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201 Lone Man Overlook 

Wimberley, Texas 78676 J ] :>^ :D \- [i l 

512-847-0174 

April 12,2011 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor W12-140 

1200 New Jersey Avenue, SE 

Washington, D.C. 20590 

REF; Petition for Rulemaking 

Dear Sirs: 

I wish to petition the U.S. Departmenl of Transportation for a change to the following 

described rule: 

Code of Federal Regulations, 14 CFR 61.197 (2)(ii); 

Renewal of flight instructor certificate; 

Under 14 CFR 11.63 and 14 CFR 11.71,1 wish to submit the following information basis 

for my proposal... 

(A)(1) Name and address: William R. Wallace 

201 Lone Man Overlook 

Wimberley, Texas 78676 

512-847-0174 

(2) The Code \4_ CFR 61.197 part (2)(ii'): not explicit enough and does not include 

a person who is a highly qualified type-rated jet flight and/or simulator instructor 

under a Part 142 flight school program who instructs both under FAR 9IK, 135, 

and 121 programs. These instructors would be employed by Flight Safety and 

CAE- SimiFlight, for example. 

That instructor not only has to be qualified under 14CFR 142.53(a)(7), but also 

the instructor individual has to have to teach under Part 135 customer guidelines, 

(i.e.American Jet, Netlets, FlexJet). 

The instructor would also have a current Part 135.293(a), and Part 135.297 check 

ride under the operator's certificate, but also the Part 142 flight school. 

In addition he or she would have to be trained to teach in the simulator 

per individual certificated Ops Specs for RNAV (GPS) approaches, reduced 

landing minimums, and lower-than-standard takeoff minimums. He could also be 

qualified to teach avionics cockpit- based-trainer and aircraft systems 

ground school. 
The FAR 142 approved flight facility usually has programs whereby they 

instruct: FAR 61.58 PIC Initial and Recurrent training, FAR 61.55 SIC Initial 

and Recurrent training. FAR 135, FAR 121 PIC/SIC Initial and Recurrent 

trainmg; usually based evaluation intervals of six (6) or twelve (12) time 

periods. 

The instructor has to sign training records (electronically) indicating the students 

completion of a individual phases of ground and simulator instructionleading up to a check ride with a designated TCE or check airman in-house 

within the training department. 

The instructor is in the position of regular evaluation of pilots in his capacity, 

but not necessarily giving the actual check ride. 

(3) 14CFR 61.197 Renewal of flight instructor certificates should state: 

(H) A record showing that, within the preceding 24 months, the flight instructor 

has served as a company check pilot, chief flight instructor, company check 

airman, or flight instructor in part 121, J3S, 142, or 91K training operations, or 

in a position involving the regular evaluation of pilots, or; 

(4) It would be in ihe public interest to include the instructor in the FAA approved 

Part 142 flight school. That individual instructor now comprises most of the 

experience and knowledge that is necessary in a new modem environment with 

Phase III all-motion simulators used in 99% of training used with most of the 

major Fortune 500 companies and domestic and international airlines. That 

training comprises.over 35 or 40 makes and models of prop, turbo-prop, £ind jet 

aircraft; including the Lear Jet series, Boeing Jet series, Gulfstream series, 

Beechcraft series aircraft, and up to and including the new Airbus A-380. 

FAR 142 flight schools include helicopters as well. Individual Far 61 instructors 

teach the basics with student pilots, private, commercial, instrument ratings, etc. 

The FAR 142 instructors are the next step in the progression of aviation training. 

(5) As previously stated. 

(6) As previously stated. 

(b.)(l) There will be DO additional cost or impact to the general public. The 

instructor still has to follow the prescribed renewal procedure with the FAA 

every twenty-four (24) months as before. 

The FAA will still follow all guidelines for renewal including all airman 

personal identification relating to TSA rules with no changes in this process. 
(b.)(2) There is no additional burden placed on small business, small 

organizations, small government jurisdictions, and Indian tribes. 

The general public will actually save money in the ling run: The training 

facilities will be able to utilize that instructor for several additional days in 

house -VS-. the two (2) day approved refiresher course 

needed at a total cost of about $1200. (2 days salary, travel, motel, food 

expenses, and course fee) which is probably paid for, down-the-line, by the 

training client which passes it on to the consumer. 

For example, if there were a total of 600 instructors that could utilize the FAR 

142 rule change, that would be a total of about $780,000 dollars 

indirect.savings for two years. 

We allow companies to print FAA exam guides giving questions and answers 

to written tests used in flight training, why not allow improved procedures 

for the renewal process. 

(b)(3) There would be no additional recordkeeping and reporting burdens with this 

proposed action. 

There could be possibly some government FAA savings also 

because of the reduced burden of renewal and recordkeeping. 

(b)(4) The quality of the social environment would be improved through a long 

over-due rule change affecting the time and effort saved by individuals during 

this process. 

Respectifiilly Submitted 

%,m^f.UWs^ 

WILLIAM R. WALLACE