Proposed new Part 105 Manual of Standards - Parachuting from aircraft - (CD 2213OS)

Section 3.01 - Under the Part 135 MOS 12.08 (6) (attached below), operators are afforded tolerance in their re-currency checks. If a re-currency check is conducted up to a month early or a month late, it is treated as if the re-currency check was completed on the date it was due.
It would be appropriate for Part 105 to also afford this tolerance period for the purpose of JPA re-currency checks.

Section 3.02 (2) (a) - This section should read: "at least 10hours of experience as pilot in command or pilot in command under supervision of the type of powered-lift aircraft being operated" to appropriately reflect the current requirements.

Section 5.29 (b). APF recommends the minimum main parachute opening height for student persons is 2,500ft AGL. This should be amended from 2,200ft to appropriately reflect the APF's requirements.

Section 5.47 (5) to 5.47 (8) recommended to be removed as target panels are not in use and have not been in use across any organisations for many years and is obsolete.

Section 5.51 (2). Approval should be given for aircraft being operated to facilitate a parachute descent if the aircraft flight manual instructions for the aircraft do not make provision for the operation of the aircraft with the door open or removed, provided they are operated in accordance with an appropriate engineering order (EO) and/or supplemental type certificate (STC) is obtained.

Section 9.01 (b) (iii) - This section should read: "at least 10hours of experience as pilot in command or pilot in command under supervision of the type of powered-lift aircraft being operated"

Section 7 Weight & balance should include authorisation for the PJE aircraft to be operated with a greater number of parachutists onboard the aircraft than that which the TCDS states as the maximum allowable passengers, provided the aircraft is compliant with the published weight and balance limitations. Wording to the effect of:

The PIC of a PJE aircraft is responsible for ensuring that the aircraft being flown is properly loaded and operated in accordance with the weight & balance data & limitations of the aircraft flight manual.
Where the aircraft is to be operated with participants exceeding that which is outlined in the TCDS, the PIC must obtain additional aircraft station position information (loading schedule), identifying the exact seating position of each participant to ensure accuracy of the aircraft weight & balance conformity. At no point shall the aircraft be operated in breach of the aircraft's published weight & balance limitations.