September 18, 2011

211 Cherryview Drive Portage, MI 49024

To whom it may concern, This letter is my request for a deviation from FAA Order 8900.2 Change 1 Effective Date 8/16/10, General Aviation Airman Designee Handbook. Specifically I request a deviation Chapter 6 , Section 1, Paragraph 1, subparagraph b.(2). This is under the “ Technical Personn el Examiner Program , General, Additional Requirements for Appointment”, “For Designated Parachute Rigger Examiner (DPRE) Appointment” . Subparagraph (2 ) s tates as an additional requirement “Held a valid master parachute rigger certificate for 2 years with the rating(s) for which the managing FAA office will issue a designation.

I request a deviation from the 2 year requirement to allow Lap type , added to m y Master Parachute Rigger certificate March 2, 2011 , to be added to my Authorized Functions with this renewal . There are several justifications for requesting this deviation. The first justification for requesting this deviation is that I am a consultant to AeroSports USA, Inc., the manufacturer of a newly introduced lap parachute. The first production item of this TSO’d lap parachute was produced in January 2011 and was used for my practical examination for my additional rating. I assisted th e manufactu

rer, Jerry Baumchen, with the design the container and harness, determination of the packing method, and writing the manual for this parachute. I evaluated several prototypes for Jerry during the design of this version of his container. T he photos in the manual illustrating the packing method for this container were taken by me in my facility while I packed the lap parachute. I am one of three designers listed in the manual

. Other than one other FAA certificated rigger who packed the lap parachute twic e for a demonstration under my guidance , I am the only rigger who has packed the production version of this parachute. Since adding the rating to my certificate I’ve begun to supervise other riggers in packing this parachute so they
may qualify for the rating. Many other riggers have expressed interest in obtaining the lap rating when testing is available. While other lap parachutes have existed I don’t believe they have been produced since the late 1930’s or very early 194 0’s. Many riggers have searched for a number of years for an old lap parachute without success. While an old military lap parachute might be available the fact that many riggers have searched for decades for one makes it unlikely that an old lap parachut e might surface. Even if one became available it would be of little relevance since the age of the natural materials used would make it unairworthy. I do have instructions on packing one make of early lap parachute. So, while I don’t have any experienc e with the old lap parachutes neither does any other DPRE or FAA inspector.AeroSports USA, Inc. has produced this modern design lap parachute. There is a potential market for

these parachutes for use in any aircraft that has side stick controls. This market cannot be explored if there are no riggers available to service the parachute. During the process of my obtaining my lap rating my Principle Managing Inspector, John Golda, searched for DPRE’s with a lap rating or FAA Inspectors with a lap rating. H e determined there were none. We found a Senior Parachute Rigger in the region who held a lap rating. This senior rigger earned his lap rating by converting his military experience to a civilian rigger certific ate. This was in 1971. This rigger hadn’t exe rcised his privileges since 1971 and was not current. Even so I did spend some time with him while earning my lap rating. The few riggers who hold lap ratings are elderly, not current on old lap parachutes and not familiar with the new lap parachute. While they could become current and familiar few of these riggers are active and none are DPRE’s. The lap parachute is very much like a seat parachute or a chest parachute in that it contains a round canopy and is packed in a very similar manner. In fac t the lap parachute container produced by AeroSports, USA is being developed as both a chest container and a seat container with very little modification. While my lap parac hute rating is recent I have held a chest rating since 1985 and a seat rating sinc e app. 1992. I currently have 217 seat and 65 chest pack jobs logged. I also have a total of 546 round emergency/reserve parachute packs logged and I estimate I have pack approximately 500 round main parachutes. I believe this extensive round experience , along with my experience with parachute types which pack in a similar manner add to my qualifications for Lap to be added as an Authorized Function.
Since there are no DPRE’s or FAA Inspectors with a lap rating my PMI administered my practical examine. My expectation is that the FAA would prefer to not have non lap rated inspectors continue to administer lap practical exams. As the only DPRE with a Lap rating, as a member of the design team for a modern lap parachute, as one of the authors of the manu al for packing of the only lap parachute that to my knowledge is currently available, and based on my experience with round and seat type parachute I believe I am fully qualified to act as a DPRE for the lap type. This parachute will add an additional option to the pilots of side stick aircraft, many of which are small light sport aircraft with limited room for a back or seat parachute. I believe supporting the introduction of this lap parachute through having a DPRE would enhance the choices of safety eq

uipment available. I believe adding the lap rating to my DPRE Authorized Functions would serve the manufacturer and customers by providing the means for other riggers to obtain the lap rating within the current DPRE testing program.

In summary I believe my involvement with the design of the newly produced lap parachute and my co

authorship of the manual, the need to support the manufacturer of the newly designed and produced lap parachute and the lack of any other DPRE’s or FAA inspectors with a lap rating or familiar with the new parachute justify a deviation to the two year rule and the addition of my lap rating to my designation now. Enclosed with this request is a copy of the manual for the current lap parachute. In addition attached for interest is a copy of a photo of one of the old lap parachutes. This may be in fact the only other model/brand of lap parachute ever produced.Thank you for your consideration,

Terry Urban Master Parachute Rigger #3128569 DPRE # 003128569
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- 5440 terryurban@pi a.com