TomSpoon 4 #1 February 8, 2004 The FAA recently extended it's deadline for comments on NPRM 4521 which would regulate air tour operators under the more stringent FAR 135. Rumor is Skydiving is next. Is this what we want? Quote Share this post Link to post Share on other sites
quade 4 #2 February 8, 2004 Skydiving is not going to operate under FAR Part 135. It's something for the USPA to get involved in and comment on, but the average skydiver need not worry.quade - The World's Most Boring Skydiver Quote Share this post Link to post Share on other sites
sducoach 0 #3 February 8, 2004 Quade, Never say never however, it is unlikely. Even so it would be directed towards aircraft and pilots, not the typical skydiver. That said, maintenance requirements and pilot proficiency would not be a bad thing, would it? Blues, J.E.James 4:8 Quote Share this post Link to post Share on other sites
quade 4 #4 February 8, 2004 Did I -say- never? While pilot training and aircraft maintenance are extremely important, there's nothing that prevents a Part 91 operator from from having standards higher than the minimum required by the FAR. In fact, many operators do: police, fire, lifeflight.quade - The World's Most Boring Skydiver Quote Share this post Link to post Share on other sites
TomSpoon 4 #5 February 8, 2004 FAR 135 may be directed at aircraft and pilots but it will affect jumpers. It will force a shake out of jump aircraft operators and significantly increase the cost of your jump ticket. Yes maintenance requirements and pilot proficiency would not be a bad thing. Do we need FAR135 to get that? Quote Share this post Link to post Share on other sites
quade 4 #6 February 8, 2004 I guess you missed the nuance of my post. I don't think FAR Part 135 will include skydiving operations. It simply wouldn't make sense. That said, the USPA is already working on the lobbying effort.quade - The World's Most Boring Skydiver Quote Share this post Link to post Share on other sites
TomSpoon 4 #7 February 8, 2004 QuoteDid I -say- never? While pilot training and aircraft maintenance are extremely important, there's nothing that prevents a Part 91 operator from from having standards higher than the minimum required by the FAR. In fact, many operators do: police, fire, lifeflight. Exactly. that is why skydiving A/C operators should clean house now before it's forced on us. Quote Share this post Link to post Share on other sites
sducoach 0 #8 February 8, 2004 No, you did not say........ never. I did not imply that you did. You are correct, there is nothing to "prevent" higher standards, other than spending their money......... Part 135 would require the DZO's to write an operations manual and comply with not only the manual but also the aircraft and pilot currency requirements of 135. Help me out here though, where did "police, fire, lifeflight." come from? I thought we were discussing skydiving? It would be great if all would lead and then "follow by example" but it is not the case. No argument here Quade, just thoughts. Blues, J.E.James 4:8 Quote Share this post Link to post Share on other sites
pilotdave 0 #9 February 8, 2004 Requiring DZs to operate under part 135 would shut down all but the biggest DZs. Or maybe jump tickets would go up to $50. It'd be bad. Dave Quote Share this post Link to post Share on other sites
TomSpoon 4 #10 February 8, 2004 QuoteI guess you missed the nuance of my post. I don't think FAR Part 135 will include skydiving operations. It simply wouldn't make sense. That said, the USPA is already working on the lobbying effort. Apparently the USPA does think 135 will eventually cover jump A/C. That's why they are lobbying. And what has sense ever had to do with the FAA ? Quote Share this post Link to post Share on other sites
sducoach 0 #11 February 8, 2004 Tom & Quade, Do we need it? I don't know. I have not looked at the aircraft incidents/accidents that are strictly skydiving related. I'm sure most "minor" incidents are not reported. Chris may be able so shed some light on those facts. What is "significantly increase"? Couple buck a ticket? Who knows without looking at the costs, load factors, etc. Please tell me what would be the bad part of "It will force a shake out of jump aircraft operators....."? That implies that there are "shady operators" and if that is true ( ), why not? I'm not stating that we need "more regulations". That seems to light some peoples fuses, I'm stating why not the higher standards for aircraft and pilots? We all know that some DZO's character is such that they will go beyond the "minimum" requirements for safety sake, some will not. Have fun with this one guys. Heading out for the day, I'll check back in later. Blues, J.E.James 4:8 Quote Share this post Link to post Share on other sites
sducoach 0 #12 February 8, 2004 Okay, I could not leave yet. How did you get to $50.00 for jump tickets? What are we talking about additional in "requirements"? 100 hour inspections in lieu of just annuals. A 135 operations manual. Pilot check rides every 6 months that are done by a staff "check pilot". The biggest item would be, as I see it, aircraft insurance. Do you have any idea how many operators do not carry insurance at all? Or do you care? It is so much easier not to ask or not want to know than face the facts sometimes. However, if we keep our "noses clean" as an industry, the FAA will probably stay at arms length. So let us concentrate on that. But please come on now, let us not start throwing around costs, problems, putting people out of business, etc. without some facts. See you all later. Blues, J.E.James 4:8 Quote Share this post Link to post Share on other sites
pilotdave 0 #13 February 8, 2004 I'd much rather see the USPA audit group member DZs, "forcing" them to comply with high standards. Part 135 just simply contains way too many regulations that don't make sense for skydiving (or sightseeing for that matter). The huge florida or CA dropzones could probably do it pretty easily. But what about a little cessna DZ or something in between? Dave Quote Share this post Link to post Share on other sites
quade 4 #14 February 8, 2004 Police, Fire and Lifeflight all operate under Part 91. Most, Police, Fire and Lifeflight operations I've seen have standards for pilot training and aircraft maintenence well in excess of those required by Part 91. I was using them as an example of going above and beyond the minimum legal requirements. There is nothing to prevent drop zones from doing the same.quade - The World's Most Boring Skydiver Quote Share this post Link to post Share on other sites
pilotdave 0 #15 February 8, 2004 You looked at FAR part 119? To fly part 135, the DZ would have to become a part 119 air carrier (as far as I know, anyway). It's long so I won't copy it, but look at the requirements of §119.69 Management personnel required for operations conducted under part 135 of this chapter. Every DZ would need a Director of Operations, a Chief Pilot, and a Director of Mainenance. To be the director of operations, you need to: have at least 3 years supervisory or managerial experience within the last 6 years in a position that exercised operational control over any operations conducted under part 121 or part 135 of this chapter; or 3 years of pilot in command experience within the last 6 years under part 121 or 135. It goes on and on... the chief pilot needs 3 years experience also, the director of maintenance needs to be an A&P, etc. As I said, no problem for a big DZ. They probably have all these people already. But what about the little cessna DZs? I mean this is just one little detail. Parts 119 and 135 are just full of these little things that would just be a pain in the ass to comply with. It could be done, but I guarantee this is a mountain of paperwork and increased operating costs. How many DZs do you know of that have extra money lying around? Dave Quote Share this post Link to post Share on other sites
TomSpoon 4 #16 February 8, 2004 QuoteI'd much rather see the USPA audit group member DZs, "forcing" them to comply with high standards. Part 135 just simply contains way too many regulations that don't make sense for skydiving (or sightseeing for that matter). The huge florida or CA dropzones could probably do it pretty easily. But what about a little cessna DZ or something in between? Dave I'm with Pilot Dave. The USPA would be most effective if they put pressure on jump A/C operators to voluntarily comply with safety regulations that make sense. BSR's for jump A/C if you will. If you want to read or comment NPRM 4521 go to http://dms.dot.gov/search/searchFormSimple.cfm type in "4521" Quote Share this post Link to post Share on other sites
sducoach 0 #17 February 8, 2004 Quade, Thank you, I understand your point now. Difference is they do not "fly for hire" however, good point. Big difference is, you are speaking of government operations. What keeps most DZO's (IMHO) is the Dollar Bill. Blues, J.E.James 4:8 Quote Share this post Link to post Share on other sites
sducoach 0 #18 February 8, 2004 Dave, Some good points however, ( my far is 2003) you simply have to list those people such as director of maintenance. The same A&P or AI you use now can become your DOM. No argument here Dave on the additional paperwork and the accountability would increase. IMOH that is a good thing. See you later! Blues, J.E.James 4:8 Quote Share this post Link to post Share on other sites
pilotdave 0 #19 February 8, 2004 I don't disagree that it would be better if all DZs were operating under part 135, with our current jump prices and dropzone availability. I just don't think every dropzone could or would be able to comply, and jump ticket prices would go up everywhere. Is that a fair price to pay for an increase in safety? Depends what the safety increase would be. Jump plane crashes happen sometimes. How many recent accidents wouldnt have occured had they been operating under part 135? I think thats an impossible question to answer. Dave Quote Share this post Link to post Share on other sites
sducoach 0 #20 February 8, 2004 Agreed.I for one am just not afraid of it. See ya, J.E.James 4:8 Quote Share this post Link to post Share on other sites
TomSpoon 4 #21 February 8, 2004 Here are just a few things FAR 135 would force A/C operators to do. I'm sure many of you can add more. Have an approved operations manual Have an approved Maintenance program. Establish and document times on A/C components Comply with TBO's on aircraft components Minimum 500 hrs and instrument rating for pilots Max duty time for pilots Annual check ride for pilots. Flight following Drug testing Written Load manifest and weight and balance for every flight. More restrictive oxygen requirements Second pilot required for some A/C 135.99 Public address system Req'd Just to name a few Quote Share this post Link to post Share on other sites
Hooknswoop 19 #22 February 9, 2004 QuoteWhat are we talking about additional in "requirements"? 100 hour inspections in lieu of just annuals 100-hour inspections are already required under Part 91 if the aircraft is used for hire, which includes parachute operations. I think it would be a huge improvement if all DZ's maintained their aircraft per Part 91 for starters. Too many don't and get away with it. I also think that if the FAA required DZ's to maintain their aircraft under Part 135, a lot simply wouldn't. Derek Quote Share this post Link to post Share on other sites
sducoach 0 #23 February 9, 2004 Okay, so what is your point. All I see here are safety items. The public address system I thought was great. Most aircraft with seperated cockpits have one through the communications system. In a 182 it's called Yelling! As Derek stated, most DZ's would probably not comply, as some do not comply with part 91 at this time. Derek, on the 100 hours, that's my point. If they are doing part 91 as required they would probably do 135. If not, then I'd know where not to jump. Just like you as a pilot I am critical of the guy driving. He can kill me in the first few minutes quicker than my AFF student. Blues, J.E.James 4:8 Quote Share this post Link to post Share on other sites
pullhigh 0 #24 February 9, 2004 Difference is they do not "fly for hire".... I bet if you take a ride in a lifeflight chopper, you and/or your insurance company get's a hefty bill for that ride. Ganja "I don't want to find out first hand though" Rodriguez Quote Share this post Link to post Share on other sites
Ron 10 #25 February 9, 2004 QuoteI'd much rather see the USPA audit group member DZs, "forcing" them to comply with high standards. The USPA has no teeth....It will never happen. The USPA does not want to do it, and even if they did they have no power. Only ONE DZ ever has been audited by the USPA,,, and it failed."No free man shall ever be debarred the use of arms." -- Thomas Jefferson, Thomas Jefferson Papers, 334 Quote Share this post Link to post Share on other sites
