w:\iimi OF 

NSPORWION 

-T OPERATIONS \ . . i 

Richard P. Veach 

Airline Transport Pilot and Flight Instructor 11-7 in A O: "3? 

483 Oak Leaf Trail ^ .^i t M > j ^ 

Suwanee, Ga 30024 

Tel: 770-887-1986 

E-mail: rpveach(Q)ho{mail.com 

November 2. 2010 

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-airptenes with throw-over control wheels. 

Under the provisions of Title14 CFR Subpart B, Sections 11.21-1137. Richard P. Veach 

(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 

instmction in Beechcraft Bonanza, Debonair. Baron, and TravelAir 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 flinctioning, single, throw-over control wheel. These provisions 

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

airplanes with single throw-over control wheels, and also prohibit 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 a 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 conduci: pilot certification flight tests in airaaft 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: U.S. Department of Transportation, November 2, 2010 - Page 2 
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 ftjil 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 instmctor in a throw-over configuration. Manipulation of the center control 

column affords the flight instructor full elevator control as tiie elevator control column is 

located in the center of Vne control panel wiUi 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 thepetitioner's knowledgearKl belief, theBPPP havenever 

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. 

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 cunrency and instrument proficiency training 

to ensure their proficiency, currency, and overall safety; 

2. By allowing pilots to train in their own airaaft ratiier than renting an aircraft with fully 

functioning dual controls, such pilots are more likely to seek needed training in both visual 

and instrument fiight; 

3. Additional pilot training and proficiency flights made possible by this exemption will result 

in more proficient pilots; 

-AJThepetitiomr^bMsvesJhaL^isjnJhe publicjnterest that the jvailabj[ity of recurrent^ilot 

training be maximized, consistent with acceptable safety practices. Maximizing such training 

should result in safer pilot practices wiUi a corresponding reduction in the likelihood of 

aviation accidents. 

Identifiable costs of the exemption to tiie public and to society: None 

Regulatory burden of the exemption; None. U.S. Department of Transportation, November 

2, 2010-Page3 
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 

sponsored pilot proficiency program provided for in section 61.56 (a) ("Wings" program); 

c. Conducting instrument fiight 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, Debonair, Baron and TravelAir 

airplanes equipped with fijnctioning dual rudder pedals and a ftjnctioning, single, throw-over 

control wheel; 

3. Pilots receiving training will possess a private or higher pilot license with the appropriate 

ratings for the airplane floWf^.^arRTa current medical certificate, and will tje fully qualified to 

serve as PIC for the entire flight; 

4. The petitioner, when acting as an authorized instiuctor under the provisions of this 

exemption, will be fully qualified to serve as PIC and as flight instiuctor, as required by FAR 

61.67 (c) (1) and (d) and FAR 61.195 (b) and (f). 

Petitioner's pilot qualifications: 

1. Petitioner Richard P. Veach, Airiine Transport Pilot, CFI, CFII, MEI, certificate 

number 1474649, Petitioner has been an active pilot since 1959 and Flight Instructor 

since 2004 and has total flying time as a pilot of 29,720 hours with 2,026 as a flight 

instructor in ASEL and MEL. Total time in multi-engine airplanes is 27,719 hours. 

2. The granting of this petition will allow the petitioner to provide recunrent 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. Richard P. Veach, U.S. Department of Transportation, November 2, 2010, 

Page 4 

Section of 14 CFR Affected: 14 CFR 91.109(a) and (b) (3). Description of Relief Sought: To 

permit Mr. Veach to conduct certain flight instiuction and instiument 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: 

Richard P. Veach