Michael W. Headrick 

Commercial Pilot and Flight Instructor 

3004 Windstone Ct 

Bedford, TX 76021 

Tel: 817-807-0645 Fax: 817-571-4276 

E-mail: Cptcloud@aol.com 

May 3, 2010 

U.S. Department of Transportation 

Docket Management System, 

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, Michael W. 

Headrick(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 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 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. 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, since 1973, pemiitted 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: 

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

Bonanza, Debonair, Baron and TravelAir 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 sufticient 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 tjoth 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. 

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. Perfomriing 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 

airpanes 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 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 fiight; 

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 Michael W.. Headrick, holder of pilot license number 2760689, holds 

an airline transport pilot and commercial pilot's license with single and multiengine airplane and instrument ratings, and a flight instructor license for single 

and multi-engine airplanes and instruments. Petitioner has been an active pilot 

and Flight Instructor since 1990 and has total flying time as a pilot of 7,823 hours 

with 1,213 as a flight instructor, of which slightly over 60% of each total is in 

multi-engine airplanes. He currently instructs in 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 Register: 

Petitioner: Mr. Michael W. Headrick. 

Section of 14 CFR Affected: 14 CFR 91.109(a) and (b)(3). 
Description of Relief Sought: To permit Mr. Headrick 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: , / j 

Michael W. Headrick