Walter Tim Miller •:-^P S 

Commercial Pilot and Flight Instructor • --' ^ocn/|ip,;,^ 

2998 E. FallentineRd ' '" ^- ^''^ 

Sandy, UT 84093 ,; , - -. or, 

Tel: 801-550-9617 Fax: 801-588-0497 ' - " - 23 

E-mail: wtimmiller@comcast.net 

January 31, 2011 

Federal Aviation Administration 

General Aviation and Commercial Division, AFS-800 

Room #835 

800 Independence Avenue, S.W., 

Washington, DC 20591 

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, Walter Tim Miller, 

CFI 3218968. (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 TravetAir 

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

Reason for this petition: .• < 

1. FAR91.109 (a) prohibits flight.instruction, except instrument instruction Insingleengine 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 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 greater level of safety than the minimal level permitted by FAR 61.45 

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Safety Considerations: 

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

Debonair, Baron and TravelAir airplanes ©quipped 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. 

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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 limitedt o: 

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. Debonair, Baron and TravelAir 

airplanes equipped with functioning dual rudder pedals and a functioning, single, throwover 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 Walter Tim Miller, holder of pilot license number 3218968, holds a 

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

and a flight instructor license for single and multi-engine airplanes and instruments. 

Petitioner is an active pilot and Flight instructor and has total flying time as a pilot of 

3,000 hours, 1,000 of which have been in Beechcraft, with 750 as a flight instructor, of 

which over 20% of each total is in multi-engine airplanes. Petitioner also is a member of 

the Salt Lake City FSDO FAA Safety Team and contributes to FAA sponsored safety 

seminars. Petitioner also instructs a number of students and pilots in [dual-control] 

Beechcraft airplanes. 

2. The granting of this petition will allow the petitioner to provide 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 RegisterPetitioner: Mr. Walter Tim Miller. 

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

Description of Relief Sought: To permit Mr. MiDer to conduct certain flight instruction and 

^a 33^d 9NI>,yw3nn. JO 3DIJ,0 ^l^,LSZZ,Z 9i:SI U,Zm,Z2 
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: 

Walter Tim Miller 

3218968 CFI exp 9/2012 

attachments: 

14 CFR 91.109 

American Bonanza Society. NPRM Comments, FAA Docket 2008-0938 

Example FAA exemption letter issued to Mr. Gerald A. Parker dated April 15, 2004 

50 ^^^=1 9Ni>iwt^3nna JO BDIJJO <^L2^LSZZ2Z 9I:ST TIBS/ST/CB 
591.109 14 CFR Ch. I (1-1-01 Edition) 

not exceed the specified weleUt limit 

fQr the restraint system; and 

(3) The restraint system must bear 

the ttppropriate labeKe). 

(b) Unless otherwl&e et&ced. this section docB not apply to operations conducted under part ISl, 125. or 135 of thlfi 

Chapter. Paraeraph Ca)0) of this section does not apply to persons subject 

to §81.105. 

[^oc. 140, 26142. 57 FE 43671, Sept. 1&, \^:i, as 

amended by Amdc 9l~25Q, fll KR 2^<i:i\, Jane 

3, 2996J 

g91.10£^ Flight inBtruction; SimulAted 

iuBtrument fliglit and curtain fli];fbt 

tests. 

(a) No person may operate a civil airCL-a.ft (except a manned free balloon) 

tha t Is belni" used for fllgrht in&truotion 

unleafi tha t al rcraft has fully Aiactionlnj dual controls. However, instrument flight Instruction may be given 

in a eingle-englne airplane eauippod 

\/llh a fllngle. functioning' throwover 

•Control wheel In place of Cixed, dual 

controls of the elevator and ailerons 

when— 

CD The Instructor has determined 

tha t the flight can be conducted safely; 

and 

(2) The person mamipulatine the controls hau ai least a private pilot cerillflcaw with appropriate category and 

clasQ railn^B, 

(b) No person may operate a civil aircraft In slmalated instrument flight 

unlesa— 

<1) The other control seat i% occupied 

by a safety pilot who po&sesses at least 

a private pilot certificate with categfory and class ratln^e appropriate to 

the aircraft beins* flov/n, 

(2) The safety pdlot has adequate vision forward and to each side of the 

aircraft, or a competent observer in Che 

airtratt adequately supplements the vision of the safety pilot; 6,nd 

(J) Except In the caae of llg:hter-thanalr aircraft, tha t aircraft is equipped 

with fully funotloning: dual controls. 

However, simulated instrument flight 

may be conducted in a aingie-engine 

airplwie. equipped with a eine-le, functioning', throwovfer control wheel, in 

place of fixed, dual controls of the elevator and allei-ons, when— 

<i) The safety pilot has determined 

that the fllffht can be conducted safely; 

and 

(li) The person manipulating the controls has a t least a private pilot cartlllcate •with appropriate category and 

clatw rating's. 

Cc) No person may operate a civil aircraft tha t is being used for a fllgrht test 

for an airline traJisport plloi certificate or a class or type rating- on tha t 

certificate, or for a part 121 proficiency 

fliB'bt test, unless the pilot seated a t 

the controls, other ihan the pilot being 

checked, is fully qualified to act £LS 

pilot in command of the alrcrafi;. 

ji «1.111 Opentiu s ""Sr other aircraft 

(a) No parson may operate an aircraft 

so close to another aircraft as to create 

a collision hazard. 

(b) No person may operate an aircraft 

in formation flight except by an-angement with the pilot in command of 

each aircraft In Che formation. 

(c) No person may operate an aircraft, carrying passent'wrs for hire, in 

formation flight. 

ilSl.llil Riglit-of-wdy rul«£: fixcopt 

water operatio&b. 

(a) Inapplicability. This section does 

not apply to the operation ol aji aircralt on water. 

(b) General When weather conditions 

permit, reffardloss of whetiher an operation is oondacted under Insti-umeut 

flight rules or visual flight rules. vlg:llance shall be maintained by each peri^on operating: an aircraft so as to see 

and avoid other aircraft. When a rule of 

this section gives another-aircraft the 

riffht-of-way. the pilot shall ^ive way 

to tha t aircraft and may not pass over, 

under, or ahead of it unloBB well clear. 

tc) In. disirtss. An aircraft in distress 

has the right-of-way over all other air 

traffic. 

Cd) Converging. When aircraft of the 

same oategrory are converging' at approximately the same altitude (axoept 

head-on, or nearly so), the aircraft to 

the other's rlsrht has the right-of-way. 

If the aircraft are of different oateg'ories— 

(1) A balloon has the rlght-of-'way 

over any other category of alrcraJt; 

(2) A ffllder has the right-of-way over 

an airship, airplane, or rotorcrafr; and 

190 

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October 14. 2009 

NPRM Comments; 

FAA Docket 2008-0938, Pilot in Command Proficiency Check and Other Changes to the 

Pilot and Pilot School Certification Rules 

RE: Proposed change to 14 CFR 91.109(a) and (b)(3) 

Good day: 

Representing neariy 10,000 owners and operators of Seech Bonanza, Debonair, Baron 

and Travel Air aircraft, the majority of whom are affected by regulations concerning 

instructional flight with single, throw-over controls, the American Bonanza Society 

supports the proposed changes to 14 CFR 91 109(a) and (b)(3). incorporation of these 

changes will enable and encourage many more pilots of single-control aircraft to obtain 

instoiction in the airplane they normally fly, making training more directly applicable to 

their day-lo-day operation and consequently improving safety of flight. 

For consistency within the regulations ABS requests the FAA consider deleting 14 CFR 

61.45(e)(2). This regulation gives pilot examiners authority to decide whether to conduct 

practical teste in single-control airplanes, but it rescfnds this examiner authority if the 

practical lest involves a demonstration of Instrument skills. Instrument flight instruction is 

already penmitted under 91.109, and this NPRM makes it clear FAA teels instruction is 

appropriate in single-control aircraft under most conditions, tt's contradictory, then, to 

prohibit practical tests for the Private and ATP certificates and the Instrument rating (as 

well as including instrument privileges when adding a IVIuitiengine rating), all of which 

require a demonstration of instrument flying skills. Deleting 61.45(e)(2) would empower 

pilot examiners to administer these practical tests in single-control airplanes at the 

examiner's discretion. 

To further encourage type-specific training and thereby Improve safiety, ABS requests 

the FAA address other common training scenarios by amending the proposed change to 

91.109(b)(3)Ov)toread; 

The pilot naaoipulaiing the contxola of au aiipJane -with oiHy a single fuuctiojiiog, 

tlirowovcu' control -wheel ijmst be qualified to, aiid sci've as, pilot in coiiimaiid of the 

airplEiiie, 

A) except tliat tlie pilot receiving instruclion need not meet th« additional 

traliung requLiements for opeiating complex or iiigb peiibnn&i'ice. airciaft 

under 14 CFR 61.31e and 61.31t respectively, if the fliglit insmictioti is 

being conducted wholly or in part for tlie purpose of fulfilling diese 

Teqiuiemeuts, and/or 

B) unless the pilot receiv'uig instruction is not qualified to net us pilot iii 

command solely because of flight review ajid/oi roceiit flight <»cperience 

P.O. Box 12a88 Wiohittt, Kansas 67277 316-&45-1700 fax 31(3-945-1710 B^^maJlfaijpnanziti.prF 

9HI.»Q TM .• 30I,,0 SiBSiBSJBS 9X:ST Tia^/BI/.B 
lequiiemonts under 14 CFR 61.56 aiid/or 61.57, if tfie tlight instnictioa is 

boing conducted wholly oi in part for flie puipose of fulfilling these 

jvquiiementB. 

These amendmerrfs would allow pilots to obtain initial complex and high performance 

instruction in the same single-control airplanes they will routinely fly. They would also 

permit pilots whose recent experience has lapsed to receive instruction to restore 

cun'ency. In all cases safety-of-fiight is not compromised because the instructor pilot 

would meet FAA's proposed experience requirements to provide instruction in singlecontrol aircraft. 

Lastly, since the Type Certificate Data Sheet (TCDS) very narrowly limits the term 

"moder to be a single subvariant of a basic airframe design, most frequently limited 1o a 

single production year of a type, we ask the FAA amend the proposed 9l.109(b)(3)(v)(B) 

to read: 

Have logged at least 25 hours of pilot i}t conunaud flight liuie in diatinoke aud model of 

airplane witli a single, fuiictioming tinowover control wheel involved. For pmposes of 

tliis icquiremem ^^model" is defined as ail versions of a manufactuiei's type or series in 

die same class of aircraft. 

Since in most cases the TCDS identifies "model" as a single year's production variaition, 

and in the case of ABS airplanes multiple TC numbers apply to airplanes with nearty 

identical cockpit layout (i.e., A-777 and 3A15 for Bonanzas and Dabonairs, 3A16 and 

A23CE for Travel Airs and Barons), this would permit an instructor meeting the 

experience requirement In one version of the Bonanza or Debonair, for instance, to 

provide instruction in a different model year of the same aircraft type. The class 

restriction differentiates between single- and multiengine models. 

Thank you forthe proposed changes to 14 CFR91.109, and your consideration of our 

suggestions. Together they will further improve instructional safety and relevance, and 

provide consistency between Parts 61 and 91. 

Respectfully 

Thomas P. Turner 

Manager of Technical Services 

P.O. Box 12888'Wiabita, Kttnaas 67277 316-945-1700 fax 316-945-1710 >ib«niaL[fgl;boTiftnia.Qfp 

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April 15, 2004 

Exemption No. 8294 

Regulatoi-y Docket No. FAA-20Q4~17406 

Mr. Gerald A. Parker 

4022 Arnold 

Houston. TX 77005 

Dear Mr. Parker: 

By letter dated March 23, 2004, you petitioned the Federal Aviation Administration (FAA) 

for ail exemption from § 9M09(a) and (b)(3) of Title 14, Code of Federal 

Regulations (14 CFR). This exemption, if granted, would allow you to conduct certain flight 

training and to provide simulated instrument flight cxpcvience in certain Beech airplanes that 

aic equipped with a functioning tluowover control wheel. 

The FAA issued a grant of exemption in circumstances similai" in all material respects to 

those presented in your petition. In Grant of Exemption No. 6156 (copy enclosed), the FAA 

found that Mr. Geitz is an experienced flight instrtictor with many years of instruction using 

a throwover control wheel. Also, Mr. Geiti narrows the request in the petition to allow him 

to provide flight traiiiing to meet recency of experience requirements ferreted pilots only. 

Duiing the entire training period, the pilot receiving the training must serve as and remain 

pilot in command (PIC) and agree to the provisions of this exemption. Mr. Geiiz must be 

fully qualified to serve as PIC and as a flight instructor in Beech Baron, Boiian2:a, or Travel 

Air type airplanes and must have given at least 25 hours of dual instruction in that type of 

airplane. However, under the provisions of this exemption, ti'aining of uncertificated airmen 

may not be conducted at any time. 

The FAA determined that with certain conditions and limitations, the flight training can be 

conducted while maintaining a level of safety equivalent to that provided by the affected 

regulation. 

Having reviewed your reasons for requesting an exemption, 1 find that they do not differ 

materially firom those presented by.the petitioner in the enclosed grant of exemption. In 

addition, I have determined that the reasons stated by the FA A Ibr granting the enclosed 

exemption also apply to the situation you present. 

AFS-04-31 7 

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In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

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

me by the Administrator, Gerald A. Parker is granted an exemption from 14 CFR §91.109(a) 

and (b)(3) to the extent necessary to allow him to conduct certain flight training and to 

provide simulated instrument flight experience in certain Beech airplanes that are equipped 

with a functioning Ihiowover control wheel. This exemption is subject to the following 

conditions and limitations: 

1. Operations under this exemption are limited to flights for completion of the flight 

review required by § 61.56 and for accomplishing recency of experience as 

required by § 61.57. 

2. Operations under this exemption are hniited to Beech Baron, Bonanza, Debonair, 

and Travel Air type feurplanes equipped with a functioning thiowover control wheel 

and operable rudder pedals, in lieu of funcLioniiig dual control; IS. 

J . The pilot inaaipulating the controls under the terms of this exemption must be 

qualified iii every respect to serve as PIC of the airplane during the entire flight. 

While operating under this exemption, the pilot sealed in the left seat must at all 

times serve as and remain PIC as defined in 14 CFR § 1.1. The PIC must agree to 

die provisions of this exemption. 

4. While serving as a flight instructor under the terms of this exemption, 

M I. Parker must: 

a. Notwithstanding paragraph 4(b) below, be otherwise fully qualified to 

serve as PIC and flight instructor in the airplajie involved, as required by 

14 CFR § 61.195(b) and (f); and 

b. Have given at least 25 hours of dual instruction in the airplane involved. 

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5. Mr. Parker, when serving as the flight instructor under the conditions of this 

exemption, and the PIC must agree that the proposed flight, under the conditions in 

evidence at the time of proposed flight, can be conducted safely. 

This exemption terminates on April 30. 2006, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

Steven W. Douglas 

Acting Director, Flight Standards Service 

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