Mario R. Sotolongo 

ATP and Flight Instructor FiH; ii^ f; 

4373 Ford Rd. 

Ann Arbor, MI 48105 ' ' ^ '• 5'^ 

Tel: 734-717-5570 

Email: raarsotol^^comcast net 

May 9, 2011 ^ 

Federal Aviation Administration 

Flight Standards District Office 

8800 Beck Road 

Belleville, MI 48111 

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 Title 14 CFR Subpart B, Sections 11.21-1137, Mario R 

Sotolongo (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 aUow 

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 

single-engine 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 a 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: 
Federal Aviation Administration, May 9,2011 - 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 throwover 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 ako 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; 

4) The petitioner believes that it is in the pubUc 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. 
Federal Aviation Administration, May 9,2011 - Page 3 

Regulatory burden of 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 FAA sponsored pilot proficiency program provided for in 

section 61.56 (e) ("Wings" program); 

c) Conducting instrument flight training under simulated and actual 

conditions to meet the requirements of 61.57 (c ) (1), (6) (d) and other 

requirements; 

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

TravelAir airplanes 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 fuUy qualified to serve as PIC and as fiight 

instructor, as required by FAR 61.57 (a), (b), (c), and (d). 

Petitioner's pilot qualifications: 

1) Petitioner Mario R. Sotolongo, holds an Airline Transport Pilot Certificate 

number 1642252, with airplane multiengine land, A-320; A-330; B-757; 

B-767; CV-A340; CV-A440; DC-9; DC-10; commercial privUeges and 

airplane single-engine land. Petitioner holds a GOLD SEAL flight instructor 

certiflcate for airplane single and multi-engine; instrument airplane (expires: 

30 APR 2013). Petitioner has been an active pilot and flight instructor since 

1965 and has over 22,400 total flight hours of which 3,200 are in singleengine airplanes. Petitioner is a retired airline captain and a former 

instructor/check airman with 14 years experience, has over 4,500 hours in 

advanced flight simulators, experience in heavy aircraft training, initial 

operating experience, line checks and aircraft acceptance flight tests. 

Petitioner worked close with the FAA qualifying pilots for type ratings and 

initial qualifications. 

2) Since 2003, the petitioner has continuously owned and operated an S-35 

Beechcraft Bonanza with a functioning, single, throw-over control wheel. 
Federal Aviation Administration, May 9,2011 - Page 4 

3) In 1982 the petitioner was chosen by his airline to provide DC-9 flight 

training under contract to a new start-up airline based in Mexico. He was 

issued a permit to act as an instructor/check airman by Mexican authorities. 

4) The petitioner has always been involved in air safety: as accident 

investigator, air safety chairman and a member of various industry 

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

recurrent and instrument training to pilots who own Beechcraft Bonanza, 

Debonair, Baron, and TravelAir airplanes with single throw-over controls. 

Summary for the Federal Register: 

Petitioner: Mario R. Sotolongo 

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

Description of Relief Sought: To permit Mr. Sotolongo 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 your prompt consideration of this request. 

Sincerely, 

Mario R. Sotolongo