All IAD/Static Line DZs using Coaches are in violation of BSR 2-1-E-4a(1)!

[skydived19006 4]

Ok, I officially applied for a Waiver; following is the content of the waiver request. After reading and rereading these rules, it comes to the point of whether the word “instructor” is capitalized or not. According to the BSRs (BSRs are the only rules to be waived, it matters not what the ISP or IRM may suggest!) a USPA rated Coach may not supervise any IAD/Static Line student, it clearly states

“2-1-E-4a(1) All jumps must be conducted by a USPA Instructor in that student's training method.”

If you read that literally (which is how literal rules should be interpreted), the word “Instructor” is capitalized, which means someone with an USPA Instructors rating (not someone with a USPA instructional rating, which would include a Coach), so a Coach is allowed to start working with IAD/Static Line students once they are no longer students, to me that means after they have their “A” license. If your DZ is allowing their Coaches to supervise any IAD/Static Line students at any phase of the ISP they/you are in violation of this BSR!
I’m trying to “light a fire” under the collective asses of the USPA Executive Council! If being in direct violation of a very specific BSR bothers you at all, you might consider contacting your Regional Director, applying for a Waiver, or suggesting that the BSRs be rewritten to include the USPA Coach.

My suggestion is that the Coach be allowed to supervise all IAD and Static Line students, excluding all actual IAD, or Static Line, and the A License Check Dive.

This is the content of my waiver request...

2-1-E-4a(1)
a. IAD and static-line [E]
(1) All jumps must be conducted by a USPA Instructor in that student's training method.

2-1-E-4c
c. All students must jump under the direct supervision of an appropriately rated USPA Instructor until demonstrating stability and heading control prior to and within five seconds after initiating two intentional disorienting maneuvers involving a back-to-earth presentation. [E]

Reason waiver is requested (cite unnecessary burden or research and development of improved techniques and methods):
1. 2-1-E-4a(1) states that “All jumps must be conducted by a USPA Instructor in that student’s training method”, following this logic a SL/IAD student would never be allowed to jump under the supervision of a USPA Coach, unless we take a liberal definition of the term “student”, call him a “neophyte” at a point of my choice in his progression, and let him jump under the supervision of a USPA Coach.
2. 2-1-E-4c is actually under the heading of “b. Harness-hold program [NW]”. This implies that after the student has shown the ability to recover form disorienting maneuvers he will be allowed to jump with any licensed skydiver, no USPA Coach or USPA Instructor is required at all. Again, I don’t understand if this is the intent, or if the rule is again simply vague.
3. Coaches are trained to teach freefall skills. As such it’s my opinion that a Coach can teach freefall skills from 10 second freefalls on.
4. We train only IAD (we also do tandem, but if a student wants to learn to skydive we only train IAD), as far as I can tell there are no additional freefall skills required of an SL/IAD instructor beyond what’s required of a Coach.
5. With the SL/IAD training method the Instructor/Coach does not “intervene” or “save” a student, the Instructor/Coach is only there to observe, critique, criticize, recommend advancement, repetition, or regression. Following the ISP, when the instructor starts to interact (RW) with the student is when the Coach is traditionally allowed to work with the student.
6. With SL/IAD the student is not allowed to freefall until they have demonstrated the ability to deploy stable (three successful and stable practice pulls). They have not yet demonstrated the ability to recover form a disorienting maneuver within 5 seconds, but again whether there’s an Instructor or Coach “directly supervising” they are not allowed or qualified to attempt to “save” the student.
7. One might argue that a seasoned Instructor might be better able to deal with a student’s stability, or turning problems. I’m not ruling out having an Instructor jump with my freefall students. Additionally if my Coaches are not allowed to use their rating, and only make half a dozen “Coach” jumps with students during their tenure as a Coach, I would argue that they are no more “seasoned” as an Instructor than they were as a Coach. They will at that point simply have a new title.
8. I do not propose that anyone other than an Instructor conduct the “A license check dive”.
9. This waiver could also be considered research and development. I think that the SIM, ISP, IRM, should be reconsidered, and rewritten to better define what exactly the Coach can do, and define it as it applies to each training discipline. I also think continuity between training methods should take a back seat to logic!
10. Currently I could theoretically move up the “recover form back to earth presentation” to come directly after the Clear and Pull, after the student had satisfactorily demonstrated that he could recover I could allow my Coaches to directly supervise my students, and be in compliance with the BSRs. I think this would be a very dangerous “solution”, as if the student were not able to recover he would be pulling unstable. Another political argument for reconsideration of the wording in the SIM, and a separation between training methods.

What I propose it to have only USPA IAD rated Instructors handle the actual Instructor Assisted Deployments, and also the first Clear and Pull (Category C, Dive Plan 1). Once the student is cleared for 10 second freefall, I propose having the USPA rated Coach directly supervise (form the plane/freefall) the student, and to have an IAD instructor indirectly supervise (from the ground).

Regarding my “hardship”:
When the USPA instituted the new instructional rating system it not only had the affect of greatly increasing the proficiency of the instructional staff, but it at the same time made it considerably more difficult to attain instructional ratings. At an SL/IAD drop zone, as the system is currently structured the Coach rating is virtually useless (only allowed to conduct the last few jumps on the 1 to 3 students we have progress to that level each year), and I believe was designed around AFF, with SL/IAD “forced” in almost as an afterthought. My “youngest” IAD instructor got his rating over 5 years ago (before the rating changes were made), and we often find ourselves in a situation where we have students who want to jump, but no “appropriately” rated instructors available to conduct the skydive. It’s my opinion that if we are allowed to implement my waiver, we will be able to provide better and timelier service to our students, and in the long run we’ll be able to train more new skydivers. As the system now stands, I have seriously considered completely dropping my student program, and becoming a “tandem factory”. This would be a last resort, and if this were to become the industry trend it would eventually kill the sport as no new skydivers would ever be trained.
I would also suggest that this requirement be reviewed and rewritten with two sets of requirements along the lines of my waiver for all IAD and SL drop zones. I do understand that the ISP was/is designed to provide continuity between training methods, but the differences between SL/IAD and AFF/Tandem Progression are so vast I think this supposed continuity is not serving as a positive compromise.
If it’s the position of USPA that under the existing BSRs no Waiver is needed to necessary to implement my suggested procedures, a letter to that affect would be sufficient.

Note: I originally wrote this waiver around the BSR pertaining to “harness hold” students. I am aware that there are inconsistencies between the two BSRs mentioned, this waiver underwent more than a few revisions, and I should have spent more time making it more consistent. In hindsight I should have eliminated everything pertaining to harness hold.

Experience is what you get when you thought you were going to get something else.

AC DZ

[SkymonkeyONE 4]

Not to nitpick, but I hope that wasn't a cut and paste of the letter you sent USPA. You misspelled the word "from" at least twice, instead writing "form." That just from the cursory glance I took at it.

[skydived19006 4]

Quote

Not to nitpick, but I hope that wasn't a cut and paste of the letter you sent USPA. You misspelled the word "from" at least twice, instead writing "form." That just from the cursory glance I took at it.

Nope, I did cut/paste it but went back and inserted a few type Os, and misspellings just for those who enjoy finding them.

I'll be the first to admit that it's not perfect, if USPA does ever respond, and they raise spelling issues, or inconsistency issues, I'll do another revision.

So Monkey, you're generally good for an openion. What's your openion on the issue?

Poor spellers of the world UNTIE!

Experience is what you get when you thought you were going to get something else.

AC DZ

[SkymonkeyONE 4]

Personally? When dealing with SL/IAD students these days, why not let the SL/IAD-I's do the work for all of it up to the last "45 second delay?" Let the USPA Coaches deal with the "post up-jumper" to "A license" stuff. The "real" rating is still obtainable very early in a jumper's career. Are you that short on IAD/SL-I's? As I read the ISP (concerning SL anyway), you can put them with a USPA Coach after Cat E in any training method, right up to the A-license check dive (which must be administered by an I).

Chuck Blue
D-12501
AFF/SL/TM-I, BMCI, PRO

[dropzonefool 0]

I don't think a coach should be allowed to hold a static line. I have seen to many incidents already because the DZO and the S&TA DO NOT understand the role of a coach, and probably believe they are the new and improved jumpmaster. As a CCD I do not believe a coach receives enough method specific training in a coach course to act as instructor.


That was my $0.02, opinions may vary.

[CDRINF 1]

This is exactly the problem USPA created when it eliminated the Jumpmaster rating. The Coach can really only do air work with a student. What is missing now is a rating for the person who is responsible for assisting the S/L or IAD Instructor and for putting the student out of the aircraft. As written now, that person has to be an Instructor. It also has the effect in S/L and IAD methods of eliminating the "apprentice" level rating for the person working towards becoming an Instructor in one of those methods. All of the old JMs were grandfathered into Instructors, but now the only choice is to become a Coach (which teaches no method specific skills) and then jump straight to trying to become an Instructor. So, you now have to eat the whole elephant in an ICC rather than a bite at a time by training and getting practical experience in the method of instruction. Personally, I would like to see the Jumpmaster rating brought back.

CDR

[skydived19006 4]

Quote

I don't think a coach should be allowed to hold a static line. I have seen to many incidents already because the DZO and the S&TA DO NOT understand the role of a coach, and probably believe they are the new and improved jumpmaster. As a CCD I do not believe a coach receives enough method specific training in a coach course to act as instructor.


That was my $0.02, opinions may vary.

I understand that my original post was long, but if you read it in it’s entirety you would know that I did not suggest that a Coach ever handle a Static Line or IAD. I also did not suggest that anyone other than an Instructor supervise the “A” License Check Dive.

Experience is what you get when you thought you were going to get something else.

AC DZ

[skydived19006 4]

Quote

Are you that short on IAD/SL-I's?

Chuck Blue
D-12501
AFF/SL/TM-I, BMCI, PRO

We do have two IAD Instructors that are always there (I and my partner); these two Instructors are also the Tandem Instructors, video guys, and virtually every other job on the DZ other than pilot. When we have tandems scheduled, if we’re the only staff available which is often the case the students may simply have to sit most of the day and wait until one of us has an hour “free” to go put them out. It’s been my observation that there are very few people who are even interested in pressuring a rating these days (other than Tandem rating), then when they know that their first rating of Coach is useless, what little motivation they might have had just went out the window.

Again, the way the BSR is written, an Instructor is required on all IAD progression student jumps and a Coach is not allowed to participate until the student is no longer a student (A licensed). I suppose a way around this would be to “convert” my IAD students to AFF students once they have demonstrated the ability to recover form back to earth presentation (although we do not train AFF at all) as the ISP is all about continuity between training methods. Now my new “neophyte AFF student” is allowed to jump with a Coach.

Here’s a little hijack of my own thread Chuck. What do you think about having a tandem Instructor with a tandem rig on his back and his passenger in the back of the 182 dispatching an actual IAD student? As far as I can tell there is no rule, law, or suggestion against it. I’m not suggesting that it’s anything other than a bad idea, or that I would do it, but ironically as far as I can tell it would be a “legal solution” to my little dilemma.

Experience is what you get when you thought you were going to get something else.

AC DZ

[SkymonkeyONE 4]

Quote

I don't think a coach should be allowed to hold a static line. I have seen to many incidents already because the DZO and the S&TA DO NOT understand the role of a coach, and probably believe they are the new and improved jumpmaster. As a CCD I do not believe a coach receives enough method specific training in a coach course to act as instructor.


That was my $0.02, opinions may vary.

No, a Coach should not be able to control a static line and dispatch a student. Coaches are for Cat F and beyond.

[SkymonkeyONE 4]

I don't see any problem whatsoever with a Tandem Instructor dispatching an IAD/SL student out low on the way up so long as his tandem passenger is securely belted in the plane when the door is open. This might be more of a hassle with a larger tandem system in a narrow body 182, but I wouldn't have any problem whatsoever doing it with my 38 pound Racer Tandem. It seems totally reasonable to me.

Chuck

[skydived19006 4]

Quote

I don't see any problem whatsoever with a Tandem Instructor dispatching an IAD/SL student out low on the way up so long as his tandem passenger is securely belted in the plane when the door is open. This might be more of a hassle with a larger tandem system in a narrow body 182, but I wouldn't have any problem whatsoever doing it with my 38 pound Racer Tandem. It seems totally reasonable to me.

Chuck

Ok, then envision a premature deployment damaging the airplane, That securely belted passenger is now not fairly screwed, but totally screwed as if it’s time to abandon the airplane he will have the privilege riding it down by himself.
It also just occurred to me that this may actually be illegal (as in a violation of FARs) as everyone is required to have a parachute when operating the door at altitude. If this is the case it would also be illegal to dispatch a student with a tandem pair on board unless they are hooked up.

Experience is what you get when you thought you were going to get something else.

AC DZ

[skydived19006 4]

Quote

Quote

I don't think a coach should be allowed to hold a static line. I have seen to many incidents already because the DZO and the S&TA DO NOT understand the role of a coach, and probably believe they are the new and improved jumpmaster. As a CCD I do not believe a coach receives enough method specific training in a coach course to act as instructor.


That was my $0.02, opinions may vary.

No, a Coach should not be able to control a static line and dispatch a student. Coaches are for Cat F and beyond.

Show me where it states that in the BSRs!

Oh, thanks for playing along Chuck! Although there may be few willing to join this topic, I think most who take the time to lurk/read it will gain some insight, if not learn something.
I’d like to hear what Tom Buchanan has to say on the topic!!! I’ll PM him and ask him to put in his 2 cents.

Martin

Experience is what you get when you thought you were going to get something else.

AC DZ

[riggerrob 643]

Chuck,
I disagree, having dispatched a few static-line students when I was a newby TI. It was simply too much of a hassle while wearing a bulky tandem rig in a Cessna 207.
Remember that I am both taller than you and "better nourished."
Now Strong Enterprises frowns on the practice out of fear that a fumbling S/L student will rip the tail off the airplane, dooming the rest of the passengers.

[riggerrob 643]

How about using a schedule that has worked well in Canada for many years?
Canadian students must jump with IAD, S/L or PFF instructors until they complete their solo certificate (minimum 10 jumps), then students can jump with Coach 1s to complete the list of solo skills for their A Certificate (minimum 25 jumps).
After that, if they want to learn relative work, they can jump with a Coach 2.
CSPA uses Coach 2 as a pre-level for PFF Instructor training because the Coach 2 Course covers most of the proximity and observation skills need by PFF Instructors.

[tombuch 0]

Quote

Oh, thanks for playing along Chuck! Although there may be few willing to join this topic, I think most who take the time to lurk/read it will gain some insight, if not learn something.
I’d like to hear what Tom Buchanan has to say on the topic!!! I’ll PM him and ask him to put in his 2 cents.

Martin

OK, here is my quick read of the regulation, interpretation, and consideration of what is reasonable. It’s only my opinion. For the definitive application of the regulation, please contact Jim Crouch directly at USPA. Remember, I’m just a guy with no authority in the matter.

First, I think your interpretation of 2-1(E)(4)(a) is correct. The regulation does say that ALL jumps must be “conducted” by an Instructor. I don’t see the significance of the capitalization of Instructor. What I do see is that the regulation does not say “under the supervision” or “direct supervision,” of the Instructor, but rather uses the term “conducted by.” That suggests that the person doing the jump training and dispatch must be an appropriately rated instructor, as long as the jumper is under the IAD/SL programs.

My hunch is the intent is that the person doing the dispatch of an actual SL or IAD must be rated in the appropriate discipline (IAD for an IAD student, or SL for a SL student). I think the idea is that once the student is beyond the IAD or SL specific part of the training, then an Instructor in any program is able to do the in air dispatch. I think that should also include a Coach as the direct supervisor, as long as an Instructor is providing oversight as the supervisor.

I think it is unreasonable for a Coach to handle an IAD or SL deployment (and I know you are not asking for this). I think it is probably reasonable for a Coach to handle everything after the first freefall, at least given the way the Coach rating is handled for other disciplines. That’s just my opinion.

Tom Buchanan
Instructor Emeritus
Comm Pilot MSEL,G
Author: JUMP! Skydiving Made Fun and Easy

[KCJumper 0]

I take offense to the thought that a coach is a useless rating. As a new jumper to the sport the only thing I could do to keep jumping was to pack. I got my first instructional rating as a coach and was able to increase my numbers.
Now I have taken the next step and gotten my S/L I rating and have already benefited from it. Would I want the responsibility of putting a first timer out on a S/L? Hell no. I like the idea that anyone who might put my wife out on a S/L knows how the class runs backward and forward. By having the jumpmaster rating we were saying that it is ok for someone who has no classroom time to take care of these first time students.

I guess I take this more personal than most becuase in the real world I am a teacher. So when you say that you think those without proper qualifications should be able to take care of that scared first timer I think wow let's just shove that guy in my classroom and see how he does with a bunch of freshman.

Sorry to go on a rant but sometimes you just need to. Have a good day and blue skies.

Patrick

[Andrewwhyte 1]

I am really surprised to hear you say that Chuck. Are you willing to exit with tandem at 3000 in a non-emergency? or willing to leave without your passenger in an emergency? If not I do not understand how you can be willing to have the door opened for any reason at that altitude. If I have a tandem on board the door may not open before 6000 for anyone.
If you have a customer who cannot leave the plane, you better make sure the pilot rig stays on the ground.

[SkymonkeyONE 4]

You apparently jump at a dropzone that does not do low passes then. We regularly let out hop and pops on the way up, no matter which airplane (Cessna, Otter, CASA, Twin Bo) we are flying. Tandem passengers are belted in during those times; it's simply not an issue. No, I would not be leaving a tandem passenger in the plane (above 3500 feet). If there were a problem with an SL student, I would simply deal with it (I have had the SL-I rating since I was 20 years old.) If I needed to get out at 3500 feet with my passenger, then I would unbuckle him, hook up at least one top snap, then exit and throw my drogue while holding the passenger around his waist with my left hand. Without the bottom connectors done on my Racer, the rig opens as soon as you throw the drogue. I simply cannot see an issue with dispatching an SL/IAD student on the way up with me wearing my tandem rig, not that I have ever needed to do so nor do I ever foresee a time when I would need to. We have not done SL or IAD progression at Raeford in quite some time since they moved the military club over to Parkton.

I don't understand why you think having the door open with a belted-in tandem passenger is a big deal; it's not. In a Cessna, the tandem passenger (at least at our dropzone) is belted in facing the rear, right behind the pilot seat. In an Otter they are all the way up front.

chuck

[skydived19006 4]

Quote

I take offense to the thought that a coach is a useless rating. As a new jumper to the sport the only thing I could do to keep jumping was to pack. I got my first instructional rating as a coach and was able to increase my numbers.
Now I have taken the next step and gotten my S/L I rating and have already benefited from it. Would I want the responsibility of putting a first timer out on a S/L? Hell no. I like the idea that anyone who might put my wife out on a S/L knows how the class runs backward and forward. By having the jumpmaster rating we were saying that it is ok for someone who has no classroom time to take care of these first time students.

I guess I take this more personal than most becuase in the real world I am a teacher. So when you say that you think those without proper qualifications should be able to take care of that scared first timer I think wow let's just shove that guy in my classroom and see how he does with a bunch of freshman.

Sorry to go on a rant but sometimes you just need to. Have a good day and blue skies.

Patrick

I never suggested that anyone other than an Instructor rated in the discipline handle the actual IAD, or Static Line. So, as I read your concern it’s moot to the discussion here.

Experience is what you get when you thought you were going to get something else.

AC DZ

[skydived19006 4]

Quote

Quote

Oh, thanks for playing along Chuck! Although there may be few willing to join this topic, I think most who take the time to lurk/read it will gain some insight, if not learn something.
I’d like to hear what Tom Buchanan has to say on the topic!!! I’ll PM him and ask him to put in his 2 cents.

Martin

OK, here is my quick read of the regulation, interpretation, and consideration of what is reasonable. It’s only my opinion. For the definitive application of the regulation, please contact Jim Crouch directly at USPA. Remember, I’m just a guy with no authority in the matter.

First, I think your interpretation of 2-1(E)(4)(a) is correct. The regulation does say that ALL jumps must be “conducted” by an Instructor. I don’t see the significance of the capitalization of Instructor. What I do see is that the regulation does not say “under the supervision” or “direct supervision,” of the Instructor, but rather uses the term “conducted by.” That suggests that the person doing the jump training and dispatch must be an appropriately rated instructor, as long as the jumper is under the IAD/SL programs.

My hunch is the intent is that the person doing the dispatch of an actual SL or IAD must be rated in the appropriate discipline (IAD for an IAD student, or SL for a SL student). I think the idea is that once the student is beyond the IAD or SL specific part of the training, then an Instructor in any program is able to do the in air dispatch. I think that should also include a Coach as the direct supervisor, as long as an Instructor is providing oversight as the supervisor.

I think it is unreasonable for a Coach to handle an IAD or SL deployment (and I know you are not asking for this). I think it is probably reasonable for a Coach to handle everything after the first freefall, at least given the way the Coach rating is handled for other disciplines. That’s just my opinion.

Tom,
In hindsight I should have touched base with you before I wrote or at least submitted my Waiver request!
You are correct with regard to contacting Jim Crouch, and I did. I and another DZO contacted him on multiple occasions regarding this issue, and he always very “political” with his response, and would not give a definitive answer. My guess would be that he sees it as giving permission to violate a BSR, and the obvious politics involved restrict him form giving his opinion, or even giving a liberal interpretation. What I’m asking is obviously not the common practice, or what is outlined within the IRM regarding the Coach rating. The problem is that the BSRs, ISP, and IRM do not correspond, and that logic takes a back seat to politics.

Martin

Experience is what you get when you thought you were going to get something else.

AC DZ

[Andrewwhyte 1]

You are correct that our twin does not do low passes on the way up. As we were talking about IADs I was specifically thinking Cessna. Dispatching h/pers from an Otter/CASA is not an issue I've given a lot of thought to as we don't use them; you are probably right in those cases.
If you are dispatching from the front facing jm position or the rear facing jm spot in a Cessna, getting the rear facing/behind the pilot student in position to get one top snap done up is a cumbersome task. It likely involves moving the centre of gravity aft. If the departing jumper has damaged the tail or there is a canopy hanging off it. I believe your chances are approaching nil. If there are other jumpers in the plane, they will not share your imperative to save the passenger at all costs. The standard drill for a crippled aircraft is for everyone to leave immediately. If you are moving the wrong way i.e. from the door toward the interior, you may encounter other jumpers trying to force their way past you.
PS My crack about leaving without the passenger was inappropriate. I apologize

[SkymonkeyONE 4]

Not to beat a dead horse, but I have been on a _LOT_ of Cessna loads doing tandems where another Instructor; sometimes even my video guy (also a SL-I); dispatched a student on the way up. I guess it just comes down to what a particular DZ feels is "normal." Remember, I work at a DZ where we regularly train 16 year-olds to skydive and now don't have any problems doing tandems with the same. I grew up on a similar dropzone and I myself began skydiving at age 17. We are fine with the USPA ruling and are more than fine with our aircraft safety procedures as they relate to dispatching students. As our dropzone has been in operation under the same ownership for over thirty years, I think we are fine with the way we do things.

Chuck

[matthewcline 0]

I was out of town when this started and missed all the previous posts that already made this point, including the LEGAL point of the implied FAR violation.



Matt

An Instructors first concern is student safety.
So, start being safe, first!!!

[tombuch 0]

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I was out of town when this started and missed all the previous posts that already made this point, including the LEGAL point of the implied FAR violation.

There is no FAR violation implied. It is a USPA BSR that we are talking about. A violation of a BSR is a big deal, a violation of an FAR is a VERY big deal. Two different animals.

Tom Buchanan
Instructor Emeritus
Comm Pilot MSEL,G
Author: JUMP! Skydiving Made Fun and Easy

[matthewcline 0]

I was refering to the door being in operation and the Student not having a parachute on. But that would probably be subject to interpretation.

Matt

An Instructors first concern is student safety.
So, start being safe, first!!!