Unpacking a Parachute AD
Update: On Dec. 3, ARSA sent a letter to the Department of Transportations Office of General Counsel. The association requested assistance from DOT after the FAA refused to consider the substantive question of its authority to issue an AD against a parachute. Click here to review the letter and attachments; ARSA members can find analysis in the November edition of the hotline.
On July 2, ARSA requested clarification of the FAA’s authority to issue an Airworthiness Directive, questioning the April 22 posting of an AD against certain Uninsured United Parachute Technologies, LLC Parachutes.
According to 14 CFR § 39.3: “FAA’s airworthiness directives are legally enforceable rules that apply to the following products: aircraft, aircraft engines, propellers, and appliances.” The association’s letter reviewed the relevant definitions in § 1.1 against this applicability, concluding a parachute could not be included under the definition of an aircraft, aircraft engine, propeller, or appliance.
“Considering the fact part 39 does not include parachutes in its applicability, please explain the FAA’s authority to issue the subject AD,” the letter requested.
ARSA followed up after the FAA’s initial response was unsatisfactory. Click here to review the exchange.
Learn more about ADs…
And test your ability to define “appliance”…