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VIA EDGAR & FEDERAL EXPRESS Division of Corporation Finance Securities and Exchange Commission Washington, DC 20549 Re: Ballistic Recovery Systems, Inc. (the “Company”) Form 10-KSB for the year ended September 30, 2004 (the “Form 10-KSB”) File No. 0-15318

Dear Mr. Humphrey:

I am writing to respond as discussed during our telephone conversation April 27, 2005. Based upon your comment letter dated February 18, 2005, the Company has re-evaluated the value of the warrants issued to Cirrus Design Corporation (“Cirrus”).

The Company believes that the 1999 value of the purchase discounts forgiven by Cirrus was $604,000 in exchange for the issuance by the Company of performance or contingent warrants to acquire the 1,400,000 shares of the Company’s Common Stock. The first set of warrants of 250,000 for the exercise period January 2002 through February 2003 was not exercised by Cirrus and therefore, expired on February 28, 2003. Therefore, the warrants that became exercisable and were exercised by Cirrus totaled 1,150,000 resulting in 82% (1,150,000/1,400,000) of the warrants exercised under the agreement. The value of the warrants, we believe is appropriate is $495,280 ($604,000 x 82%). The Company has already expensed through a reduction of sales $20,799 in fiscal year 2003 and $104,650 in fiscal year 2004. Accordingly, we propose that the financial statements for fiscal year ended September 30, 2004 be restated to show an additional reduction in sales of $369,831 ($495,280-$20,799-$104,650).

The income tax provision will be decreased as well using the September 30, 2004 effective tax rate of 39.67% ($369,831 x 39.67% = $146,700).

The following illustrates the effect of the restatement on the balance sheet as of September 30, 2004 and the statement of operations for the year ended September 30, 2004:

BALLISTIC RECOVERY SYSTEMS, INC.

BALANCE SHEET

Adjustment of

As Reported

Cirrus Warrant

Adjusted

9/30/2004

Valuation

9/30/2004

ASSETS

Current Assets

Cash

$

1,314,557

$

—

$

1,314,557

Accounts receivable, net

402,113

—

402,113

Note receivable – shareholder

12,500

—

12,500

Inventories

1,132,496

—

1,132,496

Deferred tax asset – current

106,000

146,700

252,700

Prepaid expenses

44,025

—

44,025

Total Current Assets

3,011,691

146,700

3,158,391

Furniture, fixtures and leasehold improvements

591,767

—

591,767

Less accumulated depreciation and amortization

(292,164

)

—

(292,164

)

Furniture, fixtures and leasehold improvements, net

299,603

—

299,603

Other Assets

Patents, net

1,611

—

1,611

Long-term prepaid expense

53,120

—

53,120

Covenant not to compete, net

43,530

—

43,530

Total Other Assets

98,261

—

98,261

Total Assets

$

3,409,555

$

146,700

$

3,556,255

LIABILITIES AND SHAREHOLDERS’ EQUITY (DEFICIT)

Current Liabilities

Accounts payable

$

173,515

$

—

$

173,515

Customer deposits

79,061

—

79,061

Accrued payroll

100,451

—

100,451

Other accrued liabilities

342,635

—

342,635

Current portion of covenant not to compete

45,255

—

45,255

Total Current Liabilities

740,917

—

740,917

Long-Term Liabilities

Covenant not to compete, net of current portion

4,000

—

4,000

Total Liabilities

744,917

—

744,917

Shareholders’ Equity

Common stock

68,443

—

68,443

Additional paid-in capital

3,468,301

369,831

3,838,132

Accumulated deficit

(872,106

)

(223,131

)

(1,095,237

)

Total Shareholders’ Equity

2,664,638

146,700

2,811,338

Total Liabilities and Shareholders’ Equity

$

3,409,555

$

146,700

$

3,556,255

BALLISTIC RECOVERY SYSTEMS, INC.

STATEMENT OF OPERATIONS

Adjustment of

As Reported

Cirrus Warrant

Adjusted

9/30/2004

Valuation

9/30/2004

Sales

$

6,928,382

$

(369,831

)

$

6,558,551

Cost of Sales

4,252,531

—

4,252,531

Gross Profit

2,675,851

(369,831

)

2,306,020

Operating Expenses

Selling, general and administrative

1,494,447

—

1,494,447

Research and development

272,782

—

272,782

Intangible amortization

35,519

—

35,519

Total Operating Expenses

1,802,748

—

1,802,748

Income from Operations

873,103

(369,831

)

503,272

Other Income (Expense)

Interest expense

(7,875

)

—

(7,875

)

Other income (expense)

4,377

—

4,377

Net Other Expense

(3,498

)

—

(3,498

)

Income before income taxes

869,605

(369,831

)

499,774

Income tax expense

345,000

(146,700

)

198,300

Net Income

$

524,605

$

(223,131

)

$

301,474

The 1999 value of the purchase discounts forgiven to Cirrus was $604,000 in exchange for 1,400,000 warrants. The first set of warrants of 250,000 for January 2002 through February 2003 was never exercised. Therefore, the warrants exercised by Cirrus totaled 1,150,000 resulting in a discount of 18% (250,000/1,400,000). The value of the warrants we believe is $495,280 ($604,000 x 100%-18%). The Company has already expensed through a reduction of sales $20,799 in fiscal year 2003 and $104,650 in fiscal year 2004. The financial statements will be restated to show an additional reduction of sales of $369,831($495,280-$20,799-$104,650).

Income tax provision was decreased using the September 30, 2004 effective tax rate of 39.67% ($369,831 x 39.67% = $146,700).

It is our intention to amend accordingly, the Form 10-KSB for the fiscal year ended September 30, 2004.

If you want to discuss this or have any additional questions or comments regarding our responses or about the Company, the Form 10-KSB or this letter, please feel free to call me at 651-457-7491.

Very truly yours,
/s/ Robert Nelson