PARASAIL SAFETY COUNCIL a 'safety first' parasaii commuitrty 

July 5, 2011 

SENT VIA REGULAR MAIL AND FEDEX 

U.S o-<—; . Department of Transportation ' 

Docket Operations Y> ^>^ ^ 

West Building Ground Floor ci O^? . 

Room W12-140 ZJ "" 

1200 New Jersey Avenue, SE., 

Washington, DC 20590 

Re: Petition for Rulemaking -Proposed Amendment to 14 CFR 

PETITION FOR RULEMAKING 

The Parasail Safety Council hereby petitions for rulemaking to amend two Subchapters of the 

Federal Aviation Regulations. Subchapter A, Definitions, to include the definition of a 'parasail' 

device and Subchapter F, to further define aspects of a parasail and to regulate its operation and 

equipment in a manner and method acceptable to the Administrator of the Federal Aviation 

Administration. This petition is made pursuant to Section 11.61 et seq. of the Federal Aviation 

.Regulations. Specifically, Subchapter A, Definitions, Part 1 Definitions and Abbreviations 

should be amended to include the definition for 'parasail' as a 'gliding parachute'. Subchapter F, 

Air Traffic and General Operating Rules, sections 91-105 amended to include a section titled 

'Parasail Operations' whose subparts would include General Information, Operating Rules and 

Parasail Equipment. 

INTEREST OF THE PETITIONER 

The Petitioner is the Parasail Safety Council, hereafter 'Petitioner', and its advisory board 

including parasail expert and parasail equipment patent holder Mark McCulloh. The Safety 

Council is a worldwide, not-for-profit subscription organization based in Orlando, Florida. Its 
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primary mission is to promote-safety in the manufacture and use of parasail systems. Petitioner 

has more than 58,000 individuals, private and government institutions and parasail operators as 

subscribers. They comprise nearly every commercial parasail operation in the United States, as 

well as, many federal and state legislative and enforcement agencies. Its subscribers operate 

nearly every parasail flight in the U.S. which Petitioner estimates at 3-5 million annually 

exceeding that of commercial sport skydiving. Petitioner and its subscribers have been 

particularly and substantially affected by the interpretations and regulations applied by the 

Administrator as a result of its Memorandums and directives. This includes incompatible flight 

rules, reporting requirements which cannot be complied with and certificates of waivers. The 

Petitioner has also found 14 CFR to be lacking in its oversight of the sport. Petitioner's 

subscribers and the public at large will continue to be affected by and placed at risk because of 

the lack of appropriate regulation. 

An important issue raised by the Petitioner in a series of Memorandums on parasail safety and 

regulation published earlier this year was the interpretation of parasailing by the FAA in a 

Memorandum dated November 09, 2009 authored by Ms. Rebecca Macpherson, chief counsel 

for FAA regulations. In an effort to positively address the issues surrounding parasailing as it 

relates to the FAA's regulation over the nation's airspace. Petitioner offers this practical and 

effective proposal. 

Petitioner recognizes that parasail operations require both safety authority from the FAA 

and economic authority from the Office of the Secretary of Transportation in order to be 

adequately regulated. The purpose of this petition is to address safety. 

BACKGROUND 

The FAA by way of Memorandum took the legal position that a 'parasail' falls within the 

definition of a 'kite' as it pertains to 14 CFR. The Civil Aeronautics Board, the predecessor to 

the FAA, began regulating kites in 1954. See, 19 FR 7719, 7720 (November 30, 1954). The 

FAA continues to regulate kites to the extent that they are objects in airspace. 
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These regulations are prescribed in 14 C.F.R. Part 101, subpart A and B. Section 

§ 101.11 Applicability. This subpart applies to the operation of moored balloons and kites. 

However, a person operating a moored balloon or kite within a restricted area must comply only 

with §101.19 and with additional limitations imposed by the using or controlling agency, as 

appropriate. Section 101.13 states, in relevant part, that no person may operate a kite less than 

500 feet from the base of any cloud, more than 500 feet above the surface of the earth, or from an 

area where the ground visibility is less than three miles. Section 101.15 states, in relevant part, 

that no person may operates kite more than 150 feet above the surface of the earth unless, at least 

24 hours before the operation, the operator provides the following information to the FAA air 

traffic control facility that is nearest to the place of intended operation: the names and addresses 

of the owners and operators, the size and weight of the kite, the location of the operation, the 

height above the surface at which the kite is to be operated, and the date, time, and duration of 

the operation. In addition, for daytime operations, section 101.17 require, in relevant part, that 

the kite's mooring lines have "colored pennants or streamers attached at no more than 50 foot 

intervals beginning at 150 feet above the surface of the earth and visible for at least one mile. 

The Petitioner reviewed the FAA Memorandum dated November 9, 2009, attached hereto, 

because of the impact it had on the commercial parasail industry and concluded that the opinion 

and conclusions do not apply to the sport as practiced today and present a fundamentally flawed 

interpretation of 14 CFR Part 101 on several points raising into question whether 14 CFR Part 

101 applies to commercial parasailing. 

DISCUSSION 

This petition addresses the Federal regulation of moored and unmoored manned parasails. 

A. UNMOORED PARASAIL: PARACHUTE 

Petitioner requests the Administrator to expand the definition of 'Parachute' to include an 

'Unmoored Parasail' accordingly making it subject to the FAA regulations applicable to 

parachutes. 
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The Federal Aviation Administration defines a parachute as, '... a device used or intended to be 

used to retard the fall of a body or object through the air.'' Three to five millions people 

experience the thrill of gliding hundreds of feet above the earth each year with the assistance of a 

parasail. The history of the parasail goes back nearly five decades with the early involvement of 

its design and use by NASA and the U.S. Military^. NASA used the parasail in free flight as a 

vehicle recovery device because of its unique abilities to act as a parachute in retarding an 

object's fall and to glide. In 1963 NASA called the parasail an, 'all flexible gliding parachute'^ 

contrasting it with a para-glider which has a framework and acknowledging its physical 

attributes to be that of a modified parachute. The FAA's investigators of the 2004 Gulf Shores, 

Alabama incident and the author writing, in response to a request for clarification, on behalf of 

the Administrator in the Nov. 2009 Memorandum both called the parasail a. parachute^. 

NASA and the U.S. military^ have been using the parasail to train astronauts and paratroopers 

taking advantage of the parasail's abilities to ascend followed by a free flight descent^. They 

launch the parasail by tethering it to a vehicle then releasing the tether or by self-launching from 

an elevated terrain or structure. In both cases the paratrooper or astronaut is exposed to the free 

flight of the parasail giving them a parachute- like experience without the need or cost of an 

aircraft. Recognizing the dangers and thus the need for water survival techniques, they perform 

free flight descent training over both land and water.' Sport skydivers also use parasails in the 

same manner they use parachutes. 

In its November 9, 2009 Memorandum the FAA reviewed the recommendations of their 

investigators following the 2004 collision between a parasail operation and an aircraft banner -

' 14 CFR Aeronautics and Space, Part 1 Definitions and Abbreviations §1.1 General Definitions 

^ www.parasail.org/parasail_history_pictorial_1961_201 l_slide.html 

^ http://history.nasa.gov/SP-4203/ch7-3 .htm 

^ FAA Memorandum Applicability of 14 C.F.R. Part 101 (Moored Balloons, Kites, Unmanned 

Rockets and Unmanned Free Balloons) to parasails and parasail operations E>td. Nov 9,2009 p 1, pp 1, line 4 

^ http://www.history.navy.mil/download/train-06.pdf 

* http://www.jsc.nasa.gov/history/roundups/issues/63-09-l 8.pdf 

^ http://www.jsc.nasa.gov/history/roundups/issues/63-09-l8.pdf 
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Pages 

towing operation. In its conclusion the author wrote in part, 'Accordingly, parasails and parasail 

operations are subject to the FAA regulations applicable to kites.'* 

Petitioner believes that this statement was meant to address the specific set of facts which the 

author was presented with and not to be read as a general position statement regarding 'all' 

parasails. The author was specifically addressing a 'moored parachute towed by a boat' which 

was given as the definition of a parasail. An unmoored or free parasail was not considered in the 

analysis or the discussion. The Petitioner suggests that the narrow interpretation of the author's 

statement to the facts is the appropriate conclusion. Petitioner proposes that different regulations 

apply to an unmoored parasail and requests the Administrator to: (1) expand the definition of a 

parachute to include an unmoored parasail and (2) subject unmoored parasails to the FAA 

regulations applicable to parachutes. 

B) MOORED PARASAILS 

Petitioner requests that moored manned parasails be regulated under 14 CFR, Subchapter 

F, Air Traffic and General Operating Rules, by adding a section titled 'Moored Parasail 

Operation' applicable to 'manned moored parasails'. 

The FAA's November 9, 2009 Memorandum found that moored parasails were kites and 

subsequently §101 in particular Subchapter B Moored Balloons and Kites applied. Petitioner 

takes exception to the appropriateness of this conclusion. The FAA investigators suggested that 

the FAA, 'Expand the definition of a kite or moored/tethered object to include "parasail" thus 

making parasail operations subject to the restrictions of 14 C.F.R. Part 101 regarding altitudes 

and tow line markings.' This suggestion was made after acknowledgment by the investigators 

that, 'there are no regulations in 14 C.F.R. specifically referring to the operation of parasails'^. 

With this conclusion Petitioner agrees and adds that there continues to be no section in 14 C.F.R. 

that appropriately and specifically regulates manned moored parasails. 

' FAA Memorandum Applicability of 14 C.F.R. Part 101 (Moored Balloons, Kites, Unmanned 

Rockets and Unmanned Free Balloons) to parasails and parasail operations Dtd. Nov 9, 2009 p2, pp 7, line 4 

'ibid. pl,pp2, linel 
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Is a moored parasail an aircraft? 

The FAA has defined an aircraft as ' a device that is used or intended to be used for flight in the 

air.' NASA defines it as, 'Any structure, machine, or contrivance, especially a vehicle, 

designed to be supported by the air, being borne up either by the dynamic action of the air upon 

the surfaces of the structure or object, or by its own buoyancy.'" 

In its review of parasail devices and subsequent regulation, the FAA first analyzed whether a 

parachute [parasail] being towed by a boat was an aircraft and thus applying the portions of 14 

CFR that regulate aircraft and aircraft operations. The gyro-glider operated by means of a 

towline'^,' the hang glider flown at the end of a rope'^ and the parachute towed by a boat were all 

found not to be aircraft because they were not, used or intended for 'free flight'*''. The FAA 

Memorandum's author concluded, 'free flight rather than conveyance of a person as the line 

between a kite and an aircraft."'^ Petitioner noted that the FAA reserved its right to reconsider a 

moored device an aircraft. Following the FAA's logic a moored parasail is by definition not 

used or intended for 'free flight', unless later released, and thus the FAA concluded that it was 

not an aircraft. As to a moored parasail. Petitioner agrees with this conclusion. 

Is a moored parasail a kite? 

The FAA defines a 'kite' as, '.. a framework, covered with paper, cloth, metal, or other material, 

intended to be flown at the end of a rope or cable, and having as its only support the force of the 

wind moving past its surfaces.''^ NASA defines a 'kite' as an, 'unpowered aircraft.''^ 

'° 14 CFR Aeronautics and Space, Part 1 Definitions and Abbreviations §1.1 General Definitions, Aircraft 

" http://er.jsc.nasa.gOv/seh/a.html 

" FAA Memorandum Applicability of 14 C.F.R. Part 101 (Moored Balloons, Kites, Unmanned 

Rockets and Unmanned Free Balloons) to parasails and parasail operations Dtd. Nov 9, 2009, p2, pp5, line2 

'^ Ibid. p2, pp5, line9 

'" Ibid. p2, pp5, line? 

' ' Ibid. p2, pp5, line? 

'* 14 CFR Part 1 Definitions and Abbreviations, §1.1 General Definitions, Kite 

' ^ http://www.grc.nasa.gov/WWW/K-12/airplane/guided.htm 
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Once a device is found not to be an aircraft the FAA analyzed whether or not the device was 

similar enough to be included in the definition of a device it already regulates. With respect to 

moored parasails they concluded 'kites' were similar. The FAA wrote, 'The parasail defined 

during the investigation falls within the definition of a "kite" because it is a parachute held aloft 

by the wind resulting from the movement of the boat towing it. Additionally, a parasail is 

similar to other objects previously determined to be kites.''* Petitioner notes that it appears that 

the FAA author applied the kite definition to describe the facts rather than asking whether the 

facts were similar to the definition. Petifioner addresses this issue below. Petitioner assumes that 

the author was using the FAA investigator's definition of parasail in this instance as being 

'parachutes that are towed by a boat.' In that regard Petitioner agrees that the gyro-glider, hang 

glider and parasail were similar in how they were being used; they were all dynamically moored 

to a vehicle. With this conclusion Petifioner agrees. 

While on the surface, kites and parasails appear similar, there are fundamental differences. 

Mooring for the gyro-glider, hang glider and parasail plays a radically different role then the 

mooring of a kite. If the operator of the first three devices intends, all can perform free flight, 

independent of tethering. In fact parasails, even when moored, descend under their own design 

with neither tethering or wind playing a role in its ability to fly. Kites on the other hand require 

that the resulting force vector from the lift and drag force components of its design to be opposed 

by the tension of the tether in order for it to fly. Kites are mooring dependent' regardless of the 

operator's intent. Parasails are mooring independent not unlike a glider or sailplane. 

The FAA investigators were partially accurate in their assessment of the parasail. They defined 

parasails as 'parachutes that are towed by a boat, an automobile, or other means on the surface 

and are held aloft only by the wind provided by the surface vehicle's motion.' As NASA 

pointed out a parasail is indeed a parachute which has been modified , enabling it to glide. 

^* FAA Memorandum Applicability of 14 C.F.R. Part 101 (Moored Balloons, Kites, Unmanned 

Rockets and Unmanned Free Balloons) to parasails and parasail operations Dtd. Nov 9, 2009 p2, pp6, line3 

''Ibid, pi, ppl, line4 
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However, they understated the dynamics of a parasail to the extent that a parasail doesn't require 

wind from the forward motion of the mooring vehicle or vessel to be held aloft. Like many other 

glider^° type aircraft and devices, parasails simply need altitude to begin free flight. Petitioner 

takes exception to the FAA defining a moored parasail as a 'kite' based on their fijndamental 

differences of tether dependence and independence, as well as, the parasails ability to fly without 

wind. 

Is 14 CFR 101 relevant and appropriate for the regulation and safety of manned moored 

parasails? 

Should the FAA find after carefiil re-examination that a moored parasail is a kite, one must ask, 

'Are the regulations found in 14 CFR 101 and in particular Subpart B relevant and appropriate 

for the regulation of commercial parasail operations launching millions of manned flights?' This 

Petitioner believes they are not. 

Section 101 applicability to unmanned devices. 

Legislative intent. 

Petitioner found compelling evidence in the words of the FAA, as well as, in the language of 14 

CFR §101 that Section 101 was not intended to apply to manned devices. The November 2009 

Memorandum paraphrasing the FAA's earlier position on kite regulation wrote, 'The Civil 

Aeronautics Board, the predecessor to the FAA, began regulating kites in 1954 to the extent that 

they pose a hazard to the flight of aircraft.^^^ The FAA made it abundantly clear in that statement 

that their focus was on the welfare and safety of other aircraft not the kite and in particular not 

kite passengers. 

20 

14 CFR Aeronautics and Space, Part 1 Definitions and Abbreviations §1.1 General Definitions: Glider means a 

heavier-than-air aircraft, that is supported in flight by the dynamic reaction of the air against its lifting surfaces and 

whose fi-ee flight does not depend principally on an engine. 

^' 19 FR 7719. ??20 (Nov. 30, 1954); Ibid p2, pp8, linel 
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The FAA limited their regulation of kites in §101 because they did not envision kites to be 

manned; they did not regulate a hazard that they did not envision; kite passengers. Petitioner 

asserts that had the FAA intended to regulate manned kites they would have done so by invoking 

relevant regulations and presenting a much different position statement. 

The author of the 2009 Memorandum reinforced this position by writing, 'The FAA continues to 

regulate kites only to the extent that they are objects in the airspace.'^^ The operative term being 

objects. The FAA does not see kites as passenger bearing, they are merely objects that may pose 

a threat or hazard to others. Again, these are not the words of an Administrator regulating a 

manned device. Petitioner believes they are the words of one who saw their mission with respect 

to kites as regulating a device only. This regulatory intent is found throughout the language of 

Section 101 as well. 

Section 101. 

There are extensive FAA regulations regarding manned devices because the FAA understands 

that placing a person into the airspace involves an acknowledged risk of harm and that regulation 

assists the Administrator in its mission of airspace safety to objects and people. Section 101 and 

its Subparts are clear in their language that they were intended to apply only to 'unmanned' 

devices. 

Subpart C, Amateur Rockets §101.21 reads in its pertinent part 'a) this subpart applies to 

operating unmanned rocVs.is.'' Subpart D, Unmanned Free Balloons §101.31 reads in its pertinent 

part 'a) this subpart applies to the operation of unmanned free balloons.' While Subpart B, 

Moored Balloons and Kites is not as explicit it is no less clear in carrying out the legislative 

intent to regulate objects not people. Section 101.19 continues this theme as it regulates moored 

balloons and kites. 

FAA Memorandum Applicability of 14 C.F.R. Part 101 (Moored Balloons, Kites, Unmanned 

Rockets and Unmanned Free Balloons) to parasails and parasail operations Dtd. Nov 9, 2009 p2, 
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Section 101.19 reads in its pertinent part 'No person may operate a moored balloon unless it has 

a device that will automatically and rapidly deflate the balloon if it escapes from its moorings.'^^ 

This is not the language one uses to regulate a 'manned' device. It makes it abundantly clear that 

the drafters didn't envision the balloon to be 'manned' or they would not have required that the 

balloon be 'automatically' deflated. Had it been manned the occupant(s) would have performed 

that task of deflation. Nor would they require that the balloon be 'rapidly deflated', insinuating a 

rapid and dangerous descent. These are not the words of an Administrator managing or 

intending to manage the risk of hazard to human life. 

Continuing the analysis of §101.19, kites did not require an automatic device to bring them 

rapidly back to earth because the drafters new that an untethered kite cannot continue to fly.^'' 

The drafters of §101.19 understood that a kite requires tethering to function. They also knew that 

should a kite escape its moorings' the severing of its tether, being critical to its ability to fly, 

would act as the 'automatic' device which would rapidly bring it back to earth. The drafters 

clearly anticipated unmoored kites falling harmlessly from the sky, averting midair collisions. 

They did not envision having passengers involved in this perilous event. 

None of the regulations in Section 101 reflect the thoughts of writers that anticipated passengers 

would be involved; they envisioned unmanned devices. Petitioner asserts that there may in fact 

be manned moored balloons and manned moored kites, but §101 was not intended or drafted to 

regulate either of them. It is a misapplication of the regulations to do otherwise. 

Absence of airworthiness and standards of conduct. 

Section 101 yields additional evidence that it was not intended to regulate manned devices. 

Conspicuously missing are airworthiness standards for the devices. The FAA is excellent at 

managing risk to passengers in flight. They have accomplished this by establishing extensive 

airworthiness standards for devices that are manned. §101 Subpart B Moored Balloons and Kites 

does not contain any airworthiness language. 

14 CFR Subchapter F, Air Traffic and General Operating Rules, §101.19 

10 

"" See: Page 6, paragraph 3 above 
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Was this an oversight by the drafters? Petitioner asserts that it was not. Airworthiness was 

unnecessary because Subpart B only applies to unmanned devices. In fact airworthiness 

standards for manned kites was not found in any section of §101 . The only logical conclusion 

drawn form this absence is that §101 was intended to only regulate 'unmanned' devices. 

Also absent in §101 are any references to other regulations involving moored balloon and kite 

operator and passenger standards of behavior, training, qualifications, equipment, safety 

instructions and limitations. 

Moored Kite Exclusion §101.11 

Further evidence of the drafters intent is found in §101.11 Applicability which reads in part 

'However, a person operating a moored balloon or kite within a restricted area must comply only 

with §101.19 and with additional limitations imposed by the using or controlling agency, as 

appropriate.'^^ As there is no language in §101.19 regarding moored kites, §101.11 effectively 

defines moored kites operated in a restricted area as being unregulated by Subpart B, leaving its 

control up to a controlling agency of the area. Undoubtedly not an outcome one would choose 

for the safety management of a manned device. 

Should the Administrator find that a parasail is a kite. Petitioner reasserts that 14 CFR §101 was 

not intended to regulate moored manned kites. 

The unintended consequences of §101.03 Waiver. 

The lack of relevance of §101 to commercial parasail operations has caused unintended 

consequences for the Administrator as well as commercial parasail operators and their 

customers. 

^' 14 CFR Subchapter F, Air Traffic and General Operating Rules, §101.11 Applicability: This subpart applies to the 

operation of moored balloons and kites. However, a person operating a moored balloon or kite within a restricted 

area must comply only with §101.19 and with additional limitations imposed by the using or controlling agency, as 

appropriate. 

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Much if not all of Secdon 101 is violated during the normal course of parasail operation. The 

Operafing Limitations found in §101.13 and the Notice Requirements of §101.15 are common 

sources of this problem. In order to avoid non-compliance sanctions parasail operators routinely 

apply for and receive long-term certificates of waiver under §101.3^^. This wholesale approach 

to long-term waivers has resulted in the lack of meaningful regulation of a sport which oversees 

more than three million passenger flights per year. 

SUMMARY 

More than three to five million people each year are passengers on a moored parasail. An 

additional unknown number use parasails as parachutes. Neither moored or unmoored parasails 

appear to be regulated by the Administrator. The foregoing analysis of issues leads the Petitioner 

to request four amendments to 14 CFR (1) to include the expansion of the definition of a 

parachute to include an unmoored parasail; (2) to find that a moored parasail is not a kite as used 

in 14 CFR Part 101; (3) that 14 CFR Part 101 Subpart B does not apply to 'manned' devices and 

in particular to manned moored parasails; (4) that the commercial parasail industry needs 

specific and effective regulations. 

We urge the Administrator to rescind the Memorandum dated November 09, 2009 and that for 

the safety of the public institute effective parasail regulations. 

In light of its conclusion and the statistical fact that 99% of all parasail flights ascend and 

descend over water; that 95% of all parasail accidents resulting in serious injury or death were 

the result of an unplanned descent into water in which the parasail drags the parasail passenger 

backward through water; 

Petitioner and a consortia of parasail manufacturers, operators and experts have drafted sample 

regulations for the benefit of the Administrator and will tender such language where and when 

^* 14 CFR Subchapter F, Air Traffic and General Operating Rules, §101.3, Waiver: No person may conduct 

operations that require a deviation from this part except under a certificate of waiver issued by the Administrator. 

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the Administrator requests. To assist in beginning that process Petitioner has affixed to this 

petition proposed definitions (See: Addendum A). 

Petitioner stands ready to assist the FAA in the review, revision and formulation of proposed 

regulations. Such assistance includes the testimony of the world's leading parasail expert and 

the resources, data and analysis of the Petitioner and the consortia of concerned parties. 

OTHER INFORMATION 

To the extent this petition has not already done so, the Safety Council stands ready to respond to 

a request under FAR 11.71(b) to further address the costs and benefits to society and identifiable 

groups of this proposed action; the regulatory burden on small businesses, small organizations, 

small governmental jurisdictions, and Indian tribes; the record keeping and reporting burdens; 

and natural and social environmental effects. 

Respectfully submitted. 

Mark McCulloh 

Chairman 

The Parasail Safety Council 

Clayton & McCulloh Building 

1065 Maitland Commons Blvd. • Maitland, FL 32751 

Telephone: 407. 494.6490 • Fax 866.572.9848 

Website: www.parasail.org 

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Page 14 

Addendum A 

Proposed Defmitions 

Altitude means Above Ground Level (AGL) 

Approved parasail canopy means a parasail canopy manufactured under a type certificate or a 

Technical Standard Order (C-23 series), or a personnel-carrying U.S. military parachute (other 

than a high altitude, high speed, or ejection type) identified by a Navy Air Facility, an Army Air 

Field, and Air Force-Navy drawing number, an Army Air Field order number, or any other 

military designation or specification number. 

Automatic Release Device means a mechanical self-contained release system attached to a tow 

bar in a flexible harness parasail system or to the ridged harness in a ridged harness parasail 

system which in the former system automatically releases the tow bar from the parasail canopy 

and in the latter system automatically releases the ridged harness from the parasail canopy when 

the automatic release device is acfivated. 

Commercial parasail operation means providing or offering to provide, for consideration, any 

activity involving the towing of a parasail system by a mooring vehicle when: 

(a) One or more persons are tethered to parasail system; 

(b) The person or persons ascend above ground or sea level; and 

(c) The person or persons remain suspended above the earth while the mooring vehicle is 

underway. 

Flexible Harness means a combination of straps and webbing that physically secures and 

supports a single parasailor to a tow bar. 

Flight Zone means any pre-determined area in which parasail activity is conducted 

Level Wind means a device attached to a winch system to assist the tow line to uniformly wrap 

and unwrap from the winch spool. 

Manned Parasail means a moored parasail with a passenger or parasailor attached. 

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Mooring Vehicle means a vehicle or vessel to which a parasail is tethered 

Parasail means a gliding parachute. 

Parasailor means a person who intends to exit a mooring vehicle while attached or un-attached 

to a parasail system. 

Parasail System means the combination of an approved parasail canopy, approved^ej)c/6/e 

harness with tow bar or rigid harness and an automatic release device. 

Parasail canopy means a modified parachute that ascends when towed also referred to as an 

ascending parachute or gliding parachute. 

Parasail flight means the ascension and descension of a parasail system tethered to a mooring 

vehicle to a height of 50 feet AGL or more. 

Parasail operation means the performance of all activity for the purpose of, or in support of 

parasailing. This parasail operation can involve, but is not limited to, the following persons: the 

general public, owner or operator in command of the moored vehicle. An operation in 

compliance with the parasail operation certification rules of both the FAA and Office of the 

Secretary of Transportation. 

Parasail operator in command means the person responsible for the operation and safety of a 

parasail operation. 

Parasail Winchboat means the combination of a moored vehicle, winch system, parasail, 

iowMne, flexible harness/tow bar or rigid harness, communication equipment and USCG safety 

equipment. 

Ridged Harness means a rigid structure seating device which supports single and multiple 

parasailors in a partially seated or reclined position using gravity restraint and attaches directly to 

a parasail canopy 

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Sustained Wind Speed means a wind speed determined by averaging the observed wind speed 

rounded to the nearest whole knot over a 2-minute period. 

Towline means the rope or cable connecting the mooring vehicle to a parasail system. 

Towline guide means an upright structure which swivels and supports a series of pulley(s) 

and/or rollers which a tow line passes through 

Tow Bar means a mechanical bar like device which passenger(s) v^Qaring flexible harness system 

may be tethered to. 

Winch System means a hydraulically powered parasail system launch and recovery system 

powered by hydraulics consisting of a support frame, winch spool and level wind device. 

Winch Spool means a cylindrical piece on which a tow line is wound. 

16