FAA Proposal on Landing Area Requirements (USPA Call to Action)

[NWFlyer 2]

Most USPA members probably received two emails today with this call to action (also included on the USPA web site). (I haven't compared word-for-word, but I think between these two links, all the information that was in the emails is provided, other than the example, which I've included in the attachment.) http://www.uspa.org/NewsEvents/News/tabid/59/Default.aspx#28587
http://www.uspa.org/Portals/0/News/FAAProposal070312.pdf

It refers to the FAA proposal in the current issue of the Federal Register:
http://www.gpo.gov/fdsys/pkg/FR-2012-07-03/html/2012-15912.htm

USPA Summary:

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The FAA Proposal

The FAA is proposing that all parachute landing areas (PLAs) on federally funded airports meet a newly developed FAA standard that dictates the size and location of the landing area on an airport. Here is the Federal Register notice, and here is the draft appendix. Following is a summation of the proposal’s landing area requirements:

Hazards—The FAA has adopted all landing hazards defined in the USPA Basic Safety Requirements (BSRs) and has also added runways, taxiways and on-airport navaid equipment (except lights). (The FAA will consider removing runways and taxiways as hazards as part of a risk mitigation plan; more on this later.)
Size—Minimum landing areas are specified in square feet for students, tandems and all other skydivers, as well as for ram-air and round parachutes. See Table A18-1 in the notice. Importantly, the FAA is proposing flexible shaping of those minimum sizes, not just circles, so that a PLA can sometimes fit within rectangular grass areas between runways and taxiways, for instance, as long as required buffers (see “Location” below) are met. This is actually quite helpful. The specified square footage for ram-air canopies is roughly equal to the circular square footage obtained by the use of radial distances to the nearest hazard in the BSRs. (The PLA sizes for round parachutes were derived from old USPA radial distances from the past.)
Location—The edge of any PLA must be a minimum of 30 feet from any airport navaid, and the center of the PLA must be sited beyond a 45-degree plane from the top of any hazard (hangar building, etc.). The edge of any PLA must be a minimum distance from any runway and taxiway; that distance is determined by the largest airplane using that runway or taxiway. See Table A18-2, which relates minimum buffer distances to Airplane Design Groups (ADG). The buffer distance will either be 20, 31 or 48 feet for most runways and taxiways. (For comparison, most single-engine aircraft are in ADG I; the King Air, Twin Otter, Skyvan and CASA 212 are in ADG II; the DC-3 is in ADG III.) Except at air-carrier airports, PLAs may overlap Runway Safety Areas, Taxiway Safety Areas and Object Free Areas if no other areas are feasible, as long as the buffer distances are met.
Recommended Markings—PLAs are to be outlined by chalk, cones, mowing, etc.
Application—New DZs at all federally funded airports must have landing areas that meet the standards. Landing areas of existing DZs must comply within five years, unless mitigated or granted an extension.

Example provided by USPA in email (image attached):

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Here is a Google Earth image of a public airport with a long-standing DZ. The green circle is the current USPA-compliant student landing area with a 100-meter radius clear of hazards. Note however that the landing area overlaps a taxiway, which won’t be allowed. Even by reshaping its landing area (allowed by the proposal), this DZ could not get 338,000 sq. ft. (the proposed size for student landing areas) in between the taxiways near its building. Therefore, this DZ may be forced to move its landing area some distance from its building to provide 338,000 sq. ft. of landing space where no edge is closer than 31 feet to any runway or taxiway edge. The blue trapezoid meets that requirement, however that area contains a drainage ditch that makes it unsuitable for a primary landing area. Ultimately, to meet the proposed standard, the DZ may be forced to establish a landing area on the far side of the airport (the red rectangle), introducing shuttle costs and new safety concerns. All DZOs must bring similar scenarios to USPA’s attention so we may advise the FAA.

So the question is, how much of this is due to our (perceived?) inability to effectively manage traffic in our own landing areas? The FAA says it's to mitigate the risk of parachute/aircraft incidents, but the lists of 27 "incidents" that they dug up (links at the bottom of the page) contains many specious examples (though there are some legit ones as well).

"There is only one basic human right, the right to do as you damn well please. And with it comes the only basic human duty, the duty to take the consequences." -P.J. O'Rourke

[5.samadhi 0]

sounds like typical bullshit.

[AggieDave 6]

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So the question is, how much of this is due to our (perceived?) inability to effectively manage traffic in our own landing areas?

What is "perceived" about it? The USPA has failed us in this regard and now we're facing a serious threat by the FAA. I am not surprised in the least.

--"When I die, may I be surrounded by scattered chrome and burning gasoline."

[NWFlyer 2]

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So the question is, how much of this is due to our (perceived?) inability to effectively manage traffic in our own landing areas?

What is "perceived" about it? The USPA has failed us in this regard and now we're facing a serious threat by the FAA. I am not surprised in the least.

I put the ? in there because I'm willing to bet there are some people who believe that USPA has taken adequate action (e.g., the "group member pledge."). (I'm not one who agrees with that). Plus, there are actually DZs who have taken proactive action.

"There is only one basic human right, the right to do as you damn well please. And with it comes the only basic human duty, the duty to take the consequences." -P.J. O'Rourke

[sundevil777 94]

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So the question is, how much of this is due to our (perceived?) inability to effectively manage traffic in our own landing areas?

What is "perceived" about it? The USPA has failed us in this regard and now we're facing a serious threat by the FAA. I am not surprised in the least.

How have they failed us?

People are sick and tired of being told that ordinary and decent people are fed up in this country with being sick and tired. I’m certainly not, and I’m sick and tired of being told that I am

[matthewcline 0]

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So the question is, how much of this is due to our (perceived?) inability to effectively manage traffic in our own landing areas?

What is "perceived" about it? The USPA has failed us in this regard and now we're facing a serious threat by the FAA. I am not surprised in the least.

How have they failed us?

Well, not USPA alone, but the BOD, S&TA's, DZO's etc stil do not enforce basic safety standards and landing area size "recommendations". We cross runways at all altitudes, we cross ends of runways, drop on top of life flights AFTER they have notified the DZ they are spinning up for a call. We land in yards just feet off the Airport while trying for the Airport, we land next to A/C and panic the owners, then we laugh at them.

We the Skydivers are to blame, mostly, followed by all those in "leadership" positions and roles who do not police us up. So now the FAA has heard enough complaints from FBO's, Pilots, Life Flight Ops, etc. FSDO's get calls and can only shrug and pass the info up, this is what we get from our inaction, and "cowboy" attitude.

Matt

An Instructors first concern is student safety.
So, start being safe, first!!!

[captain1976 0]

The comment; "The FAA is creating new bureaucracy" actually has another meaning for me. Its simply a bunch of dysfunctional civil servants (those useless fucks who can't go out and get a real job) flexing their muscles in an attempt to justify their useless fucking jobs.

Being in aviation my entire adult life, I have a lot of experience with this garbage, thus the reason for my kind words about the FAA

You live more in the few minutes of skydiving than many people live in their lifetime

[nigel99 151]

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So the question is, how much of this is due to our (perceived?) inability to effectively manage traffic in our own landing areas?

What is "perceived" about it? The USPA has failed us in this regard and now we're facing a serious threat by the FAA. I am not surprised in the least.

Actually Dave "we" have failed us, not the USPA. Look at the uproar every time someone suggests the current system is broken.

It looks like skydiving in the US is about to undergo a major upheaval. I don't know what can be done, and as a USPA member I'm prepared to submit feedback to the FAA. But I refuse to support the status quo.

Experienced jumper - someone who has made mistakes more often than I have and lived.

[AggieDave 6]

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So the question is, how much of this is due to our (perceived?) inability to effectively manage traffic in our own landing areas?

What is "perceived" about it? The USPA has failed us in this regard and now we're facing a serious threat by the FAA. I am not surprised in the least.

How have they failed us?

Well, not USPA alone, but the BOD, S&TA's, DZO's etc stil do not enforce basic safety standards and landing area size "recommendations". We cross runways at all altitudes, we cross ends of runways, drop on top of life flights AFTER they have notified the DZ they are spinning up for a call. We land in yards just feet off the Airport while trying for the Airport, we land next to A/C and panic the owners, then we laugh at them.

This. Add to it that it has been apparent that the USPA is unwilling to stand up to GM DZs and fight to enforce their own BSRs, the FAA has some serious ammo to significantly change skydiving as we know it.

--"When I die, may I be surrounded by scattered chrome and burning gasoline."

[pchapman 262]

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So the question is, how much of this is due to our (perceived?) inability to effectively manage traffic in our own landing areas?

I really don't know the US situation so my opinion doesn't carry a lot of weight. But I'm guessing that the above isn't the problem. The FAA has to deal with cases where a drop zone wants to locate on a funded airport, and the airport commission or some other group says, "They can't land next to the runway, it's dangerous! Make them land in a field off the airport." The FAA has little guidance on what standards to apply, so is trying to come up with something.

I could be wrong, but it doesn't sound like the FAA is upset with reports of students being dragged across taxiways in front of aircraft etc. Skydivers hitting each other under canopy may be on their radar but it doesn't seem very related to this issue. As was already noted, skydivers sometimes act as if they own the sky, or at least the patch of ground they land on.

[NWFlyer 2]

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So the question is, how much of this is due to our (perceived?) inability to effectively manage traffic in our own landing areas?

I really don't know the US situation so my opinion doesn't carry a lot of weight. But I'm guessing that the above isn't the problem. The FAA has to deal with cases where a drop zone wants to locate on a funded airport, and the airport commission or some other group says, "They can't land next to the runway, it's dangerous! Make them land in a field off the airport." The FAA has little guidance on what standards to apply, so is trying to come up with something.

I could be wrong, but it doesn't sound like the FAA is upset with reports of students being dragged across taxiways in front of aircraft etc. Skydivers hitting each other under canopy may be on their radar but it doesn't seem very related to this issue.

Here's what's in the email (also linked in my OP):

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The proposal lacks justification. The FAA has told USPA that action is needed to separate skydivers from aircraft moving on taxiways and runways. Initially, in December 2010, the FAA commissioned a study of existing DZ operations on public airports, but the resulting report contained no accident or incident data with respect to the hazards of parachutes landing on airports. In fact, on several occasions the FAA asserted that it did not need accident/incident data. Strangely, in March 2012, a full year after initiating the effort and four months after finalizing its approach, the agency hurriedly generated 27 reports involving skydivers and airports. Those 27 reports are posted on the FAA website, with a link to the site in the Federal Register proposal. These reports are now cited as justification. USPA contends the 27 reports offer little to no justification—many have nothing to do with landing areas—and that the overall safety record of skydivers coexisting with aircraft on airports is excellent. Skydiving has been conducted on airports of all types for over five decades, with an estimated 56 million cumulative jumps made. Throughout, there have been only a handful of skydiver collisions with parked aircraft and with aircraft in-flight. USPA cannot document a single collision between a skydiver and an aircraft moving on an airport surface.

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The FAA states that a PLA standard will enable airport access. The FAA contends that airport managers can currently refuse to accommodate a proposed DZ by asserting that their airport has no space for a parachute landing area. The FAA claims that a PLA standard defuses that basis for a denial. While this may be true in a few specific cases, the cost and/or burden to other DZs and airports appears not to be worth the gain.

So you're right, it's not clear that there's a connection to our lack of landing pattern discipline. I can't help but wonder if it's brought it on their radar screen, though.

"There is only one basic human right, the right to do as you damn well please. And with it comes the only basic human duty, the duty to take the consequences." -P.J. O'Rourke

[wmw999 2,166]

Sounds like they're setting up some automatic rules so that the airport access fights have some guidelines besides "trust the skydivers."

If the FAA wants some guidelines, then it's up to us to suggest some alternative ones. Sounds like airport access might be the issue, that the FAA thinks they're spending too much time on it for the small number of DZs.

Or something like that.

Wendy P.

There is nothing more dangerous than breaking a basic safety rule and getting away with it. It removes fear of the consequences and builds false confidence. (tbrown)

[chuckakers 370]

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Well, not USPA alone, but the BOD, S&TA's, DZO's etc stil do not enforce basic safety standards and landing area size "recommendations". We cross runways at all altitudes, we cross ends of runways, drop on top of life flights AFTER they have notified the DZ they are spinning up for a call. We land in yards just feet off the Airport while trying for the Airport, we land next to A/C and panic the owners, then we laugh at them.

Maybe where you jump. I've jumped at dozens of DZ's and have never experienced any of that.

BTW, I noticed that every infraction you mention had nothing to do with USPA. Every "we" you noted was about individual jumpers or pilots acting inappropriately.

Chuck Akers
D-10855
Houston, TX

[fencebuster 7]

+1

Charlie Gittins, 540-327-2208
AFF-I, Sigma TI, IAD-I
MEI, CFI-I, Senior Rigger
Former DZO, Blue Ridge Skydiving Adventures

[chuckakers 370]

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I can't help but wonder if it's brought it on their radar screen, though.

The FAA guys aren't always as bad as we make them out to be. Remember, most of these folks really are motivated to accommodate ALL airport users and don't have an inherent problem with jump operations.

My guess is that there is an established pattern of airport management in access disputes using landing area margins as a reason to knock skydiving. "Crowding" is the easiest argument when no real argument exists.

For the record, I am against regulating landing area size, location, or margins. History clearly demonstrates it isn't necessary. On the other side of that coin, if we can parlay the situation to define an acceptable PLO as being the size of a postage stamp surrounded by a hi-rise skyline, it would put a stop to municipalities using landing area margins against us.

It isn't the subject that matters. It's the outcome.

Chuck Akers
D-10855
Houston, TX

[skybytch 259]

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Add to it that it has been apparent that the USPA is unwilling to stand up to GM DZs and fight to enforce their own BSRs, the FAA has some serious ammo to significantly change skydiving as we know it.

A very good point. What are the consequences for violating a BSR? A verbal slap on the wrist - maybe. While that may have worked fine 20 years ago, it doesn't work so well today.

I know this is a slippery slope, but I'm betting this is just the beginning of much, much more FAA oversight of skydiving.

[chuckakers 370]

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Add to it that it has been apparent that the USPA is unwilling to stand up to GM DZs and fight to enforce their own BSRs, the FAA has some serious ammo to significantly change skydiving as we know it.

A very good point. What are the consequences for violating a BSR? A verbal slap on the wrist - maybe. While that may have worked fine 20 years ago, it doesn't work so well today.

I know this is a slippery slope, but I'm betting this is just the beginning of much, much more FAA oversight of skydiving.

I think you are over-thinking the fed's motives. The FAA folks aren't nearly as educated nor interested in us as many imagine.

The feds could care less how well USPA or DZO's are enforcing BSR's. Most couldn't even tell you what the term "Basic Safety Requirements" means.

Chuck Akers
D-10855
Houston, TX

[pchapman 262]

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These reports are now cited as justification. USPA contends the 27 reports offer little to no justification—many have nothing to do with landing areas—and that the overall safety record of skydivers coexisting with aircraft on airports is excellent.

I looked at those ASRS / NTSB / ASAIS reports. While some do involve accidents involving jumpers hitting airport obstacles like pavement and hangars, there is no data to show that tweaking landing area sizes and shapes has much to do with it.

Perhaps a greater concern is the issue of deconflicting aircraft and parachutists in the air -- it can be tough for pilots to learn exactly where jumpers will be descending and where to expect them to land on the airport. Everything is very foreign to the standard patterns and runways they are used to seeing and visualizing. That's going to be an issue any time there are parachutists near a traffic pattern including approach & departure. Some airports manage the issue better than others.

[stratostar 5]

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So the question is, how much of this is due to our (perceived?) inability to effectively manage traffic in our own landing areas?

Very little, this has been coming down the pike for two yrs, now... it's all about airport access and airport sponsors telling dzo/skydive companies to keep out it's not safe here, no room.

you can't pay for kids schoolin' with love of skydiving! ~ Airtwardo

[nigel99 151]

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So the question is, how much of this is due to our (perceived?) inability to effectively manage traffic in our own landing areas?

Very little, this has been coming down the pike for two yrs, now... it's all about airport access and airport sponsors telling dzo/skydive companies to keep out it's not safe here, no room.

Thanks for giving the background. In that case what positive proposals can be put forward that help airport access?

Experienced jumper - someone who has made mistakes more often than I have and lived.

[yoink 321]

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The comment; "The FAA is creating new bureaucracy" actually has another meaning for me. Its simply a bunch of dysfunctional civil servants (those useless fucks who can't go out and get a real job) flexing their muscles in an attempt to justify their useless fucking jobs.

Being in aviation my entire adult life, I have a lot of experience with this garbage, thus the reason for my kind words about the FAA

Congratulations. You're involved in a hobby that consists of 'useless fucks' who refuse to take responsibility for controlling their own behaviour around government regulated activities and as a result need to be treated like children by the powers that be... sucks huh?


The stupid thing is that until the FAA actually slap a law on us that has a direct effect on day-to-day skydivers, you'll always have morons like samdi above saying stuff along the lines of 'it's just more bullshit' or 'it'll never happen', and so we'll keep ineffectually ruling ourselves until it's too late to show that we're actually capable of it.

[Bolas 5]

Methinks they've confused landing area with landing pattern area.

[Krip 2]

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So the question is, how much of this is due to our (perceived?) inability to effectively manage traffic in our own landing areas?

Very little, this has been coming down the pike for two yrs, now... it's all about airport access and airport sponsors telling dzo/skydive companies to keep out it's not safe here, no room.

Hi SS

+1

The FAA didn't think this up themselves.

WAG a lobby group for Federal funded airports is trying to find a loophole to shut some DZ's down.

http://www.dropzone.com/cgi-bin/forum/gforum.cgi?post=4255234;sb=post_latest_reply;so=ASC;forum_view=forum_view_collapsed;;page=unread#unread

This isn't the only airport trying the "OK" except not enough room for safe GA & jumping. Packin Kathy at the jumping place is another DZ with the same problem.

On a
R

[stratostar 5]

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Thanks for giving the background. In that case what positive proposals can be put forward that help airport access?

Well great question. What is most important here is to take a chill pill and relax,. Do NOT, remark or make comments to the FAA like an asshat! If everyone will follow the guidance that USPA has provided to us, it will be the best thing to do right now.

Then draft well worded and thought out replies based on facts and using professional tones and language at all times. It would also be helpful for most here to remember that, they are reading not only comments on the register but here as well.

you can't pay for kids schoolin' with love of skydiving! ~ Airtwardo

[demoknite 0]

Is there a form letter floating around where we can change the "from" portion and sign our individual names to it? Im not very eloquent when it comes to things like this, but I would love to put my "vote" in.