Ask the DAR

Overweight LSA, paperwork confusion for a DAR inspection, converting an SLSA to an ELSA.

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Question: If you have an aircraft that qualifies as an LSA and add options and STCs that bump the gross weight above the LSA threshold, does the plane still qualify as a Light Sport Aircraft?

Answer: The definition of an LSA aircraft includes the statement that the aircraft must have met LSA parameters continuously since its original certification. If an aircraft originally met the parameters and has since been modified to increase the gross weight, then it no longer meets the definition of an LSA, even if it is returned to the original gross weight.

Question: I’m trying to complete the paperwork for a DAR inspection on a recently completed Experimental. The program letter asks yes or no to the following question: “I have received written acceptance from the local FSDO office for my Phase I test area.”

I am confused as to the answer I should give. I was under the impression that the DAR would be the approving authority for the Phase I test area. If that is true, I can’t answer yes to the question until after the aircraft is approved for flight. Please clarify.

Answer: Some FSDOs handle things differently. My FSDO allows me complete control with respect to assigning the phase I flight test area as long as I keep it reasonable. I’ve been doing this for a long time, and I’m very familiar with the surrounding airspace.

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It’s quite possible that your DAR is new and the FSDO wants to keep tighter reins on flight test areas until the DAR has shown that they are competent in that area. It’s also possible that the FSDO wants to be in the loop on all test areas. You need to contact your particular DAR and ask how they want you to proceed. They should know what that particular FSDO wants.

Question: I understand I can change my Sting S3 SLSA to an ELSA and then do my own maintenance and condition inspections, provided I take a 16-hour repairman inspection workshop offered by Rainbow Aviation Services. I also intend to take a two-day course at Lockwood Aviation on Rotax engines. If I do this, can my Sting be changed back to SLSA later if needed? I do not plan to do any changes to the Sting; I just want to do my own condition inspections. I have owned an AA-1 and AA-5 for the last 20 years and have done many owner-assisted annuals, so I feel well qualified. Is there any downside?

Answer: Yes, it is possible to change the ELSA Sling S3 back to an SLSA. However, only the original manufacturer has this authority. This means that they would have to go through the aircraft and certify that it meets all the original certification requirements. I doubt that they would want to take on this procedure. It would probably be quite costly.

Another option would be to go to Rainbow Aviation’s 120-hour repairman course. Yes, it is a much longer class, but it would allow you to perform the condition inspection on any Light Sport aircraft.

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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