of U.S. Patent 6,638,071 is enclosed with this petition. 

(g) Additional Information to Support Petition 

A prototype of U.S. Patent 6,638,071 was used for some remedial pilot training ordered by 

the local Flight Standards District Office in January of 2001. A favorable post training 

report was received from the Aviation Safety Counselor involved. This report can be 

provided upon request. Additionally, contact information for the Aviation Safety Counselor 

can be provided upon request. 

Currently 14 CFR 61.31(e) allows for complex airplane training to be done using retractable 

gear airplanes that have flaps and controllable pitch propeller. Also certain flight training 

devices may be used. This exemption will allow for combining the best features fi"om 

airplanes and training devices into an improved training method. 

Please note that 14 CFR 61.31(e) does allow for a pilot to obtain a complex airplane 

endorsement with no training in retractable gear operations. It does however require that 

this training be done in a seaplane. 

A field approval, FAA form 337, was obtained for Piper Dakota N2213F to hold the device 

specified in U.S. Patent 6,638,071. A copy of this paperwork can be provided upon request. 

(h) Exemption Outside of the United States 

Exercising this exemption outside of the United States is not necessary. 

Time is of the essence in this matter. Prompt processing of this petition will be greatly appreciated. 

Thank you. 

Sincerely, 

Gregg Stockman 

Certificate Number 2924400CFI 
Exhibit A - Complex Training Cost Savings 

N2213F 

PA28-236 

Trainee: Clark 

N736AZ 

R172K 

Trainee: 

Broolcs 

N736AZ 

R172K 

Trainee: Perico 

N736AZ 

R172K 

Trainee: 

Morrison 

Fuel $/hr 

Engine OH 

Allowance $/hr 

$43.55 

$13.00 

$36.85 

$11.50 

$36.85 

$11.50 

$36.85 

$11.50 

Total $/hr 

Training Time 

$56.55 

7.2 

$48.35 

5.9 

$48.35 

7.6 

$48.35 

7.3 

Actual Expense 

Rental Not Paid 

at $122/hr 

$407.16 

$878.40 

$285.27 

$719.80 

$367.46 

$927.20 

$352.96 

$890.60 

Savings $471.24 $434.54 $559.74 $537.65 

Average 

Savings $500.79 

Data Used 

Fuel Gal/hr 

Fuel $/Gal 

PA28-236 

13 

$3.35 

R172K 

11 

$3.35 

Engine TBO Hrs 2000 2000 

Engine OH Cost $26,000 $23,000 

* Because N2213F and N736AZ were privately owned, 

insurance and hanger costs are not related to hourly 

operation; therefore, these costs were excluded.