Ask the DAR

Sport Pilots, major changes and N numbers.




Question: I plan on buying or building a Light Sport Aircraft next year. What do I have to do to qualify as an LSA pilot? I currently hold a Private Pilot single-engine land and sea with a Third Class medical.

Answer: This is the kind of question that I enjoy answering. So many times I have to say, “Well, you just can’t get there from here.” But not this time.

I am happy to say that you are already there. A recreational pilot or above already qualifies as a Sport Pilot as long as his or her last medical was neither denied or revoked. You may simply allow your Third Class medical to expire and continue on with Light Sport Aircraft.

Question: I recently finished building a Cub kit and am past my Phase I flight time now. Before I built the Cub I had a PA-18 Super Cub and had a set of skis for it. I kept the skis and would like to install them on my new Cub too, but I’m unsure if doing so would require a new Phase I 5-hour testing schedule? Does putting skis on it constitute a major change? Reading part 21.93 on the FAA’s web site does not clear this up for me either. I’ve asked my local FSDO (Helena, Montana) the same question but get no response from them at all, so I’m hoping you can answer this for me: Would the installation of skis on an Experimental/Amateur-Built require a new testing phase? This is not an ELSA.

Answer: I can see how this could be construed as somewhat of a gray area according to 21.93.

However, it is my opinion that this would constitute a “major change.” It would likely affect your weight and balance, and would probably change the flight characteristics of the airplane, especially the takeoff and landing characteristics.

To be safe, I would recommend that you place the aircraft back into Phase I testing for a minimum of 5 hours.

When you do this, you will need to make a detailed logbook entry describing the change, and you would need to do the new flight-test phase only once. When you have completed flight testing for this configuration, it would not be necessary to do it again. In other words, once you have tested the aircraft in this particular configuration, you may change back and forth between wheels and skis without additional testing.

Question: I’m looking at a Light Sport Aircraft that was never N numbered. How can I get it numbered?

Answer: I’m not quite sure what you are asking. Has the aircraft never been certificated? What kind of aircraft is it that you wish to get the N number for?

A Light Sport Aircraft can be certificated by only three methods: First is an aircraft is built by a factory to ASTM standards under part 21.190. This is Special Light Sport Aircraft (SLSA) and is certificated before being sold to the individual. Second is under part 21.191(i)(2), which is an aircraft is built from an Experimental Light Sport Aircraft (ELSA) kit. Under this part, the kit manufacturer must supply you with a form 8130-15 showing that the kit complies with ASTM standards. The kit must be built exactly per the kit manufacturer’s plans and assembly instructions. The third way would be under 21.191(i)(3). This would be an aircraft that was originally certificated as an SLSA by a factory but is now to be “downgraded” to an ELSA.

Please send your questions for DAR Asberry to [email protected] 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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