Jim Puckett - Aviation Consuitant 

Technical, Legal & Certification Expert 

PO Box 423 Dunlap, CA 93621 Cell 605-890-7047 Fax 569-338-3260 

Emalt: iim.puckett@unwiredbb.com 

US Department of Transportation 

Docket Operations 

West Building, Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20595 

April 29 2011 

•ARTMENKJ F 

Isoi^ORTOlQM 

^T OPERAT'OMS 

Under tlie 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. 

• 14CFR43.13(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. 

• 14CFR43.16 Ainworthiness 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 periderm 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 t>e used if acceptable to 

the administrator. In the case of the 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 AinM/orthiness 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. 

Currently many aircraft have reached the first 10 year interval for repack of the ballistic 

parachute. These operators or owners are forced to wait for service because of the exclusive 
clause restricting who may perform this maintenance. 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. 

Ballistic Recovery System (BRS) is the original inventor and designer 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 issued. It should be noted that we 

have found no documentation which changed the system name from GARD, which appears in 

the Special Conditions originally issued for Cinus Design SR20 and SR22 

BRS Parachutes was the original inventor and designer of the parachute that is installed in the 

aircraft as well as holder of an STC and PMA for ballistic parachutes in some models of Cessna 

aircraft. 

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

regulatory basis for the verbiage that allows the restriction and we believe it is In the interest of 

public safety, and would benefit the public to have this equipment maintained in a timely 

manner. 

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 letterhead. 

Sincerely 

James Puckett 

^gen t for Service