NPRM for 180 day inspection cycle comment period closed

[councilman24 37]

The comment period for the 180 day repack cycle is closed. The original thread discussing this after the NPRM was published is http://dropzone.com/cgi-bin/forum/gforum.cgi?do=post_view_flat;post=2816528;page=1;sb=post_latest_reply;so=ASC;mh=25;

ALL of the comments submitted can be viewed at http://dms.dot.gov/search/searchResultsSimple.cfm by seaching for "21829" edited to fix search string There are seven pages of comments, 320 comments in total.

Two are labeled under Title "Parachute Industry Association". Neither of these comments are official positions of the PIA. If you click on the document number on the left you can see who posted these comments. I'm sure they were simply identifying the organization they were affiliated with.

The full PIA did not take a position after the NPRM was issued because no general meeting was held during the comment period. As Chairman of the Rigging Committee I considered polling the official members of the Rigging Committee for the Committee position and submitting it. I chose not to because, as can be seen from the comments, there are a variety of positions on this issue. Past Rigging committees have been divided and have engaged in spirited discussion. PIA had proposed jointly funding a study with USPA to gather empirical data. USPA hadn't yet responded to the request when we decided to submit a waiver application. A procedure would have been included in the waiver to gather data from the field. The FAA chose to reject the waiver request and move directly to NPRM.

The Rigging committee is a rather limited number of individual who have indicated at recent meetings that they wanted to be members. (All members expressing interest have been made members of the Rigging Committee.) Since the PIA membership as a whole can't take action except in person at a meeting, and since the rigging committee is a very small subset of the membership, I chose not to submit the opinion of the rigging committee and let the members comment individually. I truly don't know what way a Rigging Committee poll would have went. I know there are members on all sides of the issue.

I have read many of the comments but haven't yet taken time to read all 320. There are those against, those proposing a modified rule, and many supporting the NPRM. Including some of by best pilot rigging customers! I knew I shouldn't have told them about it! Unless someone beats me to it I'll try to tabulate for, against, and modified in the near future.

As you will see my comment is limited to making tandem mains consistent with single harness/dual parachute systems. This was over looked when tandem was incorporated into the regs and is still omitted in the NPRM.

I've been one of the members of the rigging committee who felt that maintenance issues other than the reserve system itself offset the advantage of 180 day versus 120 day cycle. I still feel that way to a large extent. I realize that 180 day and longer inspection cycles have worked elsewhere in the world and that handling does as wear to the components. I'm still of mixed feelings.

Thanks again to Allen Silver and his son Darrin for all their work on this issue.

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

[jheadley 0]

Just search for "21829". if you include the first parts, the search comes up negative.

[councilman24 37]

Thanks, thought I tried it. Original post edited.

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

[bodypilot90 0]

any news?

[2shay 0]

so when is the decision suppose to be made? What in your opinion were the approimate percentages of people for, against, or indifferent

don't try your bullshit with me!!!

[councilman24 37]

The FAA has 18 MONTHS to make a decision. I don't expect anything until at least the middle of next year.

All the following number are approximate. There were about 325 comments. 298 were yes comments. Of those that self identified there seemed to be more glider pilot, and then more pilot, comments than anyone else.

There were 9 NO comments. I believe all from riggers, almost all from fulltime riggers. There were 4 riggers who thought it should remain 120 for any gear used by someone other than the owner (student, tandem, rental skydiver and pilot, etc) and 180 was okay for user owned gear. There were 8 that thought it should go to a year. 3 others and one that thought it would kill hot air ballooning. ? Yes I don't think the numbers add up. I did it late one night.

Most of the yeses were based on it saving money and repeating what pilots heard about it causing less damage to the parachutes.

The No's were mainly based on too much other stuff going wrong or needing maintainence in a 120 days let alone 180.

My best late night guess is that the yeses included about the same number of fulltime riggers as the No's. There were probably more total riggers in the yeses, mayby 20.

The FAA has to respond to each negative comment in particular and in detail. All of this takes time. Some members of PIA believe that it is a done deal, that we have to wait out the clock. I'm not as confident, but I'm always the pessimist. Probably the best thing going is that much of the rest of the world uses something longer.

At the FAA website you can subscribe to new rule making publications and get email notification. That way you'll know when I know.

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

[councilman24 37]

See above post.

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

[rehmwa 2]

Bump -


Another jumper mentioned that the latest Skydiving magazine made note that it's a "go" in March 08.

Searching the docket, all I see are the comments and nothing newer than that. But I'm not proficient in surfing that site at all.

...
Driving is a one dimensional activity - a monkey can do it - being proud of your driving abilities is like being proud of being able to put on pants

[councilman24 37]

I don't remember seeing what your mentioning but...

NOBODY knows what will happen or when. Some people closely involved THINK it will happen in 08. The clock doesn't end until 18 months from August, in 2009.

IMHO there were enough substantive negative opinions that the FAA could choose to do many different things. And each negative opinion must responded to in the final rule.

I'm old for my age.
Terry Urban
D-8631
FAA DPRE

[rehmwa 2]

I found the article yesterday - the mag was just speculating. THANKS

...
Driving is a one dimensional activity - a monkey can do it - being proud of your driving abilities is like being proud of being able to put on pants