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## OPERAT\01';) Richard P. Veach

- Airline Transport Pilot and Flight Instructor 

## crp \ I ,tA 

## S: 05 483 Oak LeafTrail 

## 1'.e\Z 't:. Suwanee, Ga 30024

Tel: 678-516-7822 E-mail: roveach@hotmail.com September2na. 2012

U.S. Department ofTransportation Docket Operations, M-30, West Building groundfloor, Room W12-140 1200 New JerseyAvenue, SE Washington, DC 20590
Subject: Requestfor Exemption from the provisions ofTitle 14CFR Section 91.109 (a) and (b) (3) for certain Beechcraft airplanes with throw-overcontrol wheels. Underthe provisions ofTitle14 CFR Subpart B, Sections 11.21-1137, Richard P. Veach (petitioner), requests an exemption from the provisions ofTitle 14CFR Section 91.109 (a) and (b) (3) ofthe Federal Aviation Regulations (FAR's) to allow him to conductflight instruction in Beechcraft Bonanza, Debonair, Baron, and TraveiAir airplanes equipped with
a functioning, single, throw-over control wheel.

Reason forthis petition: 1. FAR 91.109 (a) prohibits flight instruction, except instrument instruction in single-engine airplanes undercertain conditions, in aircraft withoutfully functioning dual flight controls. In addition FAR 91.109 (b) (3) permits simulated instrumentflight only in single engine airplanes equipped with a functioning, single, throw-overcontrol wheel. These provisions effectively prohibit all flight instruction in Beechcraft Baron and TraveiAirtwin-engine airplanes with single throw-over control wheels, and also prohibit simulated instrumentflight in these airplanes. The cockpits of Beechcraft Baron and TravelAir airplanes are virtuaffy identical in configuration and layoutto the Beechcraft Bonanza/Debonair airplanes;

2. FAR 61.56 requires flight instruction to be performed as part ofa 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. Underthe requested exemption, the petitionerwill operate at a greater level ofsafety than the minimal level permitted by FAR 61.45 (c).
Safety Considerations: U.S. Department ofTransportation, September2, 2012 -Page 21. The specific level ofcontrol available to a flight instructor in a Beechcraft Bonanza, Debonair, Baron and TraveiAir airplanes equipped with a throw overcontrol wheel is quite good. The control configuration is such that the instructorALWAYS has full use of rudder control in flight. The instructor's access to all engine controls ofthe aircraft is unaffected by the type ofcontrol wheel installed. Full elevatorcontrol is continuously available to the instructor in eitherconfiguration as the centercontrol column ofthe airplane is easily accessible to the instructor in a throw-over configuration. Manipulation ofthe center control column affords the flight instructorfull elevator control asthe elevatorcontrol column is located in the center ofthe control panel with unobstructed access. Aileron control is also within easy reach ofthe instructor (although in front ofthe 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 manyyears. To the petitioner's knowledge and belief, the BPPP have never experienced an incident oraccident related to the conduct oftraining in an airplane with a throw-over control wheel;

3. Therefore, in view ofthefacts presented above and the experience ofthe FAA and other groups to date, it is reasonable to conclude thatflight safety will not be compromised by granting this exemption request.

The interests ofthe public are served by this exemption in thefollowing ways: 1 . The primary purpose ofthis 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 overallsafety;

2. By allowing pilots to train in their own aircraft ratherthan renting an aircraft with fully functioning dual controls, such pilots are more likely to seek neededtraining in both visual and instrumentflight;

3. Additional pilot training and proficiencyflights made possible by this exemption will result in more proficient pilots;

4. The petitioner believes that it is in the public interestthatthe 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 ofthe exemption to the public and to society: None Regulatory burden ofthe exemption: None. U.S. Department ofTransportation, September 2, 2012- Page 3Effect ofthis exemption on ofthe quality ofthe natural and social environments: None The following operational conditions are proposed forthe requested exemption: 1. Operations underthe exemption will be limited to:
a. Performing the flight review required by 14 CFR Section 61.56 (a); b. Conducting the training necessaryto accomplish one ormore phases ofan FAA sponsored pilot proficiency program provided for in section 61.56 (a) ("Wings" program);
c. Conducting instrumentflight training undersimulated and actual conditions to meetthe requirements of61.67 (c) (1) and (d) and other requirements;

2. Operations will be limited to Beechcraft Bonanza, Debonair, Baron and TraveiAir airplanes equipped with functioning dual rudder pedals and a functioning, single, throw-over control wheel;

3. Pilots receiving training will possess a private orhigher pilot license with the appropriate ratings forthe 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 underthe provisions ofthis exemption, will be fully qualified to serve as PIC and asflight instructor, as required by FAR 61.67 (c) (1) and (d) and FAR 61.195 (b) and (f).

Petitioner's pilot qualifications: 1. Petitioner Richard P. Veach, Airline Transport Pilot, CFI, CFII, MEl, certificate number 1474649, Petitioner has been an active pilot since 1959 and Flight Instructor since 2004 and has total flying time as a pilot of29,829 hours with 2,062 as a flight instructor in ASEL and MEL. Total time in multi-engine airplanes is 27,752 hours.

2. The granting ofthis petition will allowthe petitionerto provide recurrent and instrument training to his pilot clients who own Beechcraft Bonanza, Debonair, Baron, and TraveiAir airplanes with single throw-overcontrols.
Summary forthe Federal Register: Petitioner: Mr. Richard P. Veach, U.S. Department ofTransportation, September2, 2012, Page4

Section of 14 CFR Affected: 14CFR 91.109(a) and (b) (3). Description of Relief Sought: To permit Mr. Veach to conduct certain flight instruction and instrumentflights to meetthe 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 ofthis request.

# ~6:~ Richard P. Veach