Ask the DAR

Aircraft weight, logbook entries, ultralights.

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Question: I am going to fly my airplane before having it painted and before I install the wheelpants. The empty weight now is 1067 pounds. Is it appropriate for me to estimate the final weight and enter it on the placard? Also, can I record the date of manufacture on the placard; the date I think I am finished with the aircraft before the airworthiness inspection?

Answer: The empty weight is not required on the data plate. You may put anything you wish. I would not use an estimated weight. If you state anything, I would use the current empty weight. Your empty weight will change periodically over the life of the airplane, but these weight changes are only reflected in the weight-and-balance documents and maintenance records.

Officially, the date of manufacture is the date of airworthiness issuance, but again, this information is not required on the data plate. The only information required on the data plate is the builder, model, and serial number.

Question: If I build a plane on floats and register it at the gross weight of 1430 pounds so it qualifies for LSA, and then later put it on conventional gear, will the airplane still qualify to be flown by a sport pilot? If so, do you have to document a reduction to 1320 pounds on the conventional gear, or can you keep the gross weight at 1430, assuming the gear can handle the weight? I don’t plan on doing this, but the thought occurred to me and I just wanted clarification.

Answer: You’ll be glad to hear that the answer to your question is yes. And you will need to document the gross weight difference while the aircraft is on wheels. It should not be listed as a change in gross weight, just a different gross weight for a different configuration.

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Question: I have not kept a running log while building the airplane. However, I did overhaul the engine, mags and carb while adhering to appropriate ADs. Can a simple statement be made in the logbooks, while all maintenance performed on the engine and components be made in a builder’s binder? What should the initial entry in the logbooks state?

Answer: Yes, a simple statement is sufficient for the logbooks. However, it would be wise to keep detailed records of everything you did for possible future resale value. The initial aircraft logbook entry should be:

“I certify that I built this aircraft for my own education and recreation. I have inspected it in accordance with FAR part 43 appendix D and consider it eligible for an experimental airworthiness certificate for the purpose of operating amateur-built aircraft under the provisions of FAR part 21.191(g).”

Be sure to sign and date the entry.

Question: I am looking at a complete flying Minimax with a 2 cylinder VW engine. It has been flown as an ultralight for 10 years. Can I buy it and continue flying it as an ultralight?

Answer: The ultralight rules haven’t changed. If the ultralight still meets Part 103, it can be flown as an ultralight. If it does not meet Part 103, that’s another story. It is not eligible to be certificated as an Experimental Light Sport. It could be certificated as an Experimental Amateur-Built if it meets Part 21.191(g).

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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