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 W eight

- S hift

- C ontrol Ai rcraft, as specified in 14 CFR §61.109 (j)(4)
, for the issuance of Private Pilot Weight

- Shift

- Contr ol aircraft r ating privileges, which is as follows:
CFR §61.109 (j)(4) Aeronautical experience

- For a weight

- shift

control aircraft rating

. (4) Ten hour s 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 W eight

- S hift

- C ontrol (Land) A ircraft , 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

- shift

control 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 se gment 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

- Controlprivileges
, are expe cted 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 W eight

- S hift

- C ontrol A ircraft 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, powered

lift or glider rating s , 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 w ith 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 W eight

- S hift

- C ontrol A ircraft rating were to exist for this class , it would have a similar requ irement and interpretation of the Aeronautical Experience required with other aircraft categories and classes.

I n 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 l ocations to be

co mpleted on a weight

- shift

- control aircraft pe rforming the duties of pilot in command in a weight

- shift

- control aircraft with an authorized instructor on board ; or 3) F ive 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 l ocations to be

co mpleted 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 theWeight

- Shift

- Control Se a privileges after having earned Private Pilot grade

privileges on this category. The p ublic 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 Stat es. The location of these activities would most likely b e in Arizona, Florida and/ or Nevada , some of which are states that greatly suffered during the recent economic recession.
Providing this exemption w ill not adversely affect safety because I already have a significant amount of Aeronautical Experience in Airplanes, Gliders and Weight

- Shift Contro l aircraft, including hundreds of hours of solo flying and in

cross

- country ope rations . Furthermore, in pro posing to comply with the cross

country flight experience requirement by performing the duties of pilot in command in a W eight

- S hift

- C ontrol A ircraft 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 r equirements to qualify for Private Pilot

- Weight

Shift

- Control privileges

. This request is because the petitioner has found it impossible to access a n aircraft of this cl ass to meet the requirements. The petitioner propos es that a combinatio n 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 an d will provide a positive economic effect on the communities he will visit to complete his training.