Qonff P Roi. '^f'RARTMENT OF 

• . m H ^ M , . . ;^i^S"ORWION 

Commercial Pilot and Flight Instructor if:r QpFj^^^TiQWS 

1998 Airport Loop Rd. 

Kerrville, TX 78028 ^^ v?.n | i D o 17 

Tel: 830-634-2992 Fax: 830-634-2993 ""^ ' r-" ^- U 

E-mail: Iearn2fly@ktc.com 

February 21, 2011 

U.S. Department of Transportation 

Docket Management System, 400 7th Street, SW., Room PL 401 

Washington, DC 20591-0001 

<...j% . Subject: Request for Exemption from the provisions of Title 14 CFR Seetkm9^t^9' - - -

(a) and (b) (3) for certain Beechcraft airplanes with throw-over control wheels. 1 

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, 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 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; 

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: U.S. Department of Transportation, February 21, 2011 -

Page 2 
1. The specific level of control available to a flight instructor in a Beechcraft 

Bonanza, Debonair 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 

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 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, 

February 21, 2011 - Page 3 

iMHHiM 
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 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 

Qqu|gpfi(4vi^il|^ fi^nctioning dual rudder pedals and a functioning, single, throw-oiver 

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 Scott P. Belt, holder of pilot license number 2760704, holds a 

commercial pilot's license with single and multi-engine airplane and instrument 

ratings, and a flight instructor license for single airplanes and instruments. Petitioner 

has been an active pilot since 1969 and Flight Instructor Since 2003 and has total 

flying time as a pilot of 7,554 hours with 3485 as a flight instructor. 

2. 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: Mr. Scott P. Belt. U.S. Department of Transportation, February 21, 2011 -

Page 4 
Section of 14 CFR Affected: 14 CFR 91.109(a) and (b)(3). 

Description of Relief Sought: To permit Mr. Belt 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. 

Sincerely: 

Scott P. Belt