Hilary M. Williams, III LTC USA (ret) 

Airline Transport Pilot and Flight Instructor 

1801 SW85"'Drive 

Gainesville, Florida 32607 't^ 

Tel: 352-332-3618 Fax: 352-331-4971 F- >::'^aj 

> t^-^ - E-mail: hmbuckw@gmail.Gom '~' —K/S 

December 10,2010 ^^ 3^ ^ 

U.S. Department of Transportation ~ ^^~ ^ 

Docket Management System !±I ^ 

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, Hilary M. 

Williams, III (petitioner), requests an exemption froni the provisions of Title 14 

CFR Section 91.109 (a) and (b) (3) of the Federal Aviation Regulations (FAR's) 

to allow him to conductfllght instruction in Beechcraft Bonanza and Debonair 

airplanes equipped with a functioning, single, throw-over control wheel. 

Reason for this petition: 

1. FAR 91.109(a) prohibits flight instruction, except in instrument 

instruction in single- engine airplanes under certain conditions, in 

aircraft without fully functioning dual flight controls. !n addition, FAR 

91.109 (b) (3) permits simulated instrumentflight 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 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 peri'ormed 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; since1973, 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 
U. S. Department of Transportation, December 7, 2010 

Page 2 of4 

greater level of safety than the minimal level permitted by FAR 61.45 

(c). 

Safety Considerations: 

1. The specific level of control available to a flight instructor in a 

Beechcraft Bonanza and Debonair Air 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 tQ the instruK^ in ei^er 

~ configuration as the center control cofumn 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 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. Additional pilot training and proficiency flights made possible by this 

exemption will result in more proficient pilots; 
U. S. Department of Transportation, December 7, 2010 

Page 3 of4 

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: 

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 FA/\ sponsored pilot proficiency program 

provided for in section 61.56 (a) ("Wings" program); 

c. Conducting instrument ftight training under simulated and 

actual conditions to meet the requirements of 61.67 (c) (1) and 

(d) and other requirements; 

2. Operations will be limited to Beechcraft Bonanza and Debonair 

airplanes 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 

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 Hilary M. Williams, III, holder of pilot license number 

2009446, holds an airline transport pilot's license with single and 

multi-engine airplane and instrument ratings (type rating for King Air 
U. S. Department of Transportation, December 7, 2010 

Page 4 of4 

200), and a flight instructor license for single and multi-engine 

airplanes and instruments, and ground instructor advanced and 

instrument. Petitioner also holds a commercial rotorcraft license with 

a type rating for a Sikorsky SK-64. Petitioner has been an active pilot 

since 1969 and Flight Instructor since 2009 and has total flying time as 

a pilot of 4,100 hours with 156 as a flight instructor. Petitioner also has 

over 1900 hours of military flight time during a twenty-one year career 

as a U. S. Army aviator rated in helicopters and airplanes. He currently 

instructs in Beechcraft airplanes only, and is also employed as an 

aviation safety investigator for various aviation insurance companies. 

2. Petitioner became a flight instructor in 2009 with the specific intent of 

shaww^JiNi 4inique efxoeriencft nf militarvlaimiiig^f 

investigations. He is a member of the Orlando, Florida FAASTeam and 

developed a presentation titled "Lessons Learned from Accident 

Investigations". This presentation has been given at the American 

Bonanza Society annual convention in 2009 and 2010, and in several 

locations within the Orlando FSDO region. 

3. The granting of this petition will allow the petitioner to provide recurrent 

and instrument training to his pilot clients who own Beechcraft 

Bonanza and Debonair airplanes with single throw-over controls. 

Summary for the Federal Register: 

Petitioner: Hilary M.Williams, III LTC USA (ret) 

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

Description of Relief Sought: To permit LTC Williams to conduct certain flight 

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

jind instrument experience requirements in certain Beechcraft airplanes 

T^jpjbfed with a functioning throw-over control wheel in place of functioning 

dual controls. 

Thank you for prompt consideration of this request. 

Sincerely: 

LTC Hilary M.Williams, III USA (ret)