Ask the DAR

Engine data plate, airworthiness certificate issued by an IA, ELT requirements with ADS-B.


Question: I want to build a Fly Baby and power it with a Continental O-200. I’d like to buy a run-out engine and rebuild it myself. Can I do that if I don’t want to maintain it as a type-certified engine? Do I have to remove the engine data plate?

Answer: If you want to rebuild your engine, you may do so. However, you should keep in mind that sometimes things that are legal are not necessarily prudent. If you decide to do this, it’s a very good idea to do it under the supervision of someone that has experience rebuilding that particular model engine. Even a licensed A&P cannot legally rebuild an engine unless he has rebuilt that particular model before under the same supervision.

There is some disparity of opinion on removing the data plate. There is a regulation that says you may not remove the data plate from a certified engine. The opposing side says that it is no longer a certified engine, so you can remove the data plate. This is something best discussed with your DAR or FAA inspector.

Question: A local A&P IA is completely restoring a French WW-II warbird that has never been registered as a civilian aircraft. He claims he can declare it airworthy and the FAA will issue the certificate for Experimental/Exhibition on his written statement. Is this correct?

Answer: I’m not sure where this IA gets his information, but only an FAA inspector or a designated airworthiness representative may issue airworthiness certificates. While the FAA may give some credibility to his statement, he may not issue the certificate. The FAA or a DAR must find that the aircraft meets the requirements for the certificate requested.

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Question: Does the FAA currently require E/A-B aircraft that meet LSA requirements to have a working ELT and ADS-B In and Out? It seems reasonable to believe that once an aircraft is equipped with ADS-B, the ELT is no longer needed.

Answer: With a few exceptions, all U.S. registered civil airplanes must be equipped with an ELT. So unless the aircraft you are building fits one of the exceptions, such as a single-seat aircraft or a rotorcraft, it must be equipped with a valid ELT.

There are no regulations requiring ADS-B In or Out for any aircraft at this time. ADS-B Out will be a requirement beginning January 1, 2020, but that will not affect ELT requirements.

As far as ADS-B replacing the ELT, there are a few discrepancies in your thinking. First off, the ELT must be totally independent of the aircraft’s electrical system so that it will work regardless of the aircraft status. This is not true of the ADS-B system. Secondly, ADS-B will not be required outside of controlled airspace. Many aircraft that operate outside of, and never fly in, airspace where a transponder is required will not be required to install ADS-B. Third, aircraft not originally or subsequently equipped with an electrical system will not be required to install ADS-B. However, they must be equipped with an ELT.

In other words, if you should crash somewhere out in the boonies, ADS-B may or may not be picked up by anybody, especially if the aircraft electrical system is compromised during the crash. I hope this helps you understand the rules.

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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