Ask the DAR

Rebuilds, re-certification and registration.


Question: I purchased a used Experimental/Amateur-Built aircraft, a RANS S-6 that had been wrecked, and am rebuilding it. I understand that I must have an A&P sign off the repairs because I do not hold the Repairmans Certificate. What paperwork do I need to send to the FSDO when it is complete? Will I have to place the aircraft back in Phase I flight testing?

Answer: Actually you are not required to have an A&P sign off your repairs. Anyone can perform maintenance, repairs and even modifications on an Experimental/Amateur-Built aircraft. The only purpose of the Repairman Certificate is to allow performance of the condition inspection. Thats not to say it wouldn’t be prudent to have it inspected by a qualified individual, its just not required.

If you were to do modifications to the aircraft, you would need to follow your operating limitations. I don’t know when your S-6s operating limitations were issued. The wording has changed somewhat over the years, but there should be a paragraph giving explicit instructions on how to handle modifications. If you only do repairs and return the aircraft to the original configuration, it will be a simple logbook entry. On the other hand, if the aircraft is out of annual (condition inspection), then it would have to be signed off by an A&P or the original builder-if that person holds the Repairman Certificate.

Question: I own a Zodiac 601 HDS. I am not the builder. The 601 HDS does not qualify as an LSA because of the stall speed. I would like to add the HD wings, which would make the stall speed lower and allow the 601 to qualify for LSA. Would I have to re-certify the plane to make it LSA? Does the plane need to be inspected again?

Answer: First off, you can never re-certify an aircraft to make it LSA. If the aircraft meets Light Sport parameters, it may be flown by a Sport Pilot regardless of its classification. Many Sport Pilots build Experimental/Amateur-Built models that meet the LSA requirements and fly them on that type of certificate; Sport Pilots do not have to fly only ELSA or SLSA designs.

Changing the wings on your aircraft would require a model change by amending the airworthiness certificate and operating limitations. This could be done by either the FAA or a DAR holding function code 33. However, in your case, this would not solve your problem, as the Light Sport rules require that the aircraft must have continuously met LSA parameters from its original certification. Your aircraft has been certificated and flying with flight characteristics outside LSA rules, so it could never qualify as being Light Sport compliant. Sorry, I know this is not the answer you were looking for.

Question: I registered my airplane in 2009 thinking that I would be ready for inspection last year. I didn’t quite get it finished, and now it is obviously 2010. Do I have to do anything different (re-register it in 2010) because I have not done my airworthiness inspection?

Answer: Absolutely not. Many people register their aircraft before the certification year. As a matter of fact, if you look up N168TX, you’ll see that I did the same thing. I even set my serial number as 92006 and didn’t finish until 1993. No problem at all.

Please send your questions for DAR Asberry to [email protected] with Ask the DAR in the subject line.

Previous articleCarbon Cub Steals the STOL Show at Valdez
Next articleKit Stuff
Mel Asberry
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.


Please enter your comment!
Please enter your name here

This site uses Akismet to reduce spam. Learn how your comment data is processed.