Ask the DAR

Previously certified aircraft, ultralights, motorgliders and N-numbers.


Question: I’m rebuilding a 1942 L-2 Taylorcraft. I have to completely rebuild the wings and much of the fuselage. Can I recertify this aircraft as an Experimental so I can do the annuals in the future?

Answer: Unfortunately the answer is no. Any work done on a standard certificated aircraft is considered a repair and does not count toward building. FAA Order 8130.2G is very specific on this point.

Question: I’m preparing to build a legal ultralight of conventional layout and operating characteristics. If I register my ultralight as Experimental/Amateur-Built and get an N number, can I perform Phase I flight testing with just my USUA training and later do Sport Pilot solo training in the same craft? I’ll have 20 pounds or so to spare for the additional instrumentation and a handheld Nav/Com.

Answer: Congratulations on building your ultralight-legal amateur-built aircraft. Obviously, in order for you to log time in the aircraft, it must be registered and have an airworthiness certificate. Unfortunately, paragraph (18) of the operating limitations issued to Experimental/Amateur-Built aircraft states:

(18) The pilot in command of this aircraft must hold a pilot certificate or an authorized instructor’s logbook endorsement. The pilot in command also must meet the requirements of 61.3(e), (f), (g), (h), (i), and (j), as appropriate.

So, if you can find an instructor willing to make a logbook endorsement authorizing you to solo the aircraft, then you are good to go. Otherwise it’s a no-go.

Question: If I build a Pipistrel Virus with a 40-foot wing and 1320-pound gross weight, can I decide if it is a motorglider or does the DAR make that determination?

Answer: The guidelines for experimental glider qualifications can be found in CAM 1, section 1.73. My research confirms that the Pipistrel Virus should meet these requirements easily. The DAR/inspector may ask for documentation showing compliance. If he does, reference to the Pipistrel web site should be enough to convince him.

As far as compliance with LSA parameters, the web site also shows that the Pipistrel Virus should again pass easily.

Question: I’m building a Zenith CH-701 LSA. Is it legal to use 3-inch high letters for the N number? Some very experienced commercial and private pilots have advised me that I must apply 12-inch tall lettering for the N number.

Answer: You will be happy to know that you may use three-inch registration numbers on your CH-701. Twelve-inch numbers are required on Experimental/Amateur-Built aircraft that have a maximum calibrated cruise speed in excess of 180 knots. This is definitely not the case for the CH-701.

Your aircraft will be certificated under FAR 21.191(g). According to FAR part 45.29(b)(1)(iii), “Marks at least 3 inches high may be displayed on an aircraft for which the FAA has issued an experimental certificate under §21.191 (d), §21.191 (g), or §21.191 (i) of this chapter to operate as an exhibition aircraft, an amateur-built aircraft, or a light-sport aircraft when the maximum cruising speed of the aircraft does not exceed 180 knots CAS.”

Your friends may be thinking of Special Light-Sport aircraft. These aircraft are built by a factory and are not certificated in the Experimental/Amateur-Built category. Therefore they must display 12-inch numbers.

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

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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.


  1. I am a private pilot . I have built and flown my rv7a. I have my repairman’s certificate. Can i recertification this as alight sport. As it looks like it qualify’s with th new rulings.


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