BIL L STERLIN G commercial Pilot and Flight instructor 

1511 River Hill Drive 

Prosper, Texas 75078-8735 

Home: 972-346-3470 

Cell: 214-729-0656 

bsterlina@teleteam.net 

http://aceoftheclouds.com 

Febmary11,2010 F/w-20/6-e/jo 

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 Trtle14 CFR Subpart B, Sections 11.21-1137, Billy Pat 

Sterling (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 ^nctioning, 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 conditbns, in aircraft without fully 

functioning dual flight controls. In addition FAR 91.109 (b) (3) pemiits 

simulated instrument flight only in single engine airplanes equipped with a 

functioning, single, throw-over control wheel. These provisions effisctively 

prohibit all flight instruction in Beechcraft Baron and TravelAir twin-engine 

airplanes with single throw-over control wheels, and also prohibK 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, pemnitted FAA personnel 

and Designated Pilot Examiners to conduct pilot certiflcation flight tests in 

aircraft not equipped with dual controls. Under the requested exemption, the 

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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 conflguratk>n. 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 Proficiency Program (BPPP) has had exemption No. 

7571 from 91.109 for many years. To the petittoner's knowledge and belief, 

the BPPP have never experienced an inckJent or accklent 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 profteiency 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 

exemptbn will result in more proficient pilots; 

4. The petitioner believes that it is in the pubtk; interest thsrt the availability of 

recurrent pilot training be maximized, consistent with acceptable safety 
practices. Maximizing such training should result in safer pilot practtees with a 

corresponding reductton 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. Performing 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 sp>onsored 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; 

d. Conducting the additional training required for operating complex 

airplanes as per 61.31 (e); 

e. Conducting the additional training required for operating highperformance airplanes as per 61.31(f); 

2. Operations will be limited to Beechcraft Bonanza, Debonair, Baron and 

TravelAir 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 medrcal certificate; 

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 Billy Pat Starting, hokler of pilot license number 1919466, holds a 

commercial pilot's Ircense with single and multi-engine airplane and 
instrument ratings, and a flight instructor license for single engine and 

instruments. Petitioner has been an active pilot since 1969 and Flight 

Instructor since 2008 and has total flying time as a pilot of 990 hours with 70. 

He currently instructs in Beechcraft airplanes and is experienced in 

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

2. The granting of this petition will allow the petitioner to provkle advanced, 

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. Billy Pat Steriing. 

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

Description of Relief Sought: 

To pennit Mr. Steriing to conduct certain flight 

instnjction to meet the additional required training for High-Perfomnance/Complex 

endorsement, instrument flights, 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 conskleration of this request. 

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