Jim Puckett ~ Aviation Consultant

 Technical, Legal & Certification Expert

PO Box 423 Dunlap, CA 93621 Cell 805-890-7047 Fax 559-338-3260

Email: jim.puckett@unwiredbb.com

US Department of Transportation

Docket Operations

West Building, Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20595

Attn: Office of Rulemaking

Ref. FAA-2011-0492

Additional Information

Under the provisions of 14CFR11 Rule Making Procedures, we request an exemption to 

14CFR43.13 (a) and 14CFR43.16 where Airworthiness Limitations require that a Type 

Certificated Product which has Airworthiness Limitations must be followed. Specifically where 

the Airworthiness Limitations approved for Cirrus Design model SR20 and SR22 aircraft restrict 

who may perform maintenance on the ballistic parachute system. 

• 14CFR 43.13 (a) in pertinent part:

Each person performing maintenance, alteration, or preventive maintenance on an aircraft, 

engine, propeller, or appliance shall use the methods, techniques, and practices prescribed in 

the current manufacturer's maintenance manual or Instructions for Continued Airworthiness 

prepared by its manufacturer, or other methods, techniques, and practices acceptable to the 

administrator, except as noted in §43.16.

• 14 CFR43.16 Airworthiness Limitations.

Each person performing an inspection or other maintenance specified in an Airworthiness 

Limitations section of a manufacturer's maintenance manual or Instructions for Continued 

Airworthiness shall perform the inspection or other maintenance in accordance with that section, 

or in accordance with operations specifications approved by the Administrator under part 121 or 

135, or an inspection program approved under §91.409(e).

As the FAR reads, “each person,” is compelled to perform according to the Manufactures’

current maintenance manual or Instructions for continued airworthiness prepared by its 

manufacturer. However other methods, techniques, and practices may be used if acceptable to 

the administrator. Airworthiness limitations of the manufacture’s manual or Instructions for 

continued airworthiness must also be followed.

Cirrus Design Corporation Model SR20 and SR22 Ballistic Parachute System, specifically the 

CAPS system, in accordance with Airworthiness Limitations, excludes anyone other than 

persons that are trained and or certified by Cirrus Designs systems from performing 

maintenance or inspection required during repacking the parachute at the required ten year 

intervals.

There is no mechanism that we are aware of that defines who “each person” is as described in 

the above regulations except 14 CFR 43.3 Persons Authorized to Perform Maintenance, 

Preventive Maintenance, Rebuilding, and Alterations. 
Jim Puckett ~ Aviation Consultant

 Technical, Legal & Certification Expert

PO Box 423 Dunlap, CA 93621 Cell 805-890-7047 Fax 559-338-3260

Email: jim.puckett@unwiredbb.com

The ballistic parachute is required to be installed for Type Certification and may not be operated 

without its installation and continued airworthiness. There are more than 4000 Cirrus SR20 and 

SR22 aircraft in operation. Currently many aircraft have reached the first 10 year interval for 

mandatory repack and inspection of the ballistic parachute. A backlog has been created causing 

many operators to discontinue use until the repack can be accomplished. There is no provision 

to operate the aircraft without a serviceable parachute.

Ballistic Recovery System (BRS) is the original inventor, designer, and manufacturer of the 

General Aviation Recovery Device (GARD) ballistic parachute system as evidenced in the 

Special Conditions required for the type certification of the two Cirrus Models. It should be noted 

the CAPS ballistic parachute system is currently installed in some models, but is essentially the 

same including the required repack requirement.

We are requesting exemption to the above mentioned regulations because we can find no 

regulatory basis for the verbiage that allows the restriction of who may maintain this specialized 

equipment without including the manufacturer of the equipment. 

This equipment is installed as an emergency apparatus used when the aircraft is no longer 

airworthy for whatever reason and is deployed by the pilot or in some instances a passenger to 

deliver the aircraft and its occupants to the ground thus greatly diminishing damage to the 

aircraft, property, injury to occupants, and bystanders on the ground.

We believe it is in the interest of public safety, and would benefit the public to have this 

equipment maintained and inspected to the highest degree of safety. We believe the parachute 

manufacturer would fit that requirement.

Because of the expertise that BRS has exhibited we believe the above mentioned regulations 

would continue to maintain the same level of safety as provided. We do not believe these 

regulations envisioned restricting qualified persons form performing proper maintenance using 

the provisions of airworthiness limitations.

We can be reached at Attn. Mr. Boris Popov, Ballistic Recovery Systems (BRS)

380 Airport Road 

South Saint Paul, MN 55075-3551

Telephone 651-457-7491

Fax 651-457-8651

E mail bpopov@BRSparachutes.com

Or Mr. Jim Puckett at the contact addresses on this letter.

Sincerely

James Puckett

Agent for Service