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Builder Spotlight

March 2017 Issue




Ask the DAR

Applying for a Repairman Certificate, importing Experimentals, converting an SLSA Cub to ELSA.

Question: I'm working on the application for an E/AB Repairman Certificate and don't have a sample to help me fill it out. How do I complete Section II and Section III?

Answer: On FAA Form 8610-2, do not fill out Section II. On Section III, on the right side under "Type Work Performed," fill in make, model, and serial number as shown on the registration, and the date of aircraft certification. Don't sign it until you meet with the FSDO. They want you to sign it in front of them. That's about it.

Question: How do you import an Experimental airplane into the United States? Is there a simple list of the things you need to do to make this happen? It seems the info is a bit scattered. Most of what I can find simply says deregister here, register there, send in the bill of sale to the FAA, and slap on the new registration. Nowhere can I find the info regarding a DAR inspection, and/or other proof of E/A-B status. If you can point me in the right direction, I'd be grateful.

Answer: A Special Airworthiness Certificate issued to an Experimental/ Amateur-Built aircraft is a U.S. thing. When an Amateur-Built aircraft is brought into the U.S., it will not have a valid Airworthiness Certificate. To obtain a valid Airworthiness Certificate, it must be inspected and issued a Special Airworthiness Certificate in the Experimental category for the purpose of "operating Amateur-Built aircraft."

The requirements for the issuance of the airworthiness certificate are listed in FAA Order 8130.2H, Section 9, particularly paragraphs 454 & 455.

There are no provisions for "importing" an Amateur-Built aircraft from another country.

Under this order, the applicant must show, and the inspector must find, that the aircraft meets the requirements for the Airworthiness Certificate. Among these requirements is to show proof of the major portion rule, commonly known as the 51% rule.

Question: I own an SLSA Legend Cub and have always been concerned about what would happen to the value and support of my factory-built Cub if the company went out of business. Any thoughts on this would be greatly appreciated.

Also, would it be a good idea to convert it to ELSA? Could this be done later if the company were to shut down? Do I have to have the company's blessing before changing over to ELSA? Do you have any idea if switching to ELSA would affect the value?

Answer: Your concerns are valid. This has happened to other companies. If the company can no longer support an SLSA, then the SLSA would indeed need to be certificated in the Experimental category. It is a simple process—one would just apply for ELSA certification under 21.191(i)(3).

This is a common practice, and the manufacturer's "blessing" is not required. Whether or not it is a good idea is up to the individual. After recertification as an ELSA, the aircraft may no longer be used for hire or compensation. But it also eliminates the maintenance requirements set down by the manufacturer. Once it is an "Experimental," anyone can perform maintenance and/or modifications to the aircraft.

As far as affecting the value of the aircraft, there are differences of opinion. I personally have not seen that it affects the value at all, but there are people who disagree with me.

Please send your questions for DAR Asberry to editorial@kitplanes.com with “Ask the DAR” in the subject line.


Mel Asberry is an experienced Designated Airworthiness Representative specializing in Experimental/Amateur-Built aircraft. He and his wife, Ann, have built seven amateur-built airplanes including two ultralight types, a Moni Motorglider, a Dragonfly Mk2, two RV-6s and a Zenair CH 601HDS. They are currently building a scratch-built biplane.

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