t!1 Piltachute Labotatotie~ Inc. 

1665Lexington Ave. #106 Delantt FL32724 USA 

(3861 734·5867 FAX (3861 734--8464 www.Jumpshack.com 

Federal Aviation Administration 

Ms. Brenda D. Courtney 

12/2/2011 

Manager,Aircraft and Airport Rules Division 

800 Indenpendance Ave. S.W. 

Washington, D.C. 20591 

Dear Ms. Courtney, 

Thank you for your letter of November I 0, 2011 re~arding my application for exemption from 

§105.43(B)(3) of Title 14, CodeofFederal Regulations (14CFR). In compliant response to you 

letter I offer the following. 

I have copied your document Part 11 General Rulemaking Procedures, Subpart A and present it in 

red type while my response is in Black type inderdisbursed so a direct answer to each requirement 

is app~t. I hope this mee!S with your approval. . ' . . · . .. . . . . . .· 

. ': 

§ 11.81 What information must I include· in my pel.ition for an exemption? 

You must include the following information in your petition for an exemption and submit it to FAA as 

soon as you know you need an exemption. 

(a) Your name and mailing address and, if you wish, other contact information such as a fax 

number, telephone number, or e-mail address; 0 ... : ' • 

Parachute. labs., Inc. dba Jump Shack 

1665lexington Ave. Suite 106 

Deland, Fl. 32724 

John Sherman Director of Engineering 

John@Jumpshack.com 

Tel: 386-734-5867 · ·. · . · ; 

Fax: 386-734-8464 

(b) The specific section or sections of 14 CFR from which you seek an exemption; 

This is to request an exemption to part of the Federal Aviation Administration 14 CFR FAR Part 105.45 Para, 

b.3. 

It currently states: 

(b) No person may make a parachute jump with a tandem parachute system unless-

(3) The tandem parachute system contains an operational automatic activation device for the reserve parachute, 

approved by the manufacturer of that tandem parachute system. The device must ... 
(c) The extent of relief you seek, and the reason you seek the relief; 

We seek relief from paragraph (b) (3) "The tandem parachute system contains an operational 

automatic activation device for the reserve parachute, approved by the manufacturer of that tandem 

parachute system." 

(d) The reasons why granting your request would be in the public interest; that is, how it would 

benefit the public as a whole; 

The rule, as it is now written requires the "mandatory" use of AAD on Tandem Equipment. Recent 

solo jumping fatalities have been caused by the Automatic Activation Device cutter failure to cut and 

thus trapping the retaining loop, which in turn prevents the activation of the reserve parachute by 

the ripcord, 

The continuation of this rule endangers the public. If such a failure were to occur on a Tandem 

Parachute there would be two fatalities instead of one. 

The approval by the manufacturer was predicated on the long standing FAA doctrine, regarding the 

use of AAOs, of "must not interfere with the normal operation of the certificated assembly" and as 

such was intended for the manufacturer to only approve the installation, not the device itself, to 

assure no interference. Subsequently, we have learned the cutter or activation device can and will 

trap the loop during its failure to cut which in turn fails the Certificated Reserve by preventing the 

activation by a normal ripcord pull. 

(e) The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from which you 

seek the exemption; 

Continued Mandatory use of Automatic Activation Devices on Tandem parachute assemblies will 

adversely affect the public safety. We can not risk a dual fatality, especially one which is caused by 

the failure of a non-Certificated assembly which prevents the "normal function of a Certificated 

Assembly". 

The use of Automatic Activation Devices on Tandem Parachutes is a good thing which Parachute 

Labs., supports. However, it appears we (Tandem Manufacturers & The FAA) jumped the gun on 

the adoption of this rule. Field use has proven AAO's, which are currently available on the market, 

unreliable and subsequently dangerous. 

This rule must be suspended until AAD's are Certificated by the FAA or are re-designed to use 

activation devices other than "loop through cutters". If the rule requiring the Tandem Manufacturer's 

approval is re-instituted by the FAA it must be cfear that it means only the installation requires 

approval by the Tandem manufacturers not the device itself. 

Failure to waive or suspend this rule could shut down Tandem Parachute operation across the 

country and possibly world wide. Tandem operations are generally done on a commercial basic and 

such a shut down would hade a devastating effect on local economies that depend on these 

operations for a revenue stream. 

(f) A summary we can publish in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and 
Parachute Labs,. Inc .is seeking relief from Federal Aviation Administration 14 CFR FAR Part 105.45 

Para, b.3. 

(2) A brief description of the nature of the exemption you seek; 

Relief is sough from the mandatory use of non-Certificated Automatic Activation DeviGes on 

Tandem Parachutes. This relief is necessary to prevent potential dual fatalities during Tandem 

Parachute operations. This request is based upon the failures of such devices on solo parachutes 

and the revelation that the failure of the method of activation can in fact prevent the "normal 

operation of the Certificated reserve parachute", preventing the activation of the Certificated 

reserve parachute with the ripcord. 

(g) Any additional information, views or arguments available to support your request; and 

Recent world wide developments, within Skydiving, have shown that the method of activation used 

by the current crop of Automatic Activation Devices is conceptually flawed. The method of using a 

"Cutter" to activate a parachute has been around for years in the military cargo drop technology. It 

was up until recently considered to unreliable for personnel use. It is the method currently in use on 

all of the AADs available on the market. Its use requires the parachutes cloth closing/retaining loop 

pass through the eye of the cutter where a guillotine blade would sever the loop upon activation. 

Unfortunately not all cutters have successfully cut all the loops all the time. These failures have 

caused fatalities and their continued use must be under advisement to the user and the use of same 

should be of an advisory nature not "Mandatory" 

(h) If you want to exercise the privileges of your exemption outside the United States, the reason 

why you need to do so. 

Tandem Parachuting is a world wide activity. The safety of the world wide tandem jumping public 

could be at stake were this exemption to not be extended to beyond the borders of the United States. 

The world looks to us for leadership in this field. 

Ibis concluds our response I hope that it meets with your expetation and requirement. If there are 

· ·· s or issues please contact me. 

(/ -- herman 

Engmeering Manager 

Parachute Labs., Inc. dba Jump Shack 

1665 Lexington Ave. Suite 106 

Deland, Fl. 32724