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dninness

FAR 105 & the FSDO?

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Talked to the local FSDO yesterday about a small demo jump at a local fly in and whether or not I would require a Certificate of Authorization for the demo. My slant was that I wasn't going to require a Certificate of Authorization due, partly, to the nature of the event and its location (on an airport). Its definitely a Level I demo, right on the line with an "Open Field" demo.

The gentleman from the FSDO said that since parachute jumping does not normally occur at this airport (as indicated in the the Airport/Facility Directory), a certificate must be obtained for the jump.

Now, I'm filing the request, that's no sweat. It doesn't terribly bend me out of shape to do so. But I am curious that since there is no mention of this particular qualifier in the FAR, why does the FSDO use it? FAR 105 doesn't seem to require you to request a certificate of authorization for jumping at an airport that doesn't list parachute jumping in the AFD any more than, it seems, any other part of the FAR requires you to file for a certificate if you're holding, say, a fly-in breakfast or a spot landing contest at an airport where those activities are not listed in the AFD.

I've been told the the FSDO is supreme in their interpretations of the FAR, and thats cool, I'm just worried about having to hit a moving target. Its bad enough trying to read and comply with the convoluted FARs without having to worry that the FSDO has "unwritten" rules or procedures.'

On a similar note: does anybody know if, when jumping from an unmodified C-182, the pilot has to wear a bailout rig? I seem to recall that the bailout rig requirement was associated with the STC of aircraft that had been modified especially for jump ops (ie. step, jump door, seats removed, etc), not for unmodified ops. Any ideas here before I ask my FSDO guy again?

Thanks
NIN
D-19617, AFF-I '19

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That your target is an airport shouldn't be a big deal. The topic is covered in greater detail in Advisory Circular 105-2c, sections 15-20. You will find it on line at http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/c96c33525870370c862569de005bd7aa/$FILE/AC105-2c.pdf, and also in the 2004 SIM on pages 192-201.

A landing on an airport requires prior approval from airport management. A landing into controlled airspace associated with an airport requires authorization from the tower at the airport. A landing into a congested area requires authorization from the FSDO/GADO. You will find a good chart that defines the various authorization requirements in the AC.

Your desire to remove or open the door of a Cessna in flight does require the approval of the local FSDO. See the Advisory Circular, section 23.
Tom Buchanan
Instructor Emeritus
Comm Pilot MSEL,G
Author: JUMP! Skydiving Made Fun and Easy

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The picky legal details do not REQUIRE a jump pilot to wear a bail out rig, it is just good airmanship.



It does with a cessna with a completed 337 for the jump door mod. It was written into the paperwork as a reqirement for the STC (if you use that particular STC).
BS,
Masterrigger1
Skyworks Parachute Service, LLC
www.Skyworksparachuteservice.com

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Guys,

Thanks for the input here. :)

The C-182 I'll be doing the demo from is an UN-modified aircraft. Not even the door removed. Since it doesn't have the STC or a 337 applied for removal of the door, I take it the bailout rig part is not legally required under the FAR, correct? (the airmanship issues are another matter, but I do take your meaning.. I will strongly recommend this to my friend the pilot..)

I am conversant with the FAR 105 and the AC WRT demo jumps, for the most part.

My concern from the FSDO situation stems from their interpretation that the "file for a waiver/don't file for a waiver" criteria is based on whether the airport has parachuting listed as occuring at that airport in the Airport Facility Directory. (which is NOT a criteria listed in the FAR)

If the local glider or balloon club wanted to fly from an airport for a day or two that they normally didn't fly from, and that airport does not have glider or balloon operations listed in the AFD, do they too have to file for a waiver with the FSDO (I'm guessing "not."). That's my point.

I'm guessing the FSDO is preferring to err to the side of caution, and for that I have no problem. I'm just worried about having to comply with fairly arbitrary requirements that have no basis in the FAR or reality.

Thanks!

(Oh, yeah, and suggestions about how to easily get out of an un-modified Cessna 182RG are greatly appreciated...)
NIN
D-19617, AFF-I '19

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The C-182 I'll be doing the demo from is an UN-modified aircraft. Not even the door removed. Since it doesn't have the STC or a 337 applied for removal of the door, I take it the bailout rig part is not legally required under the FAR, correct? (the airmanship issues are another matter, but I do take your meaning.. I will strongly recommend this to my friend the pilot..)



You still need FSDO approval for flight with the door open or removed.

AC 105-2c
23 AIRCRAFT OPERATING AND AIRWORTHINESS REQUIREMENTS.

a. Procedure. Owners or operators of aircraft listed in Appendix 2, who
are interested in-obtaining authorization and operating limitations for these
aircraft to be flown with the door open or removed, should forward a written
- request to the FSDO having jurisdiction over the area in.which -these
operations are to be conducted. The request should contain the following
information:
(1) blame and address of the registered owner(s) of the aircraft.
(2) Make, model, serial, and registration numbers of the aircraft.
(3) Place where the aircraft is normally based.
(4) Reason the aircraft is to be operated with a door open or
removed.

Tom Buchanan
Instructor Emeritus
Comm Pilot MSEL,G
Author: JUMP! Skydiving Made Fun and Easy

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In addition to the FAR's and USPA BSR's that the FAA follows there is a FSDO hand book called document 8700. That is adocument that tells the FSDO howto interpret the FAR's and how to apply the USPA's BSR's, Rating's and Licenses.

I talked to a FSDO while preparing for a Demo in Illinios. Althoug hI too am jumping on an Airport that has had jumping in thepast itisn't an active DZ. So due to its inactivity in the FSDO's eye's I need the whole 7711-1/2 packet. That may be why your FSDOP is asking forthe 7711-2.

I also spoke to a couple of pilots for ya about your exiting advice for a unmodified 182. A unanimous "unless it is not going to survive the crash landing, Don't";)
An Instructors first concern is student safety.
So, start being safe, first!!!

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Hey, gang, I appreciate all the feedback I've gotten from this one. Its come in handy when dealing with the FSDO (especially the document 8700 & the special provisions contained therein..)

Unfortunately, the ops inspector from the FSDO called me up the other day and indicated that jumping from an unmodified 182 without the door removed is something they have heartburn with. He put me on with one of the other ops inspectors who is also a skydiver and we were able to "talk the talk", so to speak.

The long and the short of it was that opening the door of the 182 in flight is not what its designed to do. If something were to happen while doing that, the words "unsafe operation" and "careless & reckless" would probably be repeated in the report several times, and of course aviation insurance companies don't pay on claims made while operating an aircraft in a manner deemed "unsafe" or "careless & reckless" by the FAA. Bad news, but better we're told this now than later. OK, that's cool. I half expected this...

As per usual, I'm back to square one on the plane. This is always the case... :) I start looking around for someone who will let me yank the door on their 172 for this purpose, as according to the guy at the FSDO, you don't need hardly any paperwork at all for that transaction.

So a friend emails me today, says "Hey, I've got a Decathlon that I fly for aerobatics, can you jump it?"

I've been digging thru the AC 105-2C and the Internet for about an hour now, and I can't seem to find anything that pertains to the Decathlon (Aeronca Series 7s, yeah, but Decathlons, no) and jumping.

Anybody have any experience with a Decathlon and jumping out? Is it going to be a lot like getting out of a Piper Cub? Can you leave the door off? I'd like a couple informed opinions first, before I call our buddy the ops inspector at the FSDO and start poking around in the hornets nest.

Thanks!
NIN
D-19617, AFF-I '19

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I have friends who have made jumps from unmodified C182's and C172's. They told me that the pilot flew the plane at an angle into the direction it was flying, exposing the pilot's side to the headwind, thus reducing the windblast somewhat onto the door and making it easier to push it open enough to get out. Not really recommended, but in those cases, the pilots had a ton of experience and knew what to do. It was still tough for the jumpers to do it.

You're better off getting approval to remove the door...

Blue Skies
Billy
"Mediocre people don't like high achievers, and high achievers don't like mediocre people." - SIX TIME National Champion coach Nick Saban

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I have friends who have made jumps from unmodified C182's and C172's. They told me that the pilot flew the plane at an angle into the direction it was flying, exposing the pilot's side to the headwind, thus reducing the windblast somewhat onto the door and making it easier to push it open enough to get out. Not really recommended, but in those cases, the pilots had a ton of experience and knew what to do. It was still tough for the jumpers to do it.

You're better off getting approval to remove the door...



Removing the door on the 182 we were going to do it in is not an option (the plane doesn't have pinned hinges, and my buddy isn't interested in ripping the hinges off to install pin hinges..:D), so that was the reason for the un-modified airplane.

The fellow at the FSDO (the jumper) said "You know, you can do it, sure. Its like dealing drugs: you can do it, right up to the point where you get caught.. Lots of people have gotten out of a C-182 like that, sure.. But its not a good idea. We don't really approve of doing it that way. The aircraft door wasn't designed to be opened on purpose like that in flight. If something were to happen, and you were doing something with the airplane, like opening a non-inflight door in flight for the purpose of putting a jumper out, that's not what its designed for, then you'd have some problems.."

I couldn't argue with his logic: Can't remove the door easily on the plane, and the door isn't really designed to be opened like that in flight. Like he said "It would be a bad time to discover that you have a stress-crack in the hinge.." (a local FBO just recently lost a door off of one of their nearly-new C-172s, from what I understand..)

So I'm looking now for a 172 (which you can remove the door from w/o getting the STC) or something like a Cherokee Six (which you can remove the rear door from without an STC as well..)

Or a Decathlon. Which apparantly some folks have jumped (as well as things like Champs and Citabrias..)
NIN
D-19617, AFF-I '19

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Trying to struggle out of a Cessna - with the door still installed - is difficult and dangerous.
If the manufacturer approved the airplane for flight with the door off, no additional paperwork is required.
For example, most of the single-engined Cessnas were approved by factory test pilots for flight with the door removed.
Cessna also encourages you to install and expensive kit that includes a wind deflector, etc.
Most of the in-flight doors are after-market modifications which require a Supplementary Type Certificate or form 337 (single use field modification) thousands of dollars.
A long time ago, USPA published a list of airplanes that are approved for flight with one door removed. I vaguely remember the whole Aeronca Champion, Citabria, Decathlon series being on that list. I also vaguely remember that list being published in the back of one of Poynter's books.

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Just a couple of things based on experience with FSDO people.

Go ahead and file the form even if the inspector is wrong. It isn't a big deal. They can get away with almost anything by saying 9-11.

Make sure the form is completed in a way that looks professional. Aerial photographs of the landing area with dimensions drawn in are good. It might be a good idea to get a "team" name rather than file in your name. It just adds a greater degree of credibility to the form.

Don't forget the other details mentioned here like ATC and airport management. ATC might take a couple of weeks to clear if you are near a control tower.

If it looks like you know what you are doing, you will get less of a hassle. If the inspector does get unreasonable, don't be hesitant to bring out AC 105 and present the facts in an emotionless way.

Ed



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The picky legal details do not REQUIRE a jump pilot to wear a bail out rig, it is just good airmanship.



You are wrong to a point! It is stated in one of the FAR's, that is a pilot is changing the pitch of the plane by more than about 30 degrees then a rig must be worn!!! I will try and find the FAR that states that and post it!!


drakeshelby
drakeshelby

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You are wrong to a point! It is stated in one of the FAR's, that is a pilot is changing the pitch of the plane by more than about 30 degrees then a rig must be worn!!! I will try and find the FAR that states that and post it!!



Pitch by 30 Roll by 60...

But that has nothing to do with parachute operations.

Jumping a plane with the regular door on it is asking for trouble.

172's are good..they are approved for flight with the door removed. But I THINK they still need suplimental paperwork.

You should not have to file any additional paperwork...You will need a NOTAM...

But fill out anything they hand you since it is their party.
"No free man shall ever be debarred the use of arms." -- Thomas Jefferson, Thomas Jefferson Papers, 334

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