Ask the DAR

Hiring a professional build center to build an Experimental Light Sport Aircraft.


Question: I know that an ELSA must be built originally as if it were an SLSA. If a build center builds the entire aircraft for a customer and it’s going to be registered as an ELSA, is there any wiggle room for it to be different than the original SLSA? For example, would it be possible to change the instrument panel or move the location of the throttle?

Answer: An ELSA must be built exactly per the plans with absolutely no changes of any kind for certification as an ELSA.

Question: If I hire a professional build center to build an ELSA, does the build center have to complete the entire airplane or can I build part of it? Is there a certain percentage the build center must complete? For example, can the build center do, say, 75 percent of the work and I build the remaining 25 percent?

Answer: There are no restrictions on the percentage of the build for an ELSA. The build center may build the entire aircraft or any part of it.

Question: With all of the different aircraft out there, how does a DAR determine if an airplane is built exactly to ELSA standards and mirrors the SLSA it’s supposed to replicate? Is it up to the individual DAR to let certain things pass the inspection and to focus more on the “spirit” of it meeting ELSA rules and regulations?

Answer: An individual DAR may not allow any changes from the plans.

Question: I’d like to contract with a build center to build most or all of an ELSA. However, I already know I’d like to change a few things. During the build, can they do things to make it easier for me to make modifications after certification?

For example, if I’m planning on converting from a carburetor to fuel injection, can they have the fuel line plumbing already in place to accommodate a return line? I’d like to avoid having to rip out and redo a lot of things I already know I’d like to change.

Answer: If you register your aircraft as ELSA, any changes from the plans must be done after certification.

Question: Can I build and certify an ELSA in my own hangar, or does an ELSA have to be built in an official builder center?

Answer: You can build an ELSA in your own hangar. It must be built from a certified ELSA kit with everything supplied by the kit manufacturer and be built exactly per the plans.

Question: From my understanding of the rules, once an ELSA has its airworthiness certificate, the owner can take a 16-hour maintenance course and is then allowed to make changes to the original design/equipment and also do his/her own maintenance and condition inspection. Are there any restrictions on what modifications can be done?

Answer: When you take the maintenance course, you still must apply for and receive the repairman certificate from the FAA. You do not need the certificate to maintain or modify your airplane. Anyone can do that. The repairman certificate only allows you to perform the condition inspection. After certification, you may make any changes that do not take the aircraft out of LSA parameters as stated in Part 1 of the FARs.

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. Hi Mel! I am a DAR in Oregon. I have converted several SLSA aircraft to ELSA, which has been treated as an “Amended” certificate, since per 8130.2j the category and operating limitations require amending. I have a new primary at the MIDO who says that the client must proffer through the AWC portal an ORIGINAL, not Amended application. How do you treat the SLSA to ELSA certification?


    Gary Brown


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