In this morning’s Federal Register the FAA published a proposed change to AC 150/5300-13, the advisory circular that sets airport design standards for federally-obligated airports. This change, a new Appendix 18, would set a standard for any Parachute Landing Area (PLA) on an obligated airport. In response to that proposed change the USPA has sent a letter to general aviation associations asking that they look closely at this issue.
In that letter the USPA points out that they have been working with FAA Airports (the originator) for the past year and a half on this issue and continues to have deep concern for its burden on skydiving businesses, both present and future. Although this proposal is part of an overall FAA effort to assist skydive operators with gaining access to federally-obligated airports, a goal the USPA fully supports, they are concerned that this proposed PLA standard is overbearing, and may bring new costs and unnecessary burdens to new and existing skydiving businesses. "We think the proposal will have the effect of moving PLAs to remote corners of airports away from the skydiving business facility, or of keeping skydiving off of airports that don’t have sweeping property lines," said Ed Scott, Executive Director for the USPA.
Skydivers have been jumping onto airports for over 65 years. In the mid-1970s the FAA defined skydiving as an aeronautical activity, and today there are skydiving businesses on about 100 obligated airports. FAR 105.23(b) simply requires a skydive operator to have airport management approval before jumping onto an airport. Historically, the airport manager and the skydive operator mutually designate a grass area on the airport that meets USPA standards, usually close by the hangar/building to be leased by the operator. "Skydivers are taught from day one to avoid aircraft and avoid landing on taxiways and runways," said Scott. "Skydiving has proven to be very compatible at even busy airports."
The FAA now proposes that every PLA on an obligated airport will need FAA approval (in addition to the approval of airport management) and the PLA will have to be reflected on a revised Airport Layout Plan, before skydiving can commence. A buffer distance from the edge of a PLA to the edge of a runway or taxiway must be observed, and the boundaries of the PLA must be marked. The USPA letter points out that, where before they simply designated a grass area on the airport for landing; now the FAA says that landing area must undergo a new FAA approval process.
Scott says that USPA’s concern is that FAA Airports intends to make this standard retroactive to the 100-plus skydive operators currently on obligated airports. The landing area of many of these operators overlaps a taxiway or an occasional runway. FAA’s proposal will force the PLA to be moved away from the operator’s leasehold, sometimes to a far corner of the airport. This will either force skydivers to walk long distances across the airport to return to the skydive hangar, or force the operator to purchase shuttle vehicles. Either way, says Scott, a remote PLA actually introduces more opportunity for runway/taxiway incursions by skydivers or shuttle vehicles.
Over the past 65 years of skydiving (and an estimated 54 million jumps) there have been zero accidents involving a skydiver hitting an aircraft moving on a taxiway or runway. "At first," says Scott, "FAA Airports said they were proactively trying to ensure that some future skydiver does not impact an aircraft on the ground. Later, FAA Airports produced a report of 27 incidents over 30 years, many of which have no connection an airport or a parachute landing area." FAA Airports has stated that skydivers near taxiways and runways are a hazard, and the PLA standard is necessary to reduce the hazard.
The USPA letter states that FAA Airports has chosen to ignore the responsibility of all aeronautical users to see-and-avoid, and has now entered the business of trying to separate different segments of aviation on airports. "By the way," said Scott, "FAA Airports has indicated that skydiving is simply the first “non-traditional” aviation segment to get this treatment. They intend to take the same approach to other segments of aviation as well—soaring operators, banner-tow operators, ag operators, ultralights, etc., perhaps even non-radio aircraft (one FAA official based their initiative principally on the fact that “skydivers don’t have radios”)."
"We simply ask that your association look closely at this issue, and speak with us if you have any questions," said Scott. While the USPA would appreciate having the general aviation industry’s support in opposition to what they refer to as an "airport grab", they understand that may not be possible. "If not," said Scott, "we would like you’re association to at least withhold your support for the FAA proposal."