# t!1 Piltachute**Labotatotie~** 

# Inc. 1665LexingtonAve. #106Delantt FL32724 USA (3861 734·5867 FAX (3861 734--8464 www.Jumpshack.com

Federal Aviation Administration Ms. BrendaD. 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 ofNovember I0, 2011**re~arding** my application for exemption from §105.43(B)(3) ofTitle 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 informati on must I include· in my pel.ition for an exemption? You must include the following i nformation in your petition for an exemption and submit it to FAA as soon as you know you need an exemption. (a) Your na m e and mailing address and, if you wish, other contact inform ati on such as a fax number, telephone number, or e-ma il 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 ofthe Federal Aviation Administration 14 CFR FAR Part 105.45 Para, b.3. 

### It currently states: (b) No person may make a parachutejump 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 ofthat tandem parachute system. The device must

...(c) Th e extent of relief you seek, and the reason you seek th e 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) Th e reasons why gra nti ng you r request wo uld be in the p ubl ic i nterest; that is , how it woul d benefit th e publi c 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 fai l ure 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 fa i lure 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 ofthe 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) Th e reaso ns w hy granti ng the exem pt ion wo u ld not adve rsely affect safety, or how the exemption wo u ld p rovi de a level of safety at least equal to that provided by th e rule f rom w hich you seek the exempt ion; 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 approva l 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 sum ma ry we can publ ish in the Federa l Reg ister, stating : (1) The rule from wh ich you seek the exemption; andParachute Labs,. Inc .is seeking relief from Federal Aviation Administration 14 CFR FAR Part 105.45 Para, b.3. (2) A brief d escription of the natur e 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 fa i lure 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 additi on a l info rmation, vi ews o r a rg u me nts avail abl e to s u p port 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 yo u want to exe rcise the pri vileges of your exe m ption outside t he U nited States, t he reason w hy you need to d o so. Tandem Parachuting is a wo rld 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 ofthe 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. Ifthere are

· ·· s or issues please contact me. 

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# -- herman Engmeering Manager Parachute Labs., Inc. dba Jump Shack 1665 Lexington Ave. Suite 106 Deland, Fl. 32724