... 

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 of Transportation Docket 

Management System, 400 7th Street, SW., Room 

PL 401 Washington, DC 20591-0001 

',;,'.\~' •; ''I ') L~l CJ '/: 0? -- J Jdlf ,:,. i I .... "'"" 

Re: 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 -1 137, Bradford A. Docos (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 

TraveiAir 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 single-engine 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 TraveiAir twin-engine airplanes with single throw-over control wheels, and also prohibit simulated 

instrument flight in these airplanes. The cockpits of Beechcraft Baron and TraveiAir 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 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. 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 

TraveiAir 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 instr.uctor 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 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 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. 

U.S. Department of Transportation 

June 6, 2013 

Page 1 of 3 
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 throwover 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 and is 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 environment: None. 

The following operational conditions are proposed for the requested exemption: 

1. Operations under the exemption will be limited to: 

a. Performing the flight review required by 14 CF:R 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 ~eechcraft 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 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 Bradford A. Docos, holder of commercial pilot license number 3037068, 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, and has total flight time of 

approximately 2,600 hours PIC, half of those hours have been in Beechcraft single and multi-engine 

piston and turbine aircraft. 

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 TraveiAir airplanes with single throw-over 

controls. 

U.S. Department of Transportation 

June 6, 2013 

Page 2 of 3 
Summary for the Federal Register: 

Petitioner: Mr. Bradford A. Docos. 

Section of 14 CFR Affected: 14 CFR 91.1 09(a) and (b)(3). 

Description of Relief Sought: To permit Mr. Docos to conduct certain fight 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 

Bradford A. Docos 

C:\Documents and Settings\brad\Desktop\Throw over letter. doc 

U.S. Department of Transportation 

June 6, 2013 

.! 

I 

Page 3 of 3