**Tom Buchanan**

**Postal Address: PO Box 515\~ Bondville\~ Vermont\~ 05340**

**Physical Address: 2454 Route 11\~ Londonderry\~ VT 05148**

**Phone 802-824-4243\~ Email tombuch@aol.com**

James J. Ballough

US Department of Transportation

Federal Aviation Administration

800 Independence Ave., SW

Washington, D.C. 20591

Attention: Docket No. FAA-2005-21829-1

September 12, 2005

Dear Mr. Ballough;

I am writing in response to a request by the Parachute Industry
Association (PIA) for an exemption that would extend the repack cycle
for certain reserve parachute systems (Docket No. FAA-2005-21829-1). It
is my understanding that this exemption request has been rejected in
favor of future rulemaking, and that the docket has been closed. I have
told by your office that I may write a formal letter regarding this
issue, and that it will be added to the closed docket for consideration
as the new rule is written.

I am a senior parachute rigger and have been jumping sport parachute
equipment for more than 25 years. I have been issued instructional
ratings by the United States Parachute Association (USPA) in all
recognized disciplines, and serve as a USPA appointed Safety and
Training Advisor at one of the largest drop zones in the northeastern
United States. I hold an FAA commercial pilot certificate with ratings
in single and multi-engine airplanes, and gliders. I am also the author
of *JUMP! Skydiving Made Fun and Easy* (McGraw-Hill 2003), a general
title for consumers who are interested in learning about civilian
skydiving.

I believe the request for a 180 day repack cycle is appropriate for many
parachute systems, but not for all users. The easy way to write a new
rule would be to follow the PIA lead and simply change all regulations
to reflect 180 days, but this would be a serious mistake. In fact,
changing the regulation will require a more substantial alteration, and
far more consideration than the limited exemption originally requested.

**A new rule should differentiate between personal equipment used by the
owner, and equipment available to the general public on a commercial
basis through rental, loan, passenger rides, and student programs.** I
hope you will consider my comments when structuring a new rule, and base
the rule on the needs of the general public, not just the members of the
various organizations who will benefit from the cost savings.

The PIA request notes that parachute material is degraded each time it
is packed, and that opening performance is not degraded when a reserve
parachute is left in the container for 180 days or longer. I agree with
this assessment. PIA also notes that extending the repack cycle will
save users money. I agree with this assessment as well. However, a 120
day reserve repack involves more than simply rearranging nylon. The
primary reason for a repack every 120 days is to allow a certificated
parachute rigger to complete an extensive inspection of the entire
parachute system, including the harness and all associated components.
An extended repack cycle will reduce these inspections, will be a
serious mistake in some cases, and will defiantly reduce the safety
afforded to the general public.

One of the major causes of parachute malfunctions is poor maintenance.
Contemporary sport parachute equipment is constructed with Velcro, tuck
tabs, handles and cables, and electronic Automatic Activation Devices
with batteries. These components are heavy wear items that are currently
checked by a rigger at least every 120 days. Extending the repack cycle
will reduce the inspection of these elements.

I am aware of at least three failures of Velcro holding cutaway cables
to the harness at my own drop zone this year alone, each involving
student jumpers without the skill or training to recognize poor
maintenance. In each case, worn Velcro allowed the cutaway handle to
release in freefall causing an unnecessary separation of the main
parachute, and subsequent reserve deployment. In other cases, Velcro can
take a "set" over an extended period of time and make it hard to pull
the cutaway or reserve handles. My drop zone has experienced additional
malfunctions when a main parachute has deployed prematurely because the
pilot chute pocket had been stretched beyond tolerances. These issues
can best be controlled with regular inspections by a certificated
parachute rigger at the standard 120 day repack. Extending the repack
cycle will increase the number of parachute failures due to undetected
system problems and deferred maintenance.

Many parachute systems used for intentional jumping under part 105
include an Automatic Activation Device (AAD). There is currently one
mechanical AAD in general use that must be inspected at every repack
cycle by removing it from the pack and testing it in a chamber. This
AAD, called the FXC 12000, is mostly used by student jumpers. Unlike
electronic AAD's that include automatic self-tests, the only way to test
the FXC 12000 is in a chamber when the reserve is repacked. Extending
the repack cycle will also extend the operational test cycle for this
AAD, and may reduce the reliability of the device.

In addition to the single mechanical AAD, there are currently three
electronic AAD's in general use, and a fourth being readied for release.
All of these devices use batteries that are placed within the reserve
container. There have been several reported cases of leaking batteries
identified as part of the standard 120 repack cycle. Extending the
repack cycle will reduce the inspection of these batteries, and may
allow leaking batteries to damage nylon components. It is important to
understand that AAD's are not manufactured under any FAA approval
process, and manufacturers are not required to maintain any level of
quality control. In fact, the manufacturer of the Argus AAD, expected to
be released in the United States later this year, has designed the
device to use regular consumer batteries available through unmonitored
retail channels. The sale of AAD's is very competitive, with some
manufactures driving sales by promising not to require any future
service inspections or electronic component life limits. Thus, the only
inspections of these devices will occur by a rigger when the reserve is
repacked. Extending the repack cycle will reduce the inspection of these
uncertified safety-critical devices.

The use of an AAD is mandatory for every tandem parachute rig used in
the United States as listed in 105.45(b)(3). An AAD is also required for
every student jump conducted under USPA Basic Safety Requirements. Given
that extending the reserve repack cycle will reduce the inspection of
AAD's, it will clearly increase the risks that student jumpers are
exposed to. It should be noted with emphasis that the use of an AAD has
been shown to dramatically reduce fatalities, and I believe regulations
should NOT be structured in such a way that there is any incentive to
avoid the use of these life saving devices. For this reason I oppose any
regulatory change that would impose a shortened repack cycle for reserve
parachutes equipped with an AAD.

In a perfect world main parachutes used by students would be packed
under the supervision of a certificated parachute rigger as required by
105.43 and 105.45, thus giving the rigger an opportunity to conduct a
noninvasive inspection. Unfortunately, this supervision requirement is
often ignored. In fact, I recently conducted a non-scientific survey and
found several drop zones that have student programs but do not have a
rigger on staff. In many other cases a rigger allows uncertificated
persons to pack and maintain equipment without any specific training or
recognized program of supervision. Student equipment is handled
repeatedly in the field by many different students, instructors, and
other users. Often these users are unqualified to self inspect the
equipment, and thus maintenance issues may not be identified prior to
use or between 120 day repack cycles.

Parachutes that are carried in aircraft and that are available for use
under 91.307 are rarely inspected by a rigger or other knowledgeable
person between repack cycles. It is doubtful that most pilots can
recognize maintenance issues, or are capable of identifying critical
safety problems with their parachute systems. Parachutes that are
carried in commercial operations such as aerobatic passenger rides may
be passed between users and aircraft, handled roughly, and excessively
exposed to weather elements. Damages to this equipment will likely go
unnoticed for a longer period of time if the repack cycle is extended.

The initial request for an exemption to the existing 120 day repack
cycle was intended to be limited to experienced users who are members of
the requesting organizations. The request noted that some United States
military units currently use extended repack cycles for some equipment
with great success. It is important to understand that military repack
cycles are structured around specific equipment and patterns of use, and
most such equipment is regularly inspected by parachute riggers between
repacks. Military users also tend to treat their equipment with greater
care than civilian users, and few military parachute systems are
equipped with uncertified consumer electronic devices and batteries of
unknown origin.

The primary benefit of extending the repack cycle is a reduction in cost
for the owner of the equipment. The cost savings are generated because a
parachute system will require less frequent service by a certificated
rigger. Reduced material handling will increase the lifespan of the
parachute, thus further reducing costs.

The organizations that initially requested the rule change represent an
estimated 620,000 members who are active in general aviation. The
organizations do not represent non-members who may use or be exposed to
parachute systems as parachuting students or aircraft passengers. It is
important for the FAA to consider the needs and interests of these
unrepresented general public aviators when considering a rule change to
the reserve parachute repack schedule.

**I strongly recommend that when a change to the repack cycle of reserve
parachutes is considered, that two distinct users are identified,
specifically defined as Private use or Commercial use. I believe
commercial users such as aerobatic passengers, skydiving students,
parachute rentals and parachute loans, should be restricted to the
current 120 day cycle. I also believe that owners of parachute equipment
should have a longer repack cycle, such as 180 days, available when
using the equipment for their own safety.**

Knowledgeable individual owners are in the best position to select an
appropriate repack cycle based on balancing their own patterns of use
against the reduced cost of maintenance. However, members of the general
public that rent or borrow parachute equipment are clearly not able to
assess the risk of reduced inspections and maintenance associated with a
longer repack cycle. Further, the actual owners of parachutes used in
commercial operations do not have an adequate incentive to provide the
needed additional maintenance and inspections, including invasive
inspections of uncertified electronic AAD's and their batteries.

**For all of the above reasons, I believe the best way to manage repack
cycles is to distinguish between Commercial and Private users, rather
than between and among specific parachute systems or components.
Commercial users should be restricted to the current 120 day repack and
inspection cycle. Private users should be permitted to extend the repack
cycle for equipment that they make exclusive use of, and that they
personally own.**

Please consider this communication when structuring a new rule for
parachute repack cycles. The change from 120 days to 180 days, as
requested by PIA and other user groups, is a positive move for the
industry, but it needs to be structured in such a way that there is no
additional risk imposed upon the general public.

Sincerely,

Thomas Buchanan