Ask the DAR

Inactive homebuilts from the 1970s, confusion about changing from SLSA to ELSA.


Question: I own an early ’70s homebuilt that has been inactive for the past 26 years. I’m still about two or three years away from getting it back in the air and have moved it from the airport to my home. However, the local authorities are taxing me $256 per year because it appears in the FAA registration database. What are the downsides to switching the registration to an N-number reservation, then switching back when the restoration is complete, thus saving the $500-$750 expense in the meantime?

Answer: I’m not sure this can even be done. I’ve never heard of it happening. You would have to research this with the FAA Registration Branch in Oklahoma City. If what you propose can be done, the next step would be working it out with the taxing authority.

Hint: Tax offices don’t like to deal with anything out of the ordinary. Many times if you protest with any kind of reasonable request, they will just drop it. As with most things, when dealing with any government office, the answer you get very often depends on who answers the phone.

Question: I have a Bushby Midget Mustang built in 1974. I have the FAA records for the aircraft, including when one owner decided to deregister the aircraft as being scrapped. He later attempted to get the registration back. In any case, I have a stripped airframe, no logs, and will be getting a new wing from Mustang Aeronautics. Will I qualify for the repairman certificate after assembling the airframe, or will I need to use my airframe mechanic license? I don’t have a powerplant mechanic license. If I participate in the rebuild of an engine and install it, will I qualify for the repairman certificate for the engine?

Answer: There are lots of unknowns here. First, if the aircraft was officially scrapped, was the owner able to get the registration back? If not, the aircraft is dead as far as the FAA is concerned. I’ve never heard of getting the registration back after an aircraft is scrapped.

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Even if you rebuild the aircraft and have the registration, you will never be the builder. Any work you do on the aircraft will be considered repairs and will not count toward the 51% rule. So no, you will not qualify for the repairman certificate for this aircraft.

A mechanic certificate with airframe only does not qualify one to perform the condition inspection on an Experimental/Amateur-Built aircraft. I have never heard of the FAA issuing a repairman certificate for engine only, relating to amateur-built aircraft. I think you are pretty much out of luck on this one.

Question: I find FAR 21.191(i)(3) rather confusing. Am I correct that only a maintenance-level LSA repairman or A&P mechanic can change an SLSA to ELSA?

Answer: Only the FAA or an FAA DAR can change an SLSA to an ELSA. This is actually a change in airworthiness category from Light Sport to Experimental.

I think your confusion has to do with who can sign off on the annual condition inspection. A mechanic with A&P ratings can perform inspections and maintenance on both ELSA and SLSA. After completing a 16-hour training course, the owner of an ELSA may apply for a repairman certificate with an inspection rating. This rating allows the owner to perform the annual condition inspection only on an aircraft that he or she owns.

Please send your questions for DAR Asberry to 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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