Larry,

However, if you have, for example, an engine failure at 400' on
departure, the CAPS is not an option.

How do you arrive at that conclusion?

My point is, that CAPS is not an option at the times it's needed most:
below 920'.

That's not what your own quote says. It says it is not an option if you
arrive at less than 920 feet after one full turn in a spin.

So to characterize the SR22 CAPS as a safety enhancement
(for other than spin recovery, and possibly a MAC, structural failure,
loss of control, and landing in inhospitable terrain, *if* they occur
above 920') is inappropriate.

Well, the people saved by it in different circumstances would probably
beg to differ.

--
Thomas Borchert (EDDH)