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BRADFORD 

### A. Docos, CFI, CFII, MEl, AGI, IGI 9603 SAVANNAH CROSSING COURT VIENNA, VIRGINIA 2 2 1 8 2 703-403-3440 June 6, 2013 U.S. Department ofTransportation Docket Management System, 400 7th Street, SW., Room PL 401 Washington, DC 20591-0001

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Re: Requestfor Exemptionfrom the provisions ofTitle 14 CFR Section 91 .109 (a) and (b) (3) for certain Beechcraft airplanes with throw-over control wheels. Underthe provisions ofTitle14 CFR Subpart B, SeCtions 11.21 -1 137, Bradford 

### A. Docos (petitioner), requests an exemption from the provisions ofTitle 14 CFR 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 afunctioning, single, throw-over control wheel. Reason forthis petition: 1. FAR 91.109(a) prohibits flight instruction, except instrument instruction in single-engine airplanes under certain conditions, in aircraftwithout fullyfunctioning dual flight controls. In addition FAR 91.109(b)(3) permits simulated instrumentflight only in single engine airplanes equipped with afunctioning, single, throw-over control 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 TraveiAir airplanes arevirtually identical in configuration and layoutto the Beechcraft Bonanza/Debonair airplanes; 2. FAR 61.56 requires flight instruction to be performed as part ofan flight, review. Under current regulations this flight review cannot be performed in multi-engine airplanes with throw-over control wheels;
I 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 petitioner will operate ata greater level ofsafetythan the minimal level permitted by FAR 61.45 (c). Safety Considerations: 1 The specific level ofcontrol available to aflight instructor in a Beechcraft Bonanza, Debonair, Baron and TraveiAir airplanes equipped with a throw over control wheel is quite good. The control configuration is such thatthe instructor ALWAYS 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 elevator control is continuously available to the instructor in either configuration as the center control column ofthe airplane is easily accessible to the instr.uctor in a throw-over configuration. Manipulation ofthe center control · column affords theflight instructorfull elevator control as the elevator control 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 sufficientto allow any additional control inputs necessary during flight; 2 The Beechcraft Pilot Proficien9y Program (BPPP) has had exemption No. 7571 from 91 .I 09 for many years. To the petitioner's knowledge and belief, the BPPP have neverexperienced an incident oraccident related to the conduct oftraining in an airplanewith a throw-over control wheel; 3 Therefore, in view ofthe facts presented above and the experience ofthe FAA and other groups to date, it is reasonable to conclude thatflight safetywill not be compromised by granting this exemption request.

U.S. Department ofTransportation June 6, 2013 Page 1of 3The interests ofthe public are served by this exemption in thefollowing ways: 

### 1. The primary purpose ofthis requested exemption is to encourage pilots of Beechcraft aircraftwith throwover control wheels to seek currency and instrument proficiencytraining to ensure their proficiency, currency, and overall safety; 2. By allowing pilots to train in their own aircraft rather than renting an aircraftwith fullyfunctioning dual controls, such pilots are more likely to seek needed training in both visual and instrumentflight; 3. Additional pilottraining 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 pilottraining be maximized and is consistentwith acceptable safety practices. Maximizing such training should result in safer pilot practices with a corresponding reduction in the likelihood ofaviation accidents. Identifiable costs ofthe exemption to the public and to society: 

### None. Regulatory burden ofthe exemption: 

### None. Effect ofthis exemption on ofthe quality ofthe natural and social environment: 

### None. Thefollowing operational conditions are proposed forthe requested exemption: 

### 1. Operations underthe exemption will be limited to: a. Performing the flight review required by 14 CF:R Section 61.56 (a); b. Conducting the training necessaryto accomplish one or more phases ofan FAA sponsored pilot proficiency program provided for in section 61.56(a) ("Wings" program); c. Conducting instrumentflight training under simulated and actual conditions to meetthe requirements of 61.67 (c)(1) and (d) and other requirements; 2. Operations will be limited to**~eechcraft** 

### Bonanza, Debonair, Baron and TraveiAir airplanes equipped with functioning dual rudder pedals and afunctioning, 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 forthe entire flight; 4. The petitioner, when acting as an authorized instructor underthe provisions ofthis 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 Bradford 

### A. Docos, holder ofcommercial pilot license number 3037068, with single and multiengine airplane and instrument ratings, and a flight instructor licensefor single and multi-engine airplanes and instruments. Petitioner has been an active pilot and Flight Instructor, and has total flight time of approximately 2,600 hours PIC, halfofthose hours have been in Beechcraft single and multi-engine piston and turbine aircraft. 

### 2. The granting ofthis petition will allowthe petitionerto provide recurrent and instrumenttraining to his pilot clients who own Beechcraft Bonanza, Debonair, Baron, and TraveiAir airplanes with single throw-over controls.

U.S. Department ofTransportation June 6, 2013 Page 2 of 3Summaryforthe Federal Register: Petitioner: Mr. Bradford 

### A. Docos. Section of 14 CFRAffected: 14 CFR 91.109(a) and (b)(3). Description of Relief Sought: To permit Mr. Docos to conduct certain fight instruction and instrument flights to meetthe recent experience, flight review, and instrument experience requirements in certain Beechcraft airplanes equipped with afunctioning throw-over control wheel in place offunctioning dual controls.
Thank you for prompt consideration ofthis request. Sincerely

Bradford 

### A. Docos

C:\Documents andSettings\brad\Desktop\Throwoverletter.doc

U.S. Department ofTransportation June 6, 2013 

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