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Cloud Clearances

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I have written a few letters and discussed this with a few people and want some more opinions on the topic.

Usually when a FAR, BSR, Law, Statute, or any other rule is being constantly broken the rule itself needs to be looked at. Without naming any particular location, I know cloud clearances are very tough to adhere to. We want to continue to have a good relationship with the FAA and that is done by being open and forthcoming with our opinions on some of their FARS.

So are they reasonable or can they be reduced for skydiving operations in a seperate subsection. For example, we really have no need for the above 10k and below 10k differences and the above the cloud is a bit ridiculous. Do we really need 1 full mile of horizontal clearance at 13,500 agl to remain safe?

I also want to add, I personally feel the safest place for us to be is closer to the cloud given the fact that general aviation shouldnt be that close. Use a 500 foot above below and horizontally from all clouds as a starting point. Is that safe? Can we operate without jeapordizing our safety and that of general aviation.

On nice clear days with big white puffy clouds am I operating unsafe if I were allowed to go closer to the cloud then 2000 feet?

I would love to see a subsection for us giving dropzones a bit more leeway than what is currently FAR Law. remember a parachute is slower, and more controllable than an airplane.
just wanted some thoughts on our current cloud clearances and if it would be worth the effort to try to work with the FAA to reduce them for skydiving operations.

Maybe some pilots have different opinions that would be helpful.

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remember a parachute is slower, and more controllable than an airplane.



I would think the FAA's answer will be about free falling bodies and aircraft intersecting in and around clouds..... think of that clear blue sky with white puffy clouds and a guy flying along working on IFR with his hood on not looking out the windshield for falling bodies or parachutes.
you can't pay for kids schoolin' with love of skydiving! ~ Airtwardo

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Well, hopefully that pilot ( and all pilots ) have a working radio. To hear the call out from the jump plane pilot......."Jumpers out over ........( fill in the blank )" I've seen rouge aircraft fly right across drop zones during jump runs, on non-cloud days. I watched one jumper in freefall ( from the ground ), and a plane under the jumper's altitude, coming in at a 90 deg. angle. All I could do was watch as the two lines came to a perfect intersection ( they did not hit each other ). Cloud clearance is less of an issue than pilots crossing thru "known jump run areas", in my opinion.
Life is short ... jump often.

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You'll get nowhere in attempting to carve out some sort of special exception to cloud clearance regulations for sky diving operations. They are identical to the cloud clearance requirements for all VFR operations.

There is nothing "ridiculous" about them at all.
quade -
The World's Most Boring Skydiver

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Well, hopefully that pilot ( and all pilots ) have a working radio. To hear the call out from the jump plane pilot......."Jumpers out over ........( fill in the blank )" I've seen rouge aircraft fly right across drop zones during jump runs, on non-cloud days.



Well yea, we've all seen that happen, so what makes you think a guy flying IFR on VFR day with a hood on is paying any more attention to the radio calls then the guy who is flying VFR on a VFR day with no hood on and buzzs through the dz airspace while a jump is being called out on the radio and notam filed.:P
you can't pay for kids schoolin' with love of skydiving! ~ Airtwardo

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I can't see it being changed.

Even though parachutes don't go very fast, airplanes still do.

The reason for the difference above and below 10k is the 250kt speed limit below 10k.

In theory, if the weather is jumpable, then the conditions are VFR.
Unfortunately, there may be aircraft operating under IFR rules at that time. Those planes don't have to maintain cloud clearances and don't have to alter their flight paths to go around clouds (like VFR aircraft do).
Those are the aircraft that may pop out of a cloud at the worst possible time.
Those aircraft should be made aware of any jump operations in progress, but may or may not divert because of it.

At one of the bigger ways at SDC Summerfest a couple years ago there was a notable go-around due to a "large package delivery company" plane on approach into ORD. It flew directly below the formation on jump run.
"There are NO situations which do not call for a French Maid outfit." Lucky McSwervy

"~ya don't GET old by being weak & stupid!" - Airtwardo

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>Well, hopefully that pilot ( and all pilots ) have a working radio.

Some don't (it's not a requirement) and most pilots are not on frequency (i.e. not listening on unicom.) If you are lucky then ATC may relay the warning. But for a pilot out for a Sunday VFR flight - he's generally not going to hear any warnings.

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>I know cloud clearances are very tough to adhere to.

They are very, very easy to adhere to. People just don't want to adhere to them.

>So are they reasonable or can they be reduced for skydiving operations in a seperate
>subsection. For example, we really have no need for the above 10k and below 10k
>differences

Airplanes DO have a need for that. The separation rules are as much to benefit them as they are for us.

>and the above the cloud is a bit ridiculous.

For the most part, agreed. The separation rules originally came from aviation which is why that's in there

>On nice clear days with big white puffy clouds am I operating unsafe if I were allowed
>to go closer to the cloud then 2000 feet?

OK let's take an example:

You are flying towards a cloud, 2000 feet away. You are considering turning, but haven't yet. A business jet on an IFR flight plan who has strayed a bit from his course emerges from the cloud. He's descending through 5000 feet so he's doing only 250 knots.

Your closing speed is about 500 feet per second so you have four seconds to see him (and/or him see you) and turn to avoid him. Is that enough? Probably. Would two seconds be enough? Maybe but it would be very close.

BTW the above has happened to me (I was in a 172 instead of a parachute) and it's amazing how fast aircraft close when they are pointed at each other.

>I would love to see a subsection for us giving dropzones a bit more leeway than
>what is currently FAR Law. remember a parachute is slower, and more controllable
>than an airplane.

While we haven't had a lot of collisions with aircraft, I can think of two fatal and a dozen very close calls between skydivers and aircraft. So we do have issues with separation; I can't imagine them improving with relaxed clearance requirements. And while I agree that parachutes are slower, saying "we'll see and avoid aircraft" might be a tough sell to the FAA since collision with another skydiver we didn't see is one of the #1 causes of fatalities in skydiving.

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Bill,

I don't think you are being entirely honest in your reply. If all our dz's adhered strictly to the rules we would have less jumpable days. That doesn't make it easy.

In the what to do in a cloud thread, you mentioned that on a number of occasions on bigways there was a plan in place. If it was that easy to not break the FAR, why make alternative plans?

So I think it goes one of two ways. We support the current FAR and then actively support not breaking it. Alternatively we try and get an exemption, and acknowledge that it makes life difficult.

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*** I would think the FAA's answer will be about free falling bodies and aircraft intersecting in and around clouds..... think of that clear blue sky with white puffy clouds and a guy flying along working on IFR with his hood on not looking out the windshield for falling bodies or parachutes.



Or, think about gliders happily circling around right under those white puffy clouds, as that is where the lift is. There are two sailplane (glider) operations, a hang glider operation and a paraglider operation within a few miles of our DZ. IF they are flying with a radio they're most likely on their own frequency. And, as you know, while it may not be smart to be hanging out under clouds below a jump plane it's perfectly legal in uncontrolled air space. Whether or not this affects the FAAs answer it's certainly something to consider when looking down on those soft, friendly looking big white puff balls.
www.wci.nyc

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>I don't think you are being entirely honest in your reply. If all our dz's adhered strictly
>to the rules we would have less jumpable days.

Agreed.

>That doesn't make it easy.

?? It it indeed easy - just don't jump on cloudy days.

Is not putting students up in winds over 14mph hard? No, it's really pretty easy - just don't put them up when the wind is over 14mph, and don't let them out when the wind gets up there once the plane takes off. The winds might start howling the instant their feet leave the door, but that's pretty rare.

Does that mean that we put fewer students up, and thus schools make less money? Yep. But that's a different issue.

>In the what to do in a cloud thread, you mentioned that on a number of occasions on
>bigways there was a plan in place. If it was that easy to not break the FAR, why make
>alternative plans?

Because:

1) some bigway organizers don't care much about clouds and will push the limits

2) accidents happen. You can get out of an airplane and punch a cloud even though it was clear when you exited. It's only happened to me twice, but it can happen.

>We support the current FAR and then actively support not breaking it. Alternatively we
>try and get an exemption, and acknowledge that it makes life difficult.

Or we keep what we have now - follow the FAR most of the time, and violate it once in a while knowing we put our pilots at risk. (Which keeps us from doing it too often.)

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Well, hopefully that pilot ( and all pilots ) have a working radio. To hear the call out from the jump plane pilot......."Jumpers out over ........( fill in the blank )" I've seen rouge aircraft fly right across drop zones during jump runs, on non-cloud days. I watched one jumper in freefall ( from the ground ), and a plane under the jumper's altitude, coming in at a 90 deg. angle. All I could do was watch as the two lines came to a perfect intersection ( they did not hit each other ). Cloud clearance is less of an issue than pilots crossing thru "known jump run areas", in my opinion.



I don't trust pilots to have any idea that we are there. drop zones are on their charts, there are NOTAMs posted, and there are radio calls, and yet I've seen traffic fly right over our drop zone several times.

One time it was a T-6 Texan directly below us in free fall. A whole tracking dive deployed about 1k above him as he flew diagonally through jump run. honestly I don't think he ever saw us (he never changed course or altitude).

It was a perfectly cloud-free day. If I had been punching a cloud I wouldn't have known he was there. If I had not been on a tracking dive (and thus pulling higher) he would have been at deployment altitude. You become a believer in these kinds of rules (cloud clearance) when you realize that you have to assume a pilot will be exactly where he shouldn't be, because sometimes, they are.

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I don't trust pilots to have any idea that we are there. drop zones are on their charts, there are NOTAMs posted, and there are radio calls, and yet I've seen traffic fly right over our drop zone several times.



And

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You become a believer in these kinds of rules (cloud clearance) when you realize that you have to assume a pilot will be exactly where he shouldn't be, because sometimes, they are.



You need to understand something here about this.... First and foremost it is not a violation to fly over the dropzone regardless of any NOTAM's, Radio calls, sectional map markers or even GPS markers.... A pilot can fly through class E or G airspace freely without any radio use, GPS, sectionals, or even calling in for NOTAM's that are filed in the area they are flying.

So in other words "you have to assume a pilot will be exactly where he shouldn't be, because sometimes, they are" that is a false statement, because VFR- Visual Flight Rules are just that..... VISUAL! And in airspace where dz's are located (normally) in class E airspace, any type, kind and class of user can and will found there operating.

You are required to make sure via "visual" methods to make sure your airspace is clear before leaving the AC green light or no green light or pilot yelling to get the fuck out..... the same as the T-6 guy is required to maintain VFR flight as he buzz's right over the top of the DZ/airport and it all legal to do...... safe, is a whole other topic.
you can't pay for kids schoolin' with love of skydiving! ~ Airtwardo

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And in airspace where dz's are located (normally) in class E airspace, any type, kind and class of user can and will found there operating.

You are required to make sure via "visual" methods to make sure your airspace is clear before leaving the AC green light or no green light or pilot yelling to get the fuck out.....



Hence the idea that cloud clearance requirements are just that...a good idea.
My reality and yours are quite different.
I think we're all Bozos on this bus.
Falcon5232, SCS8170, SCSA353, POPS9398, DS239

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We want to continue to have a good relationship with the FAA and that is done by being open and forthcoming with our opinions on some of their FARS.



The FAA does not care very much for our opinions.

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For example, we really have no need for the above 10k and below 10k differences and the above the cloud is a bit ridiculous. Do we really need 1 full mile of horizontal clearance at 13,500 agl to remain safe?



Those are VFR flight rules and not only the jumpers, but the pilots of the jumpers are only allowed to allow dropping of objects in accordance with VFR conditions.

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I personally feel the safest place for us to be is closer to the cloud given the fact that general aviation shouldnt be that close.



IFR traffic will be there. So no, it is not safer.

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On nice clear days with big white puffy clouds am I operating unsafe if I were allowed to go closer to the cloud then 2000 feet?



Yes. IFR planes can fly very fast and are not looking outside the cockpit.

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remember a parachute is slower, and more controllable than an airplane.



Slower: Yes
More controllable: No, we can't power up and climb.

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just wanted some thoughts on our current cloud clearances and if it would be worth the effort to try to work with the FAA to reduce them for skydiving operations.



Leave it alone. You are not going to win and maybe worse you will get the FAA to look at the situation and decide that skydiving ops need MORE regulations. Remember, the Govt does not reduce regulations, they create more.

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Maybe some pilots have different opinions that would be helpful.



I am a pilot (just bought my first plane... Yeah, beer) and I can tell you that VFR rules are fine for skydiving operations and should be left alone.
"No free man shall ever be debarred the use of arms." -- Thomas Jefferson, Thomas Jefferson Papers, 334

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First and foremost it is not a violation to fly over the dropzone regardless of any NOTAM's, Radio calls, sectional map markers or even GPS markers.... A pilot can fly through class E or G airspace freely without any radio use, GPS, sectionals, or even calling in for NOTAM's that are filed in the area they are flying.



i 100% agree with this, when I was saying "supposed to" I wasn't implying they are in violation of FAA regulations. I'm saying supposed to in the sense that all these things (NOTAMs, radio calls, map markers) are saying to pilots "hey dummy shit is falling through the sky you probably don't want to be there while it's happening" and yet the commonly just blunder through.

Remember, my comments were in the context of VFR cloud clearance, where seeing what is in your airspace is very important. We all have to share the sky, which is why you really do need to see what's going on.

One last thing: we haven't even touched on needing to see other skydivers. punching a cloud on a zoo dive is just asking for a jumper-to-jumper collision.

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Bad idea ... on two counts.

First, the existing FARS have done a pretty good job of keeping skydivers alive.

Secondly, asking pilots to memorize - yet another - set of rules - for a new class of airspace - is asking too much.
IFR (read most commercial and military aviation) quit looking out their windshields decades ago.
VFR "Sunday fliers" are fully occupied just keeping their airplanes upright. Asking either group to stay out of the way of skydivers is pointless.

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Rich, we talked about this at length during the 2008 summer bod meeting in Alexandria and as I remember it never made it out of the safety and training committee. We may have mentioned it to the full board but only that it was discussed and decided to be a bad idea.

Randy Ottinger made it pretty clear that we should not ask the FAA a question if we don't want to hear the answer. (Can we do this? no, why do you want to do that?)

Essentially we don't want them to take a closer look at what we are doing. If we approach the FAA and tell them these rules are hard to adhere to and we want an exemption they may very well come back and say "really?" Why is that? Are you violating the FARs? Do we need stricter enforcement? Etc.

I think we should leave this one alone. For the most part it is fairly easy to follow the cloud clearance rules.
Onward and Upward!

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