Uwe Goehl

PO Box 50839

Hidd, Kingdom of Bahrain

E-mail: uwecavok@yahoo.com

To Whom it May Concern:

In accordance with 14 CFR §11.61, I am petitioning the Federal Aviation 

Administration for an exemption to the solo flight time requirements in 

Weight-Shift-Control Aircraft, as specified in 14 CFR §61.109 (j)(4), for the 

issuance of Private Pilot Weight-Shift-Control aircraft rating privileges, which 

is as follows:

CFR §61.109 (j)(4) Aeronautical experience- For a weight-shiftcontrol aircraft rating.

(4) Ten hours of solo flight time in a weight-shift-control aircraft, 

consisting of at least—

(i) Five hours of solo cross-country time; and

(ii) One solo cross-country flight over 100 nautical miles total 

distance, with landings at a minimum of three points, and one 

segment of the flight being a straight line distance of at least 50 

nautical miles between takeoff and landing locations; and

I am presently the holder of an Airline Transport Pilot Certificate (Airplane) 

with numerous type ratings, a Commercial Glider rating, Sport Pilot privileges 

in Weight-Shift-Control (Land) Aircraft, and over 9000 Hours of total flight 

time. I have found it an insurmountable barrier to meet the solo flight time 

requirements for this grade of pilot privileges for the following reasons:

1) No US-based flight school is willing or able to rent a weight-shiftcontrol aircraft for solo flying, primarily because of insurance 

restrictions; and

2) I am neither a US citizen nor a US resident and am therefore ineligible 

to own any US-registered aircraft to allow me to comply with the solo 

flight time requirement.

As evidenced by numerous interviews with individuals involved in this segment

of General Aviation, US-based individuals, who are not holders of a Sport Pilot 

Certificate or higher and wish to earn a Sport Pilot Weight-Shift-Control 
privileges, are expected to acquire their own Weight-Shift-Control Aircraft 

before they are able to proceed to the solo phase of their training. 

This obstacle is unusual because a Commercial grade level certificate for 

Weight-Shift-Control Aircraft does not presently exist under 14 CFR §61. For

other aircraft categories where a Commercial grade certificate exists, such as 

airplane single-engine, airplane multi-engine, helicopter, gyroplane, poweredlift or glider ratings, an applicant who wishes to add these privileges to an 

existing certificate has the option of meeting Aeronautical Experience 

requirements of the applicable paragraph (4) either with solo flight time or flight 

time performing the duties of the pilot in command in the applicable category of 

aircraft. It is reasonable to deduce that if a Commercial Weight-Shift-Control 

Aircraft rating were to exist for this class, it would have a similar requirement 

and interpretation of the Aeronautical Experience required with other aircraft 

categories and classes.

In seeking exemption of the requirement that the Aeronautical Experience 

requirements of 14 CFR §61.109 (j)(4) I propose the following Aeronautical

Experience in lieu:

1) Ten hours of solo flight time in a weight-shift-control aircraft 

registered in a foreign contracting State to the Convention on 

International Civil Aviation, with the flights having been 

conducted outside the United States, and

2) Five hours of cross-country time and one cross-country flight over 100 

nautical miles total distance with landings at a minimum of three 

points, and one segment of the flight being a straight line distance of at 

least 50 nautical miles between takeoff and landing locations to be 

completed on a weight-shift-control aircraft performing the duties of 

pilot in command in a weight-shift-control aircraft with an 

authorized instructor on board; or

3) Five hours of cross-country time and one cross-country flight over 100 

nautical miles total distance with landings at a minimum of three 

points, and one segment of the flight being a straight line distance of at 

least 50 nautical miles between takeoff and landing locations to be 

completed on a weight-shift-control aircraft registered in a foreign 

contracting State to the Convention on International Civil 

Aviation, with the flights having been conducted outside the 

United States.

Granting this request would be in the public interest because it would cause me 

to plan to travel to and spend vacation time in the United States to meet the 

remaining Aeronautical Experience requirements to apply for Private Pilot 

Weight-Shift-Control privileges. Furthermore, I would plan to train for the 
Weight-Shift-Control Sea privileges after having earned Private Pilot grade 

privileges on this category. The public benefactors would include but not be 

limited to the flight schools, flight instructors, hotels, car rental agencies, 

airlines, and restaurants that would benefit from the economic stimulus by my

activities for the duration of my travel to and stay in the United States. The

location of these activities would most likely be in Arizona, Florida and/or 

Nevada, some of which are states that greatly suffered during the recent

economic recession. 

Providing this exemption will not adversely affect safety because I already have 

a significant amount of Aeronautical Experience in Airplanes, Gliders and 

Weight-Shift Control aircraft, including hundreds of hours of solo flying and in 

cross-country operations. Furthermore, in proposing to comply with the crosscountry flight experience requirement by performing the duties of pilot in 

command in a Weight-Shift-Control Aircraft with an authorized instructor on 

board, I would be complying with a regulatory standard that is at the 

Commercial Pilot level for other aircraft categories.

I request that the FAA act favorably and expeditiously on this petition for 

exemption.

Sincerely,

Uwe Goehl

Certificate #2458187

Petitioner
Summary:

The petitioner requests that the FAA provide an exemption to the solo flight 

time aeronautical experience requirements to qualify for Private Pilot- WeightShift-Control privileges. This request is because the petitioner has found it 

impossible to access an aircraft of this class to meet the requirements. The 

petitioner proposes that a combination of flight time in aircraft of the same 

category and class, registered in a foreign contracting State to the Convention 

on International Civil Aviation with the flights having been conducted outside 

the United States the same category and class, as well as flight time while 

performing the duties of pilot in command in a weight-shift-control aircraft with 

an authorized instructor on board be accepted in lieu of the present requirement. 

The petitioner, who is an experienced pilot, believes that the granting of his 

petition will not adversely affect safety and will provide a positive economic 

effect on the communities he will visit to complete his training.