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 Personnel Examiner Program, General, 

Additional Requirements for Appointment”, “For Designated Parachute Rigger Examiner (DPRE) 

Appointment”. Subparagraph (2) states 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 my 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 the manufacturer, 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. The 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 twice 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 1940’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 parachute 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 experience 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. He 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 certificate. This was in 1971. This rigger hadn’t exercised 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 fact 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 parachute rating is recent I have held a chest rating since 1985 and a seat 

rating since 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 manual 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 equipment 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 coauthorship 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

269-569-5440

terryurban@pia.com