Jamos Rayvon Williams 

Commercial Pilot and Flight Instructor 

108 Bordeaux Lane '•-,zPARTMENT OF 

Scotts Valley. California 95066 1^^^''^P^RTATI0N 

Tel: 831 439 8597 Fax: 831 438 3159 ' " - ' 

E-mail: cfii@straight-and-leveL com 

September 1, 2010 

OKH OPEB/aiONS 

m SEP -8 P 3- lb 

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 T|t)e/14 CFR Subpart B, Sectjons 11.21 -1137. James Rayvon _ 

^NMMili^0l&e^m»r), f^yjestft an exemption firom the provisions of Title 14 CFR Section 

91.109 (a) and (b) (3) of the Fecteral Aviation Regulations (FAR's) to allow him to 

conduct flight instruction in Beechcraft Bonanza and Defc>onair 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 Beechcriaft Bonanza and Debonair 

airplanes with single throw-over control wheels, and also prohibit simulated instrument 

flight in these airplanes; 

2. FAR 61.56 requires flight instruction to be perfonned as part of a required flight 

review. Under current regulations this flight review cannot t^e 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 aircrafft 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 control available to a flight instructor in a Beechcraft Bonanza and Debonair 

aircraft equipped with a throw over control wheel is quite good. The control configuration 

ensures the instructor ALWAYS has full use of rudder control. The instructor's access to 

aircraft engine controls is unaffected by the type of control wheel installed. Full elevator 

control is continuously available in either configuration as the center control column is 

easily accessible 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; 

>»*-»iU>;i, 
James Rayvon Williams 

Commercial Pilot and Flight Instructor 

108 Bordeaux Lane 

Scotts Valley. California 95066 

Tel: 831 439 8597 Fax: 831 438 3159 

E-mail: cfii@straight-and-level. com 

U.S. Department of Transportation, Septeml>er 1, 2010 - Page 2 

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. The petitioner has attended BPPP and obtained instruction 

five (5) times since 2001; 

3. Therefore, in view of the facts presented atx)ve and the experience of the FAA and 

other groups to date, it is reasonable to conclude that flight safety will not be 

comprpmisedLby granting this exernption 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 vtnth 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 v^h 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. Performir^ 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 equipped 

with functioning dual rudder pedals and a functioning, single, throw-over control wheel; 
James Rayvon Williams 

Commercial Pilot and Flight Instructor 

108 Bordeaux Lane 

Scotts Valley, California 95066 

Tel: 831 439 8597 Fax: 831 438 3159 

E-mail: cfii@straight-and-level. com 

U.S. Department of Transportation, September 1, 2010 - Page 3 

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. f^iiSoner Jsiines Rayvui WUtiams, holder of pilot certificate nimnber 2677^^5CR, ^ w- .%j^*^i 

holds a commercial pilot's certificate with single and multi-engine airplane and 

instrument ratings, and a flight instructor certificate for single airplanes and instruments. 

Petitioner has been an active pilot since 1999, a Flight Instructor since 2001 and has 

total flying time of 2,000 hours with 400 as a flight instructor. He currently serves as a 

FAA Safety Team representative (San Jose FSDO) and has experience with over 1,000 

hours in Beechcraft single control airplanes with a throw-over control wheel; 

2. The granting of this petition will allow the petitioner to provide recurrent and 

instrument training to pilots who own Beechcraft Bonanza and Detjonair airplanes with 

single throw-over controls. 

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

Summary for the Federal Register: 

Petitioner: James Rayvon Williams 

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

and instrument flights to meet the recent experience, flight review, and instrument 

experience requirements in certain Beechcraft airplanes equfpped with a functfoning 

throw-over control wheel in place of functioning dual controls. 

Thank you for prompt consideration of this request. 

Sincerely: 

James Rayvon Williams 

Cc: San Jose FSDO, Operations